1. DATA CONTROLLER
OPTIMITIVE S.L., Tax ID: B01636166; registered address: Avda. de los Huetos, nĀŗ 75, Edificio Azucarera, 01010 Vitoria-Gasteiz (Ćlava), Spain. Email: rrhh@optimitive.com. Phone: (+34) 945.298.120
2. WHAT DATA DO WE PROCESS AND FOR WHAT PURPOSE?
2.1. Contact forms and information requests
What data do we collect? Full name, email address, and the content of your inquiry or message.
What do we use it for? To handle and manage inquiries, information requests, or contact submissions made through the website forms, as well as to follow up on any commercial opportunities that may arise.
What is the legal basis? Processing necessary for the application of pre-contractual measures at your request, and legitimate interest in handling information requests and managing commercial opportunities in a B2B context.
How long do we retain your data? Personal data associated with inquiries will be retained for a period of one (1) year from the last interaction. If the inquiry results in a contractual relationship, the data will be incorporated into the corresponding file and retained in accordance with the terms established for the relationship between Optimitive and the client, as set out in the contract generated, which will include the relevant information regarding the processing of personal data.
2.2. Newsletter and commercial communications
What data do we collect? Full name and email address.
What do we use it for? Sending newsletters, informational bulletins, commercial communications about our services, event invitations, and promotion of products related to our activity.
What is the legal basis? Your explicit consent when you voluntarily subscribe to the newsletter service (Article 6.1.a of the GDPR).
How long do we retain your data? Your data will be retained until you withdraw your consent or unsubscribe from the service. If your data remains inactive (with no interaction for two consecutive years), we will proceed with its automatic deletion. You may unsubscribe at any time by using the link included in each communication or by contacting us at info@optimitive.com.
2.3. Analysis of website use and performance through cookies
What data do we collect? IP address; browsing data; technical device information.
What do we use it for? To ensure the correct technical functioning of the website; to analyze website usage for statistical purposes; to improve the user browsing experience.
What is the legal basis? Legitimate interest (technical and preference cookies) and user consent (in the case of analytics and marketing cookies).
How long do we retain your data? Personal data collected through cookies will be retained for a maximum period of two years, or until the user withdraws their consent or exercises their right to object. You may withdraw your consent to the use of analytics and marketing cookies at any time by adjusting the cookie settings tool available on the website.
3. WHO DO WE SHARE YOUR DATA WITH?
Your personal data will not be shared with third parties, except where there is a legal obligation requiring it, or to satisfy a legitimate interest pursued by Optimitive ā specifically, the filing of legal actions or the exercise of defense against such actions.
Additionally, please be aware that certain technology providers working with Optimitive may access your personal data in their capacity as data processors, which does not constitute a data transfer or disclosure for these purposes. In any case, access by such processors will be carried out under the corresponding contractual guarantees established by Optimitive with them.
4. INTERNATIONAL DATA TRANSFERS
In the context of managing analytics cookies used on the website ā particularly through Google Analytics (provided by Google LLC) ā international data transfers outside the European Economic Area (EEA), specifically to the United States, may take place.
These transfers arise from the processing of browsing data (such as IP addresses and other technical identifiers) required for statistical analysis of website usage. In such cases, Optimitive ensures that these transfers are carried out with adequate safeguards in accordance with applicable data protection regulations, including, where applicable, the execution of Standard Contractual Clauses approved by the European Commission, and, where relevant, other safeguards recognized by the GDPR, including adequacy decisions adopted by the European Commission.
Beyond the above, we confirm that no additional international transfers of personal data outside the European Economic Area (EEA) are carried out.
You can consult the updated list of countries with an adequacy decision at: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
You may request additional information about international transfers and obtain a copy of the applicable safeguards by contacting us at rrhh@optimitive.com.
5. YOUR RIGHTS
As the owner of your personal data, you may exercise the following rights at any time:
Right of access: Obtain confirmation of whether we are processing your personal data and, if so, access it and obtain information about the purposes, categories of data, recipients, and retention periods.
Right to rectification: Request the correction of inaccurate or incomplete data.
Right to erasure ("right to be forgotten"): Request the deletion of your data when it is no longer necessary for the purposes for which it was collected, when you withdraw your consent, when you object to the processing, or when the processing is unlawful. This right is not absolute and may not apply where there is a legal obligation to retain the data or where it is necessary for the exercise or defense of legal claims.
Right to restriction of processing: Request that we retain your data but not process it, when you contest the accuracy of the data, the processing is unlawful but you oppose its deletion, or you need it for the exercise or defense of legal claims.
Right to object: Object at any time to the processing of your data on grounds relating to your particular situation, especially when the processing is based on legitimate interest. We also remind you that you may object to or withdraw your consent to the sending of commercial communications, as well as to the use of cookies for analytics and marketing purposes.
Right to data portability: Receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and transmit it to another controller, where the processing is based on consent or a contract and is carried out by automated means.
Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of the processing carried out prior to the withdrawal.
Right not to be subject to automated decision-making: You have the right not to be subject to a decision based solely on automated processing that produces legal effects or significantly affects you. OPTIMITIVE does not currently carry out this type of automated decision-making.
6. HOW TO EXERCISE YOUR RIGHTS
To exercise any of the rights listed above, you may submit a written request to OPTIMITIVE through:
Email: rrhh@optimitive.com
Postal address: OPTIMITIVE S.L. Avda. de los Huetos, nĀŗ 75, Edificio Azucarera 01010 Vitoria-Gasteiz (Ćlava), Spain
7. SECURITY OF YOUR DATA
OPTIMITIVE has implemented the necessary technical and organizational measures to ensure the security of personal data and prevent its alteration, loss, unauthorized processing, or access, in accordance with Article 32 of the GDPR.
We operate an Information Security Management System certified under the ISO/IEC 27001:2022 standard, which ensures a systematic and documented approach to security, subject to ongoing review and continuous improvement.
Implemented measures include access controls, data encryption, network security, data backups, a security breach management protocol, and ongoing staff training.
8. COMPLAINTS TO THE SUPERVISORY AUTHORITY
Without prejudice to the exercise of your rights, if you consider that we have not properly handled your requests or that we have violated your rights, you may lodge a complaint with the Spanish Data Protection Agency (AEPD):
Address: C/ Jorge Juan, 6, 28001 Madrid, Spain Phone: 901 100 099 / 912 663 517 Electronic office: https://sedeagpd.gob.es
9. CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may change over time due to possible shifts in the criteria applied by supervisory authorities, legislative amendments, or relevant case law. Optimitive therefore reserves the right to modify this Privacy Policy in order to adapt it to such criteria, as well as to new case law or legislative developments.
Last updated: May 7, 2026.
For any questions about this privacy policy or the processing of your personal data, please contact us at rrhh@optimitive.com.