1. Data controller

      • Identity: SMART FLASH S.L
      • Tax Code: B-67122168
      • Postal address: Avenida Diagonal 419, 5º-2ª, 08008, Barcelona, Spain.
      • Email:
      • Data processor: SMART FLASH SL
      • Contact details of the data processor: SMART FLASH SL, Avenida Diagonal 419, 5º-2ª, 08008, Barcelona, Spain,, E-mail:

 SMART FLASH S.L., as the data controller for the platform, in accordance with the provisions of EU Regulation 2016/679, of 27 April 2016 (GDPR) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and other current legislation on personal data protection, and of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce, informs you that it has implemented the necessary security measures, of a technical and organisational nature, to guarantee and protect the confidentiality, integrity and availability of the data entered.

The platform is comprised of the website and the corresponding mobile application (hereinafter collectively known as the ‘Platform’).



2. Data processed

SMART FLASH S.L. processes the following personal data that it accesses through the following channels:

  1. Data from the Platform Forms and the User Profile: to be able to register as a user of the Application (the «User» or «Users»), the User must complete the electronic registration form that appears on the Platform by providing a number of pieces of data required to provide our services. The personal data collection form specifies the data that must be provided by users, so if a user refuses to provide such data they will not be able to register as a User. Similarly, being a User registered on the Platform implies having a profile with open fields in which the User can enter whatever they consider to be appropriate (except the Prohibited Data listed below).
    The data requested in the registration form are: (1) e-mail address or login details for your Facebook account, (2) username and (3) password if an e-mail address is used to register.
  2. Data provided by third-party companies: the User may have the option not to fill in the registration form but rather to log in to the Platform through user accounts from third-party companies such as Facebook, Inc. The User understands that these companies will provide us with certain data about them in accordance with the privacy policies and/or cookies of these companies (to which the User has previously consented). SMART FLASH S.L. will make its best efforts not to access more data than is necessary to ensure a good user experience and the correct operation of the Platform.
  3. Data processed automatically by the Application: when using the Application, it automatically accesses a series of pieces of data and elements from the mobile device on which it is installed. Most operating systems inform the user before allowing the Application to download and some of them allow the user to limit this access (although this may impede the normal use of the Application). The current version of the Application uses the following accesses (with the processing of personal data that each access implies): (1) access to the device’s camera, (2) information on the device’s Wi-Fi connection, (3) device identifier, (4) configuration of the device’s language and country and (5) geolocation data.
  4. Data associated with the browsing on the Platform: When a User accesses any of the Platform’s formats, SMART FLASH S.L. collects the browsing data associated with each User. In this way, all actions carried out by the User within the Platform are collected (for example, opening a chat, having a set of photos available, downloading purchased photos, etc.), which are associated with the user ID, IP address, general information about the device and its operating system/browser, the date and time, as well as the IDs of all other elements associated with that action.
  5. Data associated with the Cookie Policy: consult our Platform’s cookie policy in website format.
  6. Data on your communications with SMART FLASH SL: when sending us a communication, we collect its metadata (date and time of the call or e-mail, identity of the sender and receiver, technical data) and the data incorporated into any communication between the User and SMART FLASH S.L.
    In any case, it is prohibited to send SMART FLASH S.L. or publish on the Platform (especially but not only in the User Content) any content that contravenes any prohibition or limitation established in the Conditions of Use (especially but not limited to the prohibition on using personal data, those of both the User and third parties, which contain sensitive information regarding identifiable or identified persons, such as: racial origin; union membership; religion, ideology or sexual orientation; health data; or data regarding criminal records, proceedings and sanctions or fines deriving from them, or a breach of monetary obligations).
    The User guarantees (a) the authenticity and accuracy of all data (especially but not limited to personal data) that they communicate through the Platform, (b) that they are their own personal data or their own image, or that they have the permission of the data subject to use these data, and (c) that they will keep the information provided to SMART FLASH S.L. updated so that it corresponds to their current situation at all times, being solely responsible for any false or inaccurate statements they make, as well as any damage this may cause to SMART FLASH S.L. or to third parties.


3. Purpose of the processing

Your personal data will only be used for the following purposes:


  • To carry out the necessary commercial and administrative procedures with the users of the platform.
        • To send or display electronic commercial communications, within the scope of the SMART FLASH S.L. service of information or electronic commerce. The User will have the option to object to receiving regular electronic commercial communications (including e-mails) that promote or advertise the services and products offered by SMART FLASH S.L
        • To respond to queries and/or provide information required by the User.
        • To provide services and/or products purchased or subscribed by the User.
        • To use your data to contact you, both electronically and non-electronically, to obtain your opinion on the service provided.
        • To notify you of changes and important developments to the privacy policy, legal notice or cookie policy.

To perform profile and usability analyses.

  • The data of customers and/or suppliers will be processed, within the contractual relationship that links them to the controller, in compliance with the administrative, tax, accounting and labour obligations that are necessary under the current legislation.

The purposes of the data processing, by category, are:

      • Category «a) Data from Platform and Profile Forms»: the platform (especially the Website) may include forms that are clearly linked to specific purposes and this is indicated on the Platform itself (for example, the data collected in the «contact form» will be processed for the purpose of responding to and communicating with whoever wishes to communicate with SMART FLASH S.L.).
      • Category «f) Data associated with the Cookie Policy»: they will also be processed for the purposes indicated in the Cookie Policy.

To unsubscribe and revoke your consent at any time you can send an e-mail with the subject ‘User Unsubscription’ to, including in the body of the e-mail the username and e-mail address, or username in the social network used when registering for the Platform.

In accordance with Law 34/2002, of 11 July, regarding Information Society Services and Electronic commerce, SMART FLASH S.L. does not perform SPAM practices, therefore it does not send commercial messages by e-mail that have not been previously requested or authorised by the User. As a result, in all communications received from SMART FLASH S.L., the user has the option to cancel their express consent to receiving our communications.

We will not process your data for any purposes other than those described, except when legally obliged to do so or when this is ordered by a court.

Your data will be retained for the duration of your commercial relationship with us, or until you exercise your right to erasure, to object or to restrict processing. However, we will retain certain personal identification and traffic data for a maximum period of 2 years in case it is required by the Courts, or to initiate internal actions deriving from the misuse of the website.

It will not be subject to decisions based on automated processing that affect your data.


4. Necessary acceptance of the User

The legal basis for the processing of data is your consent granted for the aforementioned purposes, which will be requested when the user registers on the platform and accepts the conditions of the service.

Not providing the personal data requested or not accepting this data protection policy means that you cannot subscribe, register or receive information regarding the Provider’s products and services.

In cases where there is a prior contractual relationship between the parties, the legitimation for developing the administrative, tax, accounting and labour obligations necessary under the current legislation will be the prior existence of the commercial relationship established between the parties.


5. Communications

Any communication sent will be incorporated into the computer systems of SMART FLASH S.L. By accepting these terms, conditions and policies, the User expressly consents to SMART FLASH S.L. performing the following activities and/or actions, unless the User indicates otherwise:

      • The sending of commercial and/or promotional communications through any enabled means, informing Users about the activities, services, promotions, publicity, news, offers and other information regarding the services and products related to the activity.
      • In the event that the User has expressly consented to the sending of commercial e-mails by subscribing to the NEWSLETTER, these communications will be sent electronically to inform Users of the activities, services, promotions, publicity, news, offers and other information regarding the services and products of SMART FLASH S.L., which are the same as or similar to those that were initially purchased by or of interest to the User.
      • The retention of data for the periods set forth in the applicable provisions.


6. Official means of communication

The user is informed that the means enabled by the company to communicate with customers and other affected parties is the corporate e-mail address: o

If you send personal information through a means of communication other than those indicated in this section, SMART FLASH S.L. will be exempt from any liability with regard to the security measures offered by the means in question.


7. Recipients of assignments or transfers and viewing consen

SMART FLASH S.L. may carry out transfers to third parties, who will process and handle the data, as well as make international transfers for the same purpose. The user expressly accepts that the assignment of their data is limited to the purposes indicated in this document.

The service provider will also pass on information to security forces and bodies under court order or when obliged to do so by a legal rule, without prejudice to being able to block or delete your account if there may be indications that the user has committed a crime. The information passed on will only be that available to the service provider at that time.

Users know, accept and are considered informed that, in accordance with their settings and actions on the Platform, some personal data (the User decides which) may be consulted or viewed by other users of the Platform in accordance with this Privacy Policy and the Conditions of Use for the purposes of providing the service as indicated in the Conditions of Use.

The information you provide to us through the application will be stored on the servers of SMART FLASH S.L.


8. Rights of data subjects

As the user-data subject, you may contact SMART FLASH exercise the following rights, writing a letter to the postal address listed in the header or sending an e-mail to, indicating as the subject: ‘GDPR: Affected rights’, attaching a photocopy of your national identity card or any other similar means, as indicated by law.


      • Right to access: allows the data subject to discover and obtain information about their personal data subject to processing.
      • Right to rectification or deletion: allows you to correct errors and amend any data that may be inaccurate or incomplete.
      • Right to be forgotten: allows you to erase data that are inadequate or excessive.
      • Right to object: the right of the data subject to not have their personal data processed or to stop such processing.
      • Right to restrict processing: involves marking the personal data retained to limit its future processing.
      • Data portability: provision of the data being processed to the data subject, so that it can transfer them to another data controller without impediment.
      • The right to not be subject to automated individual decision-making (including profiling): the right to not be subject to a decision based on automated processing which produces legal effects or similarly significantly affects you.

As a user, you have the right to withdraw your consent at any time. Withdrawal of this consent will not affect the lawfulness of the processing carried out before consent is withdrawn.

You also have the right to submit a complaint to the supervisory body if you believe that your rights with regard to the protection of your data may have been violated (in Spain, this means contacting


9. Additional information


Through this Privacy Policy, we inform you that the photographs posted on the platform are owned by SMART FLASH S.L., including those of minors where, in order to obtain them, the prior consent of their parents, guardians or legal representatives has been obtained through the signing of the forms created for this purpose by the centres of which these minors form a part.


We inform you that SMART FLASH S.L. may be present on social networks. The data processing carried out in relation to people who become followers in the social networks (and/or create any link or connection action through the social networks) of the official pages of SMART FLASH S.L. will be governed by this section, as well as by the conditions of use, privacy policies and access rules of the applicable social network in each case and accepted previously by the user.

SMART FLASH S.L. will process your data for the purposes of correctly managing your presence on the social network, informing you of the activities, products or services of the service provider, as well as for any other purpose permitted by the social networks.

It is prohibited to publish content:

      • That is allegedly illegal under national, community or international legislation, or includes activities that are allegedly illegal or contravene the principles of good faith.
      • That violates the fundamental rights of people, does not meet the network’s courtesy standards, annoys or may generate negative opinions in our users or third parties, and generally any content that SMART FLASH S.L. deems inappropriate.
      • And that generally contravenes the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of private life, protection of the consumer and intellectual and industrial property rights.

SMART FLASH S.L. also reserves the right to withdraw from the social network, without prior notice, the content it deems inappropriate.

Communications sent through social networks will be entered into a file owned by SMART FLASH S.L., who may send you information of interest to you.

You can find more information, as well as consult the companies who form part of our group, in this privacy policy.

In any case, if you send personal information through the social network, SMART FLASH S.L. will be exempt from liability with regard to the security measures applicable to this platform. The user must, should they want to know them, consult the corresponding particular conditions of the social network in question.


The data you provide will be processed confidentially. The Provider has adopted all technical and organisational measures and all levels of protection necessary to ensure security when processing data and prevent their alteration, loss, theft, unauthorised processing or access, in accordance with the current state of technology and the nature of the stored data. It also ensures that the processing and recording in files, programs, systems or equipment, local and central, complies with the requirements and conditions of integrity and security established in the current regulations.


10. Changes to the privacy policy

SMART FLASH S.L. reserves the right to amend this policy to adapt it to new legislation or jurisprudence.
In any case, any amendment to the privacy policy will be notified to users.


11. Legislation

For all purposes, the relationships between SMART FLASH S.L. and Users of its telematic services, present on this platform, are subject to Spanish legislation and jurisdiction, to which the parties expressly submit. All conflicts deriving from or related to its use will be resolved by the competent Courts of Barcelona.