Privacy policy
Last updated: 7 August 2026
1. Data controller
- Controller: GONZALEZ CIURANA GABRIEL
- Tax ID (NIF): 40345015W
- Address: Carrer Calderers, 4 – 17004 Girona (Girona), Spain
- Email: info@programem.com
- Phone: +34 639 58 11 49
2. Purposes and legal bases of processing
- Answering enquiries received through the contact form: legal basis, the data subject's consent.
- Managing quotations, contracts, payments and invoicing: legal basis, performance of the contract and compliance with legal (tax and accounting) obligations.
- Sending commercial communications and the newsletter: legal basis, consent, revocable at any time.
- Preventing payment fraud: legal basis, the legitimate interest of the controller and of the payment institution.
3. Data retention
Data is retained for as long as the commercial relationship lasts and thereafter for the applicable statutory limitation periods (6 years for commercial and accounting records under the Spanish Commercial Code, and 4 years for tax obligations). Data processed on the basis of consent is kept until that consent is withdrawn.
4. Recipients and processors
No data is transferred to third parties except where legally required. The following processors are involved in providing the service:
- MONEI Digital Payments, S.L. – card payment processing. The provider has no access to the full card number.
- Hosting and email provider – maintenance of the technical infrastructure.
- Tax and accounting advisers – compliance with legal obligations.
5. Data subject rights
You may exercise your rights of access, rectification, erasure, objection, restriction of processing and data portability, as well as withdraw any consent given, by writing to info@programem.com or to the address above, enclosing a copy of your identity document.
If you believe the processing does not comply with the applicable rules, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).
6. Cookies
This website uses technical cookies necessary for the correct operation of browsing and language selection. You can configure your browser to block or delete cookies, bearing in mind that this may affect how the site works.
7. Security
The provider applies appropriate technical and organisational measures to ensure the security of personal data, including encrypted transmission via an SSL/TLS certificate.