PRIVACY AND COOKIE POLICY
This Privacy and Cookie Policy governs the processing of personal data and the use of cookies on the website [unionmusical.es / djmania.es / numemusic.es] (the “website”), owned by HOL MUSIC DRAL, S.L. (“HLM”). We recommend reading it carefully before browsing or using the services of the website.
Part I. Privacy Policy
1. Data controller
The controller responsible for the processing of personal data is HOL MUSIC DRAL, S.L., with registered office at Av. Ferrería 3, 08110 Montcada i Reixac (Barcelona) and tax ID B66589961. For any matter relating to data protection, you may write to [email protected].
HLM has appointed a Data Protection Officer, who can be contacted at [email protected].
2. Scope
This policy applies to the processing of personal data of professional customers and consumers, contacts of client companies and suppliers, website users and any person who interacts with HLM. It applies both to business-to-business sales (B2B) and to sales to consumers (B2C).
3. Data we process and how we obtain it
Personal data means any information relating to an identified or identifiable natural person. Depending on the relationship, HLM may process the following categories of data:
- Identification and contact data: name, company, address, telephone and email.
- Order and billing data: shipping and billing address, products purchased, amount and history.
- Payment data: only the reference needed to process the charge, never the full card details.
- Account data: username, password, preferences and language.
- Browsing and website usage data: IP address, browser, device, pages visited and data collected through cookies.
- Customer service data: queries, complaints and communications.
We obtain this data directly from the data subject, through forms and the purchase process, and automatically during browsing by means of cookies and similar technologies.
HLM does not request specially protected data (such as data relating to health, ideology, religion or ethnic or racial origin). Data subjects are asked not to include this type of data in their communications.
4. Purposes and legal bases
HLM processes personal data for the following purposes:
- To manage registration, orders and the contractual relationship, based on the performance of the contract or the pre-contractual measures requested by the data subject.
- To issue invoices and comply with legal, accounting and tax obligations, based on compliance with legal obligations.
- To handle queries, incidents, warranties and returns through Customer Service, based on the performance of the contract or HLM’s legitimate interest.
- To manage credit, collection and the prevention of late payment in business-to-business transactions, based on HLM’s legitimate interest.
- To send commercial communications about HLM’s products and services, based on the data subject’s consent or on legitimate interest where a prior relationship exists.
- To ensure the security, operation and improvement of the website, based on HLM’s legitimate interest.
5. Retention periods
HLM keeps the data for as long as necessary for the purpose for which it was collected and, thereafter, for the applicable legal limitation periods, in particular those provided for by commercial, accounting and tax regulations. When the data is no longer necessary, it is deleted or blocked in accordance with the law.
6. Recipients
HLM may share data with providers that render services on behalf of HLM (for example, transport and logistics, payment institutions and gateways, web hosting, email and analytics tools), acting as data processors under HLM’s instructions. Where necessary to manage warranties or repairs, data may be shared with manufacturers and technical services. An up-to-date list of the data processors is available to any data subject who requests it at [email protected].
HLM may also share data with public authorities and bodies where there is a legal obligation. Beyond these cases, HLM does not transfer data to third parties without a legitimate basis.
7. International transfers
HLM does not carry out international transfers of personal data outside the European Economic Area. Although some of HLM’s providers are international, they do not access customers’ personal data, nor does HLM provide them with per-customer information without express authorisation. If a transfer outside the European Economic Area were ever necessary, HLM would adopt the safeguards provided for by law, such as standard contractual clauses.
8. Rights of data subjects
The data subject may exercise the rights of access, rectification, erasure, objection, restriction of processing and portability, and may withdraw any consent given at any time, without affecting the lawfulness of prior processing.
To exercise these rights, they may contact HLM at [email protected], providing proof of identity. The data subject may also lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if they consider that their rights have not been properly addressed.
9. Security
HLM applies appropriate technical and organisational measures to protect personal data against loss, misuse or unauthorised access.
10. Links to third-party sites
The website may contain links to third-party sites unrelated to HLM. HLM does not control these sites and is not responsible for their content or their privacy policies. We recommend reviewing the privacy policies of those sites before providing them with data.
11. Social media
HLM has a presence on social media. When the user interacts with HLM through these channels, the processing of their data is also governed by the privacy policy of the relevant social network, which we recommend consulting.
12. Minors
The website and HLM’s services are aimed at persons of legal age. HLM does not knowingly collect data from minors without the consent of their legal representatives.
13. Changes to this policy
HLM may update this Policy to adapt it to regulatory or operational changes. The version in force will be the one published on the website at any given time.
Part II. Cookie Policy
1. What cookies are
Cookies are small files that are downloaded onto the user’s device when visiting a website and that allow, among other functions, remembering their preferences, measuring the use of the site or displaying tailored content. The term “cookies” here includes other tracking technologies with an equivalent function. Cookies cannot damage the user’s device.
2. Types of cookies we use
Depending on their purpose, the website may use the following categories of cookies:
| Category | Purpose | Consent |
| Technical or necessary | Enable the basic operation of the website, language, registration, login and order management. | Not required |
| Preferences or functional | Remember user options, such as language, region or login details. | Required |
| Analytics | Allow statistical measurement and analysis of website use to improve it. | Required |
| Marketing or advertising | Allow advertising tailored to the user’s interests based on their browsing. | Required |
The first category (technical or necessary) is essential for the website to function and is always active, so it cannot be rejected. The other categories are optional and are only activated with the user’s consent.
The detailed and up-to-date list of each cookie (name, provider, purpose and duration) is available in the cookie settings panel of the website, without the need to include it in this policy.
3. Legal basis and consent
Technical or necessary cookies are exempt from consent and cannot be rejected. The remaining cookies are only installed if the user gives their consent through the banner shown when accessing the website, where they can accept all cookies, reject the optional ones or configure them by category.
4. How to manage or withdraw consent
The user may modify or withdraw their consent at any time through the cookie settings panel available on the website. They may also block or delete cookies from their browser settings, although disabling technical or browsing cookies may affect the functioning of some parts of the website.
5. Third-party cookies
Some cookies may be managed by third parties that provide services to HLM, such as analytics or advertising tools. These third parties may process the data in accordance with their own policies, links to which are provided in the cookie settings panel.
6. Retention
Each cookie is kept for the time indicated in the settings panel, after which it expires or consent is renewed. Consent is requested again after the period provided for by applicable law.
7. Updates
HLM may update this Cookie Policy when the cookies used or the applicable regulations change. The version in force will be the one published on the website at any given time. For more information about the processing of personal data, see Part I of this document.