Privacy Policy

GRAPHENEA S.A. Privacy Policy

Website (First Party Cookies and Analytics)




GRAPHENEA S.A. understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits our websites, and (“Our Sitess”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.


Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of Our Sites. If you do not accept and agree with this Privacy Policy, you must stop using Our Sites immediately.


  1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:



means an account required to access and/or use certain areas and features of Our Sites;


means a small text file placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in section 13, below;

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

“personal data”

means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via Our Sites. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and


means GRAPHENEA S.A., a limited company registered in Spain under company number A26004978, whose registered address is Pº Mikeletegi 83-2, 20010 San Sebastián, Guipúzcoa, Spain.


  1. Information About Us
      1. Our Sites is owned and operated by GRAPHENEA S.A. our VAT number is ES A26004978.
      2. Any data protection enquiries should be emails to


  1. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Sites. Our Sites may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.


  1. Your Rights
      1. As a data subject, you have a number of rights under the GDPR, which this Policy and our use of personal data have been designed to uphold
      2. If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the Spain’s supervisory authority, the Information Commissioner’s Office.
      3. For further information about your rights, please contact the ICO.


  1. What Data Do We Collect?

Depending upon your use of Our Sites, we may collect some or all of the following personal and non-personal data (please also see section 13 on our use of Cookies and similar technologies:


  1. name;
  2. business/company name;
  3. job title and/or profession;
  4. contact information such as email addresses and telephone numbers;
  5. demographic information such as post code, preferences and interests;
  6. IP address;
  7. web browser type and version;
  8. operating system;
  9. a list of URLs starting with a referring site, your activity on Our Sites, and the site you exit to;


  1. How Do We Use Your Data?


  1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
  2. Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:


  1. Providing and managing your Account;
  2. Providing and managing your access to Our Sites;
  3. Personalising and tailoring your experience on Our Sites;
  4. Supplying our productsAND/OR services to you (please note that we require your personal data in order to enter into a contract with you);
  5. Personalising and tailoring our productsAND/OR services for you;
  6. Replying to emails from you;
  7. Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing
  8. Market research;
  9. Analysing your use of Our Sites and gathering feedback to enable us to continually improve Our Sites and your user experience;
  1. With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by emailtelephone and/or post with information, news and offers on our productsAND/OR  We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
  2. You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it.
  3. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the periods outlined in our Data Retention Policy.


  1. How and Where Do We Store Your Data?


  1. We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.
  2. Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
  3. Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through Our Sites.
  4. Steps we take to secure and protect your data include:
      1. Password controlled
      2. Restricted access
      3. Not shared with third parties


  1. Do We Share Your Data?


  1. Subject to section 8.2,we will not share any of your data with any third parties.
  2. We may sometimes contract with third parties to supply products andservices to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
  3. We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
  4. We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within SPAIN and under the GDPR.
  5. In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.


  1. What Happens If Our Business Changes Hands?


  1. We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by us.
  2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.


  1. How Can You Control Your Data?


  1. When you submit personal data via Our Sites, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emailsand at the point of providing your details.
  2. You may also wish to sign up to one or more of the preference services operating in SPAIN: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.


  1. Your Right to Withhold Information


  1. You may access certain areas of Our Sites without providing any data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.
  2. You may restrict our use of Cookies. For more information, see section 13.


  1. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details at, or using the contact details below in section 14. Alternatively, please refer to our Data Protection Policy.


  1. Our Use of Cookies


  1. Our Sites may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve our products AND/OR In addition, Our Sites uses analytics services provided by Google, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Sites. For more details, please refer to our Cookie Policy.


  1. Contacting Us

If you have any questions about Our Sites or this Privacy Policy, please contact us by email at, or by telephone on +34 943359937. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 12, above).


  1. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Sites and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Sites following the alterations. We recommend that you check this page regularly to keep up-to-date.



Cookies Policy


GRAPHENEA uses cookies to store information on your computer to help provide a better user experience of our website.


Most of the cookies used do not collect personal information that identify a visitor. Some of the cookies are essential to allow the site to work properly and other are used by us to improve how the website works by giving us some insight into how the site is being used.


Where cookies do collect personal information, GRAPHENEA will not use this information for purposes which are not clear when you provide your details and will not disclose it to any other parties other than to the relevant authorities as requested.



Cookies are files that are saved to your computer or mobile device using your internet browser, which allow websites to recognise a user’s device. They organise and store browsing information


Cookies set by the GRAPHENEA website are referred to as "first-party cookies”. Other websites or services set cookies that run content on the page you are viewing such as Google Analytics.


A majority of websites use cookies to improve users’ experience. E.g., cookie enabled websites don’t think you’re a new visitor every time you move to a new page on a website and therefore improve your user experience by letting you navigate between pages quickly and easily without having to enter your username and password for each new page.


Cookies also allow a website to remember you, and your browsing preferences, either for the duration of your visit using a "session cookie" or for repeat visits using a "persistent cookie".


Cookie Policy

To make full use of the GRAPHENEA website, your computer or mobile device will need to accept cookies. By using our website, you consent that we can place cookies on your device.


The cookies are used to:

  • Ensure the site works as you would expect it to
  • Help us improve Our Sites based on insights from user visits


Data from our website is sent to your browser and is stored on your system.


If you do not wish cookies to store your data you can control the use of cookies and disable them by adjusting the security settings in your internet browser at any time; the ‘help’ function within your browser should tell you how to do this. Please note that you may not be able to use all the functions of our website if the cookies are disabled.


By visiting this site without adjusting your security settings, we assume that you are consenting to the use of cookies.



Cookies are used to retain user preferences, store information for things like shopping basket and log in, and provide anonymised tracking data to third party applications like Google Analytics to measure such things as how many people visit the site, how long they stay and what pages they visit. We do not use this information to identify individual visitors to the site.


More information on the Google Analytics privacy policy is available here


Cookies used 

First party cookies

First-party cookies are set by our website and they can only be read by that website. These cookies are essential so that the website works as expected during your visit. Make your experience on the web more efficient by recording your browsing activities, such as what pages and content you’ve looked at, when you visited, and what you searched for while visiting the website.


Cookie acceptance

This is used to remember the essential preference of your cookie consent, recording if a user has consented to the use of cookies on the website.


Session cookie

Session cookies are set when a user first loads a page and is crucial to the basic operation of the website. It is stored temporarily during the browsing session and is deleted from the user’s device when the browser is closed or the cookie times out. It does not store any user information; it is used to maintain a unique link between the browser and the site for the purposes of information requests and session data.


Performance cookies

We use some Performance Cookies to help us understand how people are using the website, so we can make it better.


Persistent cookies
Persistent cookie are saved on your computer for a fixed period and are not deleted when the browser is closed. These cookies are used to save your preferences, they persist when you return to the website to improve the user experience.



These cookies are used to collect information about how visitors access and use Our Sites. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Please note, some parts of the site will not work properly if you disable the use of cookies.