Synexis

Privacy Policy

Last updated: March 16, 2026

This Privacy Policy aims to provide information about the rights you are entitled to under Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR), as well as the Spanish Organic Law 3/2018, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD). At Moraleda Gestión & Capital SLP, we process the personal information you provide through the Synexis® platform in order to provide vehicle transfer management services and associated tools. Below is a transparent description of how and for what purpose your personal data is processed.

1. Data Controller and DPO identification

  • Data Controller: Moraleda Gestión & Capital SLP

  • Tax ID (CIF): B72516982

  • Postal Address: C. Comuneros, 12, 45300, Ocaña, Toledo

  • General email: info@moraledagestion.com

Data Protection Officer (DPO):

dpo@moraledagestion.com
This channel is available for any queries related to privacy, personal data processing, or the exercise of rights recognized by applicable regulations.

2. Data processed through the platform

The Synexis® platform collects and processes the following personal data provided voluntarily by the user, necessary for the provision of the contracted services:

A) Registration and authentication data

  • First name and last name: to create and manage the user account.

  • Email address: as account identifier and communication channel.

  • Phone number (optional): to facilitate communication about ongoing procedures.

  • Password: stored in encrypted form for secure authentication.

  • DNI/NIE (optional at registration): for user identification in administrative processes.

B) Profile data and transfer party data

  • Identity documents: type (DNI, NIE, CIF, Passport) and number, including algorithmic validation. Critical sensitivity data necessary for processing with the DGT.

  • Full address: street type, street name, number, staircase, floor, door, postal code, province, and municipality. Required for transfer documentation and contracts.

  • Legal representative data (for legal entities): name, surnames, type and number of the representative's identity document.

C) Vehicle and transaction data

  • Vehicle license plate: identifier required for DGT queries and transfer processing.

  • Vehicle Identification Number (VIN): for vehicle history reports and vehicle identity verification.

  • Vehicle technical data: make, model, first registration date, kilometers.

  • Sale price: for generating the purchase-sale contract and calculating the Property Transfer Tax (ITP).

All processed data comes directly from the data subject or from the counterparty in the transfer process, with prior acceptance of the terms of service.

3. Purpose of data processing

  1. User account management: registration, authentication, access recovery, and maintenance of the user profile.

  2. Vehicle transfer management: complete processing of the transfer between private parties, including communication with the General Directorate of Traffic (DGT), document generation, and coordination between the parties.

  3. Complementary tools and services: generation of purchase-sale contracts, ITP calculation, obtaining vehicle reports through official sources (DGT), and vehicle history reports.

  4. Service communications: transactional notifications about transfer status, account security alerts, and communications necessary for service provision.

  5. Statistical navigation analysis: through web traffic analysis tools, only when the user has given consent through the cookie banner.

4. Legal basis for processing

  • Performance of a contract (Art. 6.1.b GDPR): data processing is necessary for the provision of vehicle transfer services contracted by the user.

  • User consent (Art. 6.1.a GDPR): given when registering on the platform and accepting the service conditions, as well as when configuring cookie preferences.

  • Compliance with legal obligations (Art. 6.1.c GDPR): tax obligations, document retention, and cooperation with competent authorities.

  • Legitimate interest (Art. 6.1.f GDPR): for the management of essential technical cookies for the operation of the platform and service security.

5. Data retention period

  • Account data: as long as the account remains active. After account deletion request, data will be retained blocked for legally required periods.

  • Transfer data: during the contractual relationship and, subsequently, for applicable legal limitation periods (minimum 5 years for tax obligations and administrative documentation).

  • Cookie-related data: will be retained according to the periods defined in the Cookie Policy.

6. Data recipients and transfers

Moraleda Gestión & Capital SLP does not sell or transfer personal data to third parties for advertising purposes. Data may only be communicated in the following cases:

  • General Directorate of Traffic (DGT): as the competent public body, for processing vehicle ownership transfers.

  • Compliance with legal obligations: before competent public authorities (Tax Agency, regulatory bodies) when required by applicable regulations.

  • Technology service providers: acting as Data Processors (hosting services, cloud infrastructure, payment gateways), with whom the corresponding contracts have been signed in accordance with Article 28 of the GDPR.

No international data transfers are made outside the European Economic Area, except those derived from the use of certified technology providers, in which case the legally required guarantees apply, including the Standard Contractual Clauses approved by the European Commission.

7. User rights

The user may exercise the following rights at any time:

  • Access

  • Rectification

  • Erasure

  • Objection

  • Restriction of processing

  • Data portability

To do so, you must send a request to: dpo@moraledagestion.com with the subject "Exercise of Rights – Data Protection". In order to verify the identity of the applicant, a copy of a valid identification document may be required.

Likewise, the user has the right to file a complaint with the Spanish Data Protection Agency (AEPD) if they consider that the processing of their data does not comply with applicable regulations (www.aepd.es).

8. Automated decisions and profiling

No automated decisions or profiling that produce legal or significant effects on the user are carried out. Tax calculation tools (ITP) and vehicle queries provide indicative information and do not constitute binding decisions.

9. Information security

Moraleda Gestión & Capital SLP has adopted the necessary technical and organizational measures to guarantee the security, integrity, and confidentiality of personal data. These measures include: secure connections via HTTPS (SSL) protocol, encrypted password storage, httpOnly authentication tokens to prevent XSS attacks, role-based access control systems, and logical deletion (soft-delete) of data to ensure traceability.

10. Cookies and analytics tools

Detailed information about the use of cookies is available in the Cookie Policy.

11. Modifications to the Privacy Policy

Moraleda Gestión & Capital SLP reserves the right to modify this Privacy Policy to adapt it to legislative, jurisprudential developments or changes in the platform's operation. The date of the last update will always be visible at the beginning of this document.