S2M-group Privacy Policy


S2M-group Data Services & Software Holding, S.L. (later on referred as S2M-group) is a provider of B2B data for sales and marketing activities as well as service provider related to marketing activities performed on behalf of customers. This privacy policy describes how S2M-group handles procedures related to data and in what relation S2M-group acts as a Data Controller or Data Processor. This Privacy Policy statement is of a general character related to both data security and other data usage by S2M-group, a summary of matters related to General Data Protection Regulation may be found here. This policy shows S2M-group internal standards of Privacy Protection addressed both in daily activities as well as in all activities related to this webpage.




“Beneficiary or Customer” means any company or person entering a contractual relation with S2M-group due to provided Service or Product.

“Marketing and Sales Activities” means all activities related to service provided by the Company especially in the field of research, preparation of databases of targeted prospects, planning commercial actions, building brand awareness, performing outreach activities.

“Service” means all activities established in the Contract, as performed in line with marketing and sales purposes for the benefit of Beneficiary.

“Data Controller” means a person who defines why and how data is being processed.

“Data Processor” means anyone who processes data on behalf of Data Controller and in accordance with Controller’s will and agreed instruction.

“Data Subject” means anyone whose data is being processed.

“Visitor” means anyone who visits this website.



S2M-group may act as either Data Controller or Data Processor in following situations.

  1. S2M-group acts as Data Controller in relation to data of our Customers entrusted to us for the purpose of, for example, contract establishment or addressing potential questions concerning our service. Once you contact us via our webpage contact form available at email you entrust us your data and, consequently, we act as Data Controller. Furthermore, S2M-group acts as Data Controller in relation to data collected via Cookies – more about Cookies Policy available here.
  2. S2M-group acts as Data Controller in relation to data processed for its own marketing and sales activities defined solely by S2M-group and only for the benefit of S2M-group.
  3. S2M-group acts as Data Controller in relation to data of our Employees and potential Candidates applying for open positions via our job portal and entrusting us their data.
  4. S2M-group acts as Data Processor once being chosen to process data on behalf of the Customer, because in such circumstances S2M-group shall follow instructions of the Customer who is responsible for decision making regarding how, to what extent and when data shall be processed. Such relation is implied by the Contract signed between parties.



  1. During the course of Marketing and Sales Activities, acting either as Data Processor or Data Controller, S2M-group may collect following categories of data:
    1. Name
    2. Job title
    3. Company Details
    4. Email address
    5. Contextual information necessary to perform Service for the customer or necessary during the course of our own marketing or sales activities.

This list is not exclusive and serves as an indication of most often examples. Each activity performed by S2M-group may include some but not all of the information included in this example. Furthermore, it may be modified on the request of Data Controller.

  1. What is more, S2M-group may collect
    1. Information about your computer and about your visits to and use of this website, such as your IP address, geographical location, browser type, referral source, length of visit and number of page views.
    2. Information relating to any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you make of our products or services.
    3. Information that you provide to us for the purpose of registering with us.
    4. Information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters.
    5. Any other additional information you decide to share with us.



S2M-group collects data in different circumstances, major scenarios are described below. S2M-group may collect data or information to:

  1. Answer your question concerning our Product or Service, prepare pricing or detailed offer.
  2. Administer this webpage, help you in case of any quests and improve your browsing experience by personalizing the website.
  3. Send statements and invoices to you and collect payments from you.
  4. Send you general (non-marketing) commercial communications.
  5. Send you email notifications which you have specifically requested or update you when such action is necessary.
  6. Ask clarification questions regarding data processing performed on behalf of Data Controller.
  7. Send to you our newsletter and other marketing communications (relating to our business) which we think may be of interest to you by post, email or similar technology. You can inform us at any time if you no longer require marketing communications to be sent by using the unsubscribe option which will be in every marketing communication we send you.
  8. Statistic and research purposes presented in a form not containing personal data.
  9. Deal with enquiries and complaints made by or about you relating to the website
  10. Contact individuals during the course of Marketing or Sales activities performed on behalf of Data Controller.



In addition to the disclosures reasonably necessary for the purposes identified elsewhere in this privacy policy, we may disclose information about you:

  1. To the extent that we are required to do so by law.
  2. In connection with any legal proceedings or prospective legal proceedings.
  3. In order to establish, exercise or defend our legal rights in case of any legal or administrative proceeding.
  4. To the purchaser [or prospective purchaser] of any business or asset which we are [or are contemplating] selling.

Except as provided in this Privacy Policy, we will not provide your information to third parties.



  1. Once acting as Data Controller, S2M-group is obliged to grant possibility to delete, correct or return data. Where your information is processed by S2M-group or if you are from the European Union or European Economic Area you have certain rights concerning processing standards guaranteed by General Data Protection Regulation. You can find more about your data protection rights in our GDPR compliance statement available here.
  2. Once acting as Data Processor, S2M-group shall obey notification duty towards Data Controller and notify about any direct request to delete, correct or return data. Furthermore, S2M-group is obliged not to perform any action without a written request from Data Controller. Such request may be delivered via email to



S2M-group is dedicated to ensuring an adequate level of protection internally as well as to assist Data Controllers in their duties. That is why, as Data Processor, we are willing to assist in case of Risk Assessment preparations by providing necessary information to assess the risk arising out of choosing us as Data Processor. Such help needs to be reasonably bounded by what is possible from business and technical perspective and should not raise any costs to S2M-group.




  1. If you decide to contact S2M-group via webpage contact form (including job applications) or directly via email you agree that we need to process your data to provide you with an answer or address your claim. By such activity, we understand that you agree to data processing.
  2. If we collect your data as Data Processor on behalf of Data Controller we either rely on consent collected by Data Controller or on their Legitimate Interest. S2M-group shall not be responsible for the quality of consent forms on the opt-in procedure performed by the Controller.
  3. If we collect your data on our own benefit and process such data during Marketing or Sales activities as Data Controller, we rely either on your consent given to S2M-group or on our Legitimate Interest as Data Controller based upon art. 6(1)(f) and Recital 47 of General Data Protection Regulation.



S2M-group reserves its right to update or amend this Privacy Policy. At the same time, by current Privacy Policy, we understand the one present at this webpage.




If you have any concerns regarding data safety, how we keep data or what measures we provide you can always contact us via