Privacy Policy

Your privacy and trust are important to us, which is why this Privacy Policy provides you with important information about how we process your personal information. We recommend that you read the following carefully and, if you have any questions afterward, you may contact us through our contact form.

This Privacy Policy applies to https://transaffirmationunit.com/ in accordance with the provisions of our Legal Notice and Terms of Use.

Data Controller and declaration of regulatory compliance.

The owner of this website and data controller is CLÍNICA SAN CLEMENTE SL (operating under the trade name “Trans Affirmation Unit”, and hereinafter referred to by this name), a company registered in the Commercial Registry of Zaragoza at Volume 3943, Folio 184, Section 8, Sheet Z-54165, Entry 1, with Tax ID No. B72570872 and registered office located at Calle Sanclemente, 4, Entlo. Ctro., Postal Code 50001 Zaragoza (Spain).

If you wish to contact us, you may do so through our:

  • Contact Form

  • Telephone: (+34) 601031708

  • Email: info@transaffirmationunit.com

Or if you prefer, you may send us a postal communication to the address mentioned above. If your inquiry is related to our use of your personal data or if you wish to unsubscribe from any of our services, you may contact our Data Protection Officer (DPO) at the following addresses:

  • Postal Address: Calle Sanclemente, 4, Entlo. Ctro., Postal Code 50001 Zaragoza (Spain)

  • Email: info@transaffirmationunit.com

“Trans Affirmation Unit” declares its compliance with current Spanish and European legislation on Personal Data Protection, specifically Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016, Organic Law 3/2018 of December 5 on the Protection of Personal Data and guarantee of digital rights, and in accordance with the state of technology, the nature of the data and the risks to which they are exposed, “Trans Affirmation Unit” declares that it applies appropriate technical and organizational measures to ensure the confidentiality and privacy of personal data collected through this website, as well as their integrity, availability and security, taking the necessary actions to prevent any alteration, loss, unauthorized access or fraudulent use of the data processed.

“Trans Affirmation Unit” guarantees that the User’s personal data are processed lawfully, fairly and transparently, and that they have been collected with the explicit consent of the User following information about the purpose of the processing expressly set out in this Privacy Policy.

“Trans Affirmation Unit” will not process or share users’ personal data except as permitted by current regulations, at the request of competent authorities or when it has the express and previously informed consent of the User.

“Trans Affirmation Unit” will not use users’ personal data for purposes other than those previously informed prior to the submission of data by the User.

Personal information and processing of personal data. What does this mean?

Personal information refers to any information relating to an identified or identifiable natural person, directly or indirectly, (name, identification number, location data or specific factors of the physical, psychological, genetic, mental, economic, cultural or social identity of the person, precise geographic location information, financial information and bank account numbers, as well as unique identification elements, such as ID numbers, IP, MAC, social security, driver’s license, etc.). Specially protected personal information is that related to race or ethnic origin, political opinions, religious beliefs, membership in workers’ associations, physical or mental health, additional medical information, including biometric and genetic data or sexual preferences, background or convictions.

The operations, management and technical procedures carried out in an automated or non-automated manner that enable the collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of enabling access or interconnection, restriction, erasure or destruction of personal data or sets of personal data are considered processing of personal data.

“Trans Affirmation Unit” does not collect or process personal data related to specially protected personal information of users through the website. If you wish to know how we process your personal data, we invite you to continue reading this Privacy Policy.

How we use personal information

Transparency and information on personal data protection. We want to make our privacy practices clear so that you can make informed decisions about the use of your personal information by “Trans Affirmation Unit”. Our values for the processing of personal data:

  • Lawfulness and fairness: We will always require your prior consent for the processing of your personal data for one or more specific purposes that will be informed prior to the submission of your data. Unless the processing of your personal data is based on some other legitimate basis in accordance with applicable current legislation.

  • Minimization: We only require from users the data strictly necessary in relation to the purposes of the processing of the data.

  • Storage limitation: We retain data for the time necessary according to the purpose of the processing, informing in each case of the retention period. We review and update personal databases by removing inactive records or those that are no longer necessary because the purpose of the processing has ended.

  • Confidentiality: We apply appropriate technical and organizational security measures for the processing of personal data ensuring their confidentiality and minimizing the risk of unauthorized access or misuse of users’ personal data by third parties.

  • Transparency: In this policy you will find all information relating to the use that “Trans Affirmation Unit” makes of your personal data. In general, we collect, use, disclose, transfer and store personal information when necessary to provide our services and for our operational and business purposes, as described in this Privacy Policy.

We invite you to contact us if you have questions or concerns regarding the processing of your personal data through our contact form.

How do we obtain your data? Type of personal information we collect.

We collect your personal information through:

  • The Contact Form

  • The use of Cookies

  • When you exercise any of your data protection rights with us.

Through the aforementioned channels we may collect the following information:

  • Name and surname

  • Tax ID (only in the event that a data protection right is exercised and provided by the user to verify their identity)

  • Phone

  • Address

  • City

  • Email address

  • Any other information and/or files that you freely decide to provide to “Trans Affirmation Unit”

  • Information collected through the use of cookies, which you may consult in our Cookie Policy.

Your commitment, the accuracy of the data you provide us. The User declares that the personal data provided to “Trans Affirmation Unit” at any stage of the use of this website are accurate.

As a User you should know that you are solely responsible for any damage or harm, direct or indirect, that may be caused to “Trans Affirmation Unit” as the controller of this website or to a third party if you complete any form with false data or data of third parties without their prior consent causing deception, damage or harm. In order for us to keep your data accurate and up to date, we ask the User to communicate any changes that may occur in the data provided.

Consent of minors.

“Trans Affirmation Unit” prohibits the submission of personal data through this website by users under 14 years of age. In the event that “Trans Affirmation Unit” detects users who may be under the indicated age, it will not process their data nor will it respond to requests.

“Trans Affirmation Unit” reserves the right to request a copy of your ID or equivalent document that proves your legitimacy in case of having founded suspicions about the User’s minority.

Purpose of processing carried out by “Trans Affirmation Unit”

“Trans Affirmation Unit” informs that all personal data that the User provides through this website will be incorporated and processed by “Trans Affirmation Unit” as data controller for the following purposes:

  • Manage inquiries made through the Contact Form and provide the appropriate response.

  • Send you commercial communications about our news, developments, products and services, only if you have expressly and informedly authorized it in advance.

  • Manage registrations and cancellations of user records in “Trans Affirmation Unit” databases for electronic communications.

  • Attend to the exercise of the rights of data subjects.

  • Legal obligations: We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection or investigation of a crime, prevention of loss or fraud or to comply with internal and external audit requirements, with our information security objectives, crime prevention, which may entail that they are processed: (a) under applicable law, which may include laws outside the User’s country of residence; (b) to respond to requests from courts, security agencies, regulatory bodies and other public and governmental authorities, which may include authorities outside the User’s country of residence; (c), and to protect our rights, privacy, security or property, or those of other persons.

  • Legitimate interest: For business management reasons “Trans Affirmation Unit” may transmit your personal information to affiliated companies or to third parties for business management purposes located outside the European Economic Area, always verifying compliance with the guarantees required by European data protection regulations.

Prior to sending any request or information through the email addresses published on this website, the User agrees to have read this Privacy Policy, which for legal purposes means that they have given unequivocal, free, specific and informed consent to the processing of their personal data for the purposes indicated, without prejudice to subsequently having the right to exercise their rights in accordance with current regulations and the provisions of this Privacy Policy.

The aforementioned express consent implies authorization for the processing of your data by “Trans Affirmation Unit” under the terms established in this Privacy Policy, as well as by the joint controllers and processors with whom “Trans Affirmation Unit” maintains a mandatory contractual relationship and compliance control.

The personal information that “Trans Affirmation Unit” holds about users is not always obtained directly from users. Our servers through cookies collect certain information automatically that may identify the User.

International transfers.

In some cases “Trans Affirmation Unit” uses third-party tools and services for the management of some of the services offered on this website. Some of these services may be owned by third parties residing outside the European Economic Area.

“Trans Affirmation Unit” seeks to use secure tools whose servers are preferably located in Spain, or failing that, in a member state of the European Union, or that comply with European law in accordance with the guidelines and recommendations of the Spanish Data Protection Agency, the European Commission and the relevant community agreements on international data transfer. In the event that international data transfer is necessary, acceptance of this Privacy Policy means that as a User you expressly consent to said transfer.

Security Measures Applicable to the Processing of Personal Data.

In order to protect the personal data of web users, “Trans Affirmation Unit” ensures by itself and controls its processors, in the application of appropriate technical and organizational measures to the state of the art to protect personal data, taking into account the scope, context and purposes of the processing, as well as the risks of varying probability and severity to the rights and freedoms of data subjects, seeking to be able to ensure the confidentiality, integrity, availability and resilience of processing systems and services.

In particular, “Trans Affirmation Unit” has implemented Encryption and authentication protocol (TLS 1.2, ECDHE_RSA with P-256 and AES_128_GCM) issued by Avast trusted CA, which ensures that the personal data consulted by us are transmitted to our servers through a secure SSL connection (“Secure-Socket-Layer”), in order to protect them from third parties.

Our information security policies and procedures are regularly reviewed and updated in order to meet the needs of our business, technological changes and regulatory requirements.

We implement technical and organizational measures to store and transfer information securely, in order to protect it from attacks or accidental loss as well as from unauthorized access, use, destruction or disclosure.

  • We have a privacy and security risk assessment strategy.

  • We apply appropriate restrictions on access to personal information.

  • We require our processor suppliers to provide evidence of appropriate security controls for the processing of personal data that, in each case, they perform.

Notification of personal data security breaches.

In the event of a breach of personal data security, unless it is unlikely that such security breach constitutes a risk to the rights and freedoms of natural persons, “Trans Affirmation Unit” will notify the Spanish Data Protection Agency within 72 hours after becoming aware of the incident, describing the nature of the violation, the possible consequences that may arise and the measures adopted or proposed to remedy the security breach; and if possible, it will be made known what are the categories and the approximate number of data subjects and data affected.

Likewise, “Trans Affirmation Unit” will notify data subjects, as soon as possible, when it is likely that the breach of personal data security entails a high risk to the rights and freedoms of natural persons, describing the possible consequences that may arise and the measures adopted or proposed to remedy the security breach.

Exercise of rights.

At any time the User may withdraw their consent and/or exercise their rights of access, rectification, erasure, restriction, objection and portability provided for in European personal data protection regulations, by sending an email to info@transaffirmationunit.com or by postal mail addressed to CLÍNICA SAN CLEMENTE SL, at Calle Sanclemente, 4, Entlo. Ctro., Postal Code 50001 Zaragoza, (Spain). In such case, the User must indicate the right they wish to exercise, the website on which they exercise the right and attach a copy of their ID or any other valid identification documentation that legitimizes them to do so, including that which allows their electronic identification.

What do these rights consist of?

  • The right of access entitles the User to obtain information about what personal data are being processed, the purpose of the processing, the categories of data processed, the retention period or criteria, the recipients or categories of recipients; if profiles are created, significant information about the logic applied and the expected consequences of the processing; the exercise of the rights to rectification or erasure of personal data and the restriction or objection to processing and the right to lodge a complaint with the supervisory authority. To exercise it, the User does not need to provide justification, unless they have exercised it in the last six months. In the event of exercising your right of access, “Trans Affirmation Unit” is legally obliged to resolve the access request within a maximum period of one month from receipt of the request, providing a copy of the personal data subject to processing or allowing you remote access to them. “Trans Affirmation Unit” will also provide any additional copy requested by the data subject, subject to payment of the fee generated by the administrative costs of issuance. “Trans Affirmation Unit” may deny access and invoke, where appropriate, the protection of the Spanish Data Protection Agency on the grounds that such access has been exercised in the previous six months, or because it is provided for or prevented by a national or community regulation.

  • The right of rectification entitles the User to require “Trans Affirmation Unit” to rectify data that they consider to be inaccurate or incomplete. To do so, the User must indicate to us which data they refer to and the correction that must be made by providing documentation that justifies it. In such case, “Trans Affirmation Unit” will have to carry out the rectification as soon as possible and, in any case, within one month from receipt of your request. This period may be extended by another two months if necessary, taking into account the complexity and number of requests. “Trans Affirmation Unit” will inform the data subject of the extension within the first month from the request.

  • The right to erasure (or “right to be forgotten”) means that the User has the right to have the data erased when the processing is unlawful, the data subject has withdrawn their consent or has exercised the right to object and there are no other legitimate grounds for the processing; they are no longer necessary in relation to the purposes for which they were collected or processed; or they must be erased to comply with a legal obligation of “Trans Affirmation Unit”. The data subject will not have the right for “Trans Affirmation Unit” to erase their data when the processing is necessary to exercise the right to freedom of expression and information; to comply with a legal obligation; for the formulation, exercise or defense of claims ; for public interest based on current legislation for reasons of public health or for purposes of historical, statistical or scientific research. “Trans Affirmation Unit” will respond to your request as soon as possible and, in any case, within one month from receipt of your request. This period may be extended by another two months if necessary, taking into account the complexity and number of requests. “Trans Affirmation Unit” will inform the data subject of the extension within the first month from the request.

  • The right to object means that the User has the right for the processing of their personal data not to be carried out or to cease in cases where the processing is based on direct marketing, profiling; the interests or the rights and freedoms of the data subject prevail, especially if they are a child, over the legitimate interest of “Trans Affirmation Unit” or third parties; historical, statistical or scientific research, unless the processing is necessary for reasons of public interest. “Trans Affirmation Unit” will respond to your request as soon as possible and, in any case, within one month from receipt of your request. This period may be extended by another two months if necessary, taking into account the complexity and number of requests. “Trans Affirmation Unit” will inform the data subject of the extension within the first month from the request.

  • The right to restriction of processing means that the User has the right to decide what personal data they do not want to be processed in the future, being able to exercise this right when they have previously contested the accuracy of the data; when the processing is unlawful and instead of exercising the erasure of the data they decide to restrict them for future processing; or when they consider that “Trans Affirmation Unit” no longer needs the personal data for the authorized processing purposes, but instead, the User needs them for the formulation, the exercise or defense of claims. In the event of restriction of processing, the restriction may be lifted if there is consent of the data subject; possibility that the processing affects the protection of the rights of another natural or legal person; legal proceedings that justify it; or there is an important reason of public interest based on current legislation. “Trans Affirmation Unit” will respond to your request as soon as possible and, in any case, within one month fro m receipt of your request. This period may be extended by another two months if necessary, taking into account the complexity and number of requests. “Trans Affirmation Unit” will inform the data subject of the extension within the first month from the request.

  • The right to data portability means that the User has the right to receive the personal data provided to “Trans Affirmation Unit” or for “Trans Affirmation Unit” to transmit them to another controller, in a structured, commonly used and machine-readable format, provided that the processing is carried out by automated means and the processing is based on the consent that the User once gave for one or more specific purposes, or for the performance of a contract to which they were a party. The right to data portability will not apply when it is technically impossible to transmit; nor when it may negatively affect the rights and freedoms of third parties; nor when the processing has a mission of public interest based on current legislation. “Trans Affirma tion Unit” will respond to your request as soon as possible and, in any case, within one month from receipt of your request. This period may be extended by another two months if necessary, taking into account the complexity and number of requests. “Trans Affirmation Unit” will inform the data subject of the extension within the first month from the request.

How do we share information with third parties? Processors.

We share personal information with third parties in order to provide services or conduct business operations under the terms described in this Privacy Policy or when we consider that the law permits or requires it. When we share personal information, we do so in compliance with data privacy and security requirements. “Trans Affirmation Unit” informs the User that some of our suppliers may process your personal data as processors, for example in the case of:

  • our business partners and third-party service providers, when necessary for the provision of services, internal management, software support, systems and platforms, cloud hosting services and electronic communications. In such cases, the provider only accesses personal data when “Trans Affirmation Unit” informs the User and maintains a contractual relationship with the processor that guarantees confidentiality, non-use of users’ personal information that we make available to them for purposes other than those necessary for the performance of the contract, as well as compliance with our internal data privacy and security regulations.

  • when such data transfer is supported by a legal obligation or is required by competent authorities to respond to legal requirements, criminal investigation of possible illegal activity or claims asserting that content infringes the rights of third parties or to protect the rights, property or security of third parties, in the event of merger, sale, restructuring, acquisition, joint venture, assignment, transfer or other disposition, in whole or in part, of our business, assets or shares.

If “Trans Affirmation Unit” were required by competent authorities to respond to legal requirements, criminal investigation of possible illegal activity or claims asserting that content infringes the rights of third parties or to protect the rights, property or security of third parties, it may communicate to competent authorities personal information of users. If the rights to the website were transferred to another entity, “Trans Affirmation Unit” undertakes to agree on the subrogation and commitment of the new managing entity responsible for the processing of the personal data for the continuation of this Privacy Policy, warning of the commitment that if personal information is to be used in a manner contrary to this policy, the User must be notified in advance.

Cookie Policy.

“Trans Affirmation Unit” uses cookies (small information files that are downloaded to a User’s terminal device when accessing a website, with the purpose of storing data that may be updated and retrieved by the party responsible for their installation) and other tracking technologies to carry out certain functions that are considered essential for the proper functioning and display of the website and, in some cases, to store and manage User preferences, enable content and collect analytical and usage data.

To obtain these analyses, this website may store certain information in the server logs automatically through the use of cookies that collect non-personal usage and browsing data relating to the User’s use of this website. These logs typically include information such as, for example, the type of browser, browser language, date and time of access request, URL, device or equipment model, operating system version and data about the mobile network used in accessing and browsing this website.

The IP address is personal data. However, “Trans Affirmation Unit” generally does not access such personal data as it is provided encrypted by the third-party analysis tools used. If you wish to obtain more information about our use of cookies and learn how you can prevent their installation, you may visit our Cookie Policy.

How long will we process your data?

The personal data provided will be retained as long as the contractual relationship that may bind us subsists, during the legal retention periods, or until you request its deletion, with the purpose of keeping you informed about the actions promoted by “Trans Affirmation Unit”, provided that such processing is adequate, relevant and limited to what is necessary for the purposes for which the data were collected in accordance with this Privacy Policy.

Reuse of this policy.

“Trans Affirmation Unit” does not authorize the copying, reproduction or reuse of this privacy policy, which has been specifically analyzed to respond to the obligations inherent to this website.

Applicable legislation and jurisdiction.

“Trans Affirmation Unit” is based in Spain, therefore the content of this Privacy Policy has been drafted pursuant to Spanish legislation and applicable European Union regulations. You accept that claims or complaints against “Trans Affirmation Unit” arising from or related to the use of this website and more specifically to the processing of your personal data will be resolved by the court of competent jurisdiction located in Zaragoza. If “Trans Affirmation Unit” were to make any type of claim, it will do so before the competent court of your domicile or in Zaragoza if it concerns legal entities or non-consumer professionals. If you access this site from a location outside Spain, you are responsible for complying with all local and international laws that apply to you.

Reservation of the right to modify the Privacy Policy

“Trans Affirmation Unit” may modify this Privacy Policy at any time, in response to the evolution of this website and the content offered therein, if it deems it necessary, whether for legal reasons, technical reasons, or due to changes in the nature or layout of the website, without any obligation to notify or inform the User of such modifications, it being understood that its publication on the website itself is sufficient.

Any modification will take effect for users who use this website after such modification. Continued use of this site after the publication of any changes will be considered as acceptance of the same. Therefore, at the end of this Privacy Policy, the latest update date will always be published, so the changes introduced will be effective from that date.

Should the User not agree with the updates to our Privacy Policy, they may waive them by not entering their personal data in the website’s contact forms or by exercising their rights as previously specified. If their rights are not satisfied, they may file a complaint with the supervisory authority.

Last updated Privacy Policy last updated on 2026-03-25.

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