PRIVACY POLICY

1. Responsible

LA TORRE WALLACE, S.L.U. – Tax ID No. B-85142859 – Calle Ribera de Curtidores 28, 28005 Madrid, Spain. Belonging to the Shibumi Group.

Specific channel: pdatos@kallia.tech

2. Scope and applicable regulations

This policy regulates the processing of data belonging to users who submit information via the forms on the Kallia website/landing page. Regulation (EU) 2016/679 (GDPR), Organic Law 3/2018 (LOPDGDD) and Law 34/2002 (LSSI) apply.

3. Data processed

The data we request through the Website are: name, email address, telephone number, company, position, and interaction metadata (for example, information relating to the opening of emails or interaction with links in our communications).

All fields marked as mandatory on the forms are necessary in order to correctly process the request. If the User does not provide this data, LA TORRE WALLACE S.L.U. will not be able to respond to their request.

The data comes directly from the data subject, either by submitting the forms available on the Website or through voluntary communications (such as replying to a subscription confirmation email).

4. Purposes and legal bases

The personal data collected through the Kallia Website, belonging to LA TORRE WALLACE S.L.U., is processed for the following purposes:

Management of requests for information and contact relating to the Kallia product and other solutions from LA TORRE WALLACE S.L.U., as well as the commercial qualification of the lead.

Legal basis: execution of pre-contractual measures (Art. 6.1.b GDPR).

Sending newsletters and commercial communications (email, SMS, or calls) about Kallia and other services from LA TORRE WALLACE, S.L.U.

Legal basis: consent of the data subject (Art. 6.1.a GDPR), given by expressly checking the box provided on the form. The User may revoke their consent at any time without retroactive effect .

Scheduling of Kallia demonstrations (demos) and their subsequent follow-up, to assess commercial interest and coordinate the presentation of the product.

Legal basis: execution of pre-contractual measures (Art. 6.1.b GDPR).

Basic analysis of the performance of Kallia's campaigns and landing page, for statistical purposes and to improve the service, without creating profiles that have significant legal effects on the data subject.

Legal basis: legitimate interest of LA TORRE WALLACE S.L.U. (Art. 6.1.f GDPR), having carried out the corresponding assessment.

Under no circumstances are decisions made based solely on automated processing that produces significant legal effects for the User.

5. Data retention

The personal data provided will only be kept for the time strictly necessary to fulfill the purposes for which it was collected, in accordance with the following criteria:

Inactive leads: these will be kept for 24 months from the last relevant interaction (opening an email, reply, downloading content, phone call, etc.). After this period of inactivity, the data will be securely deleted or anonymized.
Commercial communications and newsletters: these will be kept as long as the User does not revoke their consent. If consent is withdrawn, they will be removed from the active databases and will only be kept on exclusion lists to ensure that unwanted communications are not sent again.
Requests for contracted demos or effective commercial relationships: the data will be kept for the duration of the contractual relationship and, subsequently, for an additional period of 24 months from the last interaction, in order to deal with any incidents and maintain the commercial history. Likewise, it will be kept blocked for the applicable legal limitation periods (e.g., 24 months for commercial and accounting obligations, in accordance with the Commercial Code).

In any case, the data will remain blocked for as long as legal liabilities may arise, and will only be available to judges, courts, and competent public administrations.

6. Recipients

Under no circumstances will personal data be transferred to third parties for commercial purposes without the User's prior consent. It may only be communicated in the following cases:

Legal obligation: when there is a regulatory or judicial requirement that obliges LA TORRE WALLACE S.L.U. to provide data to competent authorities (public administrations, judges, and courts).
Suppliers and data processors: the data may be processed by third parties that provide services to LA TORRE WALLACE S.L.U., acting as data processors in accordance with the provisions of Article 28 of the GDPR. These include, but are not limited to:

CRM platforms used for lead and contact management.
Email marketing services for sending newsletters and communications.
Hosting providers and technology services necessary for the operation of the Website.
Consulting or administrative services with limited access to data when essential.

The corresponding data processing agreement will be formalized with all these providers, ensuring that they comply with the security measures required by the regulations.

Joint responsibility scenarios: in certain cases, there may be situations of joint responsibility in the processing, such as in the use of social media platforms that integrate tracking mechanisms or advertising pixels. In these cases, LA TORRE WALLACE S.L.U. will establish agreements that define the responsibilities of each party and will inform the User in a clear and accessible manner.

7. Automated decisions

No decisions are made based solely on automated processing that produces significant legal effects or similarly affects the User.
The User has the right not to be subject to this type of decision and, if automated decision-making systems are implemented in the future, they will be informed in a clear and transparent manner.

8. User rights

The User may exercise the following rights recognized by the regulations at any time:

Right of access to their personal data.
Right to rectify inaccurate or incomplete data.
Right to erasure of data when it is no longer necessary or consent is withdrawn.
Right to object to the processing of their data in certain circumstances (including the right to object to commercial communications).
Right to restrict processing in the cases provided for by the regulations.
Right to data portability in a structured, commonly used, and machine- d format.
Right to withdraw consent at any time and without retroactive effect.

To exercise your rights, you may contact pdatos@kallia.tech, indicating "Data Protection - Kallia" in the subject line and attaching a valid document proving your identity.

If you consider that your rights have been violated, you may also file a complaint with the Spanish Data Protection Agency (www.aepd.es).

9. Information security

LA TORRE WALLACE S.L.U. applies appropriate technical and organizational measures to ensure the confidentiality, integrity, and availability of personal data, in accordance with Article 32 of the GDPR. These include:

Encryption of communications using secure protocols (TLS/HTTPS).
Access controls based on roles and minimum privileges.
Regular backups and restoration tests.
Logging and monitoring of system access.
Internal password policies and multi-factor authentication.
Specific training for authorized personnel on data protection.
Procedures for detecting and responding to security incidents or data breaches.

10. Minors

The Kallia Website does not knowingly collect data from minors under the age of 18.
If data is detected to have been sent by a minor, it will be immediately canceled and securely deleted.

11. Changes to the Policy

LA TORRE WALLACE S.L.U. may modify this Privacy Policy to adapt it to new legislation, case law, or changes in the processing carried out.

The current version will always be the one published on the Kallia Website at any given time.