PRIVACY POLICY

I. PRIVACY POLICY AND DATA PROTECTION

In accordance with the provisions of current legislation, Konsultan Kit (hereinafter, also the Website) undertakes to adopt the technical and organizational measures necessary, according to the level of security appropriate to the risk of the data collected.

Laws incorporated in this privacy policy

This privacy policy is adapted to current Spanish and European regulations on the protection of personal data on the Internet. Specifically, it complies with the following rules:

• Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).
• Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights (LOPD-GDD).
• Royal Decree 1720/2007, of December 21, approving the implementing regulations of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD).
• Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI-CE).

Identity of the controller of the personal data processing

The controller of the processing of the personal data collected in Konsultan Kit is: Graham Keeley, with NIF: X5516182T (hereinafter, the Controller). Their contact details are as follows:

The controller of the processing of the personal data collected in Konsultan Kit is: , with NIF: , registered in: , with the following registry details: , whose representative is: (hereinafter, the Controller). Their contact details are as follows:

Address: Calle Roses, 16 – Bajos, 08850 Gavà (Gavà Mar), Barcelona

Contact telephone: +34669311731

Contact email: grkeeley@gmail.com

Personal Data Records

In compliance with the provisions of the GDPR and the LOPD-GDD, we inform you that the personal data collected by Konsultan Kit, through the forms provided on its pages, will be incorporated and processed in our file in order to facilitate, streamline and fulfill the commitments established between Konsultan Kit and the User, or the maintenance of the relationship established in the forms completed by the latter, or to deal with a request or query made by the same. Likewise, in accordance with the provisions of the GDPR and the LOPD-GDD, unless the exception provided for in Article 30.5 of the GDPR applies, a record of processing activities is maintained which specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User’s personal data shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights:

• Principle of lawfulness, fairness and transparency: the User’s consent will be required at all times after fully transparent information about the purposes for which the personal data are collected.
• Principle of purpose limitation: personal data will be collected for specified, explicit and legitimate purposes.
• Principle of data minimization: personal data collected will be only those strictly necessary in relation to the purposes for which they are processed.
• Principle of accuracy: personal data must be accurate and kept up to date.
• Principle of storage limitation: personal data will be kept only for as long as necessary for the purposes of their processing.
• Principle of integrity and confidentiality: personal data will be processed in a manner that ensures their security and confidentiality.
• Principle of accountability: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed in Konsultan Kit are only identifying data. Under no circumstances are special categories of personal data processed within the meaning of Article 9 of the GDPR.

The categories of data processed in Konsultan Kit include both identifying data and special categories of personal data within the meaning of Article 9 of the GDPR.

Special categories of personal data are understood as those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data aimed at uniquely identifying a natural person, data concerning health, or data concerning a person’s sex life or sexual orientation.

For the processing of special categories of personal data, the User’s explicit consent will be required in all cases for one or more specific purposes.

Legal basis for the processing of personal data

The legal basis for processing personal data is consent. Konsultan Kit undertakes to obtain the User’s express and verifiable consent for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw their consent at any time. It will be as easy to withdraw consent as to give it. As a general rule, the withdrawal of consent will not condition the use of the Website.

On occasions when the User must or may provide their data through forms to make inquiries, request information, or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory because such data are essential for the proper development of the operation carried out.

Purposes of the processing of personal data

Personal data are collected and managed by Konsultan Kit for the purpose of facilitating, streamlining and fulfilling the commitments established between the Website and the User, or maintaining the relationship established in the forms completed by the latter, or to deal with a request or query.

Likewise, the data may be used for a commercial purpose of personalization, operational and statistical purposes, and activities related to the corporate purpose of Konsultan Kit, as well as for data extraction, storage and marketing studies to adapt the Content offered to the User, as well as to improve the quality, operation and browsing of the Website.

At the time personal data are obtained, the User will be informed about the specific purpose or purposes of the processing for which the personal data will be used; that is, about the use or uses that will be made of the information collected.

Retention periods for personal data

Personal data will only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: , or until the User requests their deletion.

At the time personal data are obtained, the User will be informed about the period for which the personal data will be kept or, where that is not possible, the criteria used to determine that period.

Recipients of personal data

The User’s personal data will not be shared with third parties.

In any case, at the time personal data are obtained, the User will be informed about the recipients or categories of recipients of the personal data.

The User’s personal data will be shared with the following recipients or categories of recipients:

Graham Keeley. Calle Roses, 16 – Bajos, 08850 Gavà (Gavà Mar), Barcelona

If the Controller intends to transfer personal data to a third country or an international organization, at the time personal data are obtained, the User will be informed about the third country or international organization to which the personal data are intended to be transferred, as well as about the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In accordance with Articles 8 of the GDPR and 7 of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, only persons over 14 years of age may give their consent for the lawful processing of their personal data by Konsultan Kit. If the person is under 14 years of age, the consent of parents or guardians will be required for processing, and this will only be considered lawful to the extent that they have authorized it.

Confidentiality and security of personal data

Konsultan Kit undertakes to adopt the technical and organizational measures necessary, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized disclosure of or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, and in feedback, is fully encrypted.

However, since Konsultan Kit cannot guarantee the absolute invulnerability of the Internet or the complete absence of hackers or others who fraudulently access personal data, the Controller undertakes to inform the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. As set out in Article 4 of the GDPR, a personal data breach means any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed.

Personal data will be treated as confidential by the Controller, who undertakes to inform and ensure, through a legal or contractual obligation, that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.

Rights arising from the processing of personal data

The User has the following rights over Konsultan Kit and may therefore exercise the following rights recognized in the GDPR and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, against the Controller:

• Right of access: The User’s right to obtain confirmation as to whether Konsultan Kit is processing their personal data and, where that is the case, access to the personal data and information about the processing carried out or to be carried out by Konsultan Kit, as well as, among other things, information available about the origin of the data and the recipients of communications made or envisaged.
• Right to rectification: The User’s right to have inaccurate personal data corrected or, taking into account the purposes of the processing, to have incomplete personal data completed.
• Right to erasure («right to be forgotten»): The User’s right, provided that current legislation does not establish otherwise, to have their personal data erased when it is no longer necessary for the purposes for which it was collected or processed; the User has withdrawn consent and there is no other legal basis for processing; the User objects to processing and there are no overriding legitimate grounds; the personal data have been unlawfully processed; the personal data must be erased for compliance with a legal obligation; or the personal data have been obtained in relation to the offer of information society services directly to a child under 14 years of age. In addition to erasing the data, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps to inform controllers that are processing the personal data of the data subject’s request to erase any links to, or copy or replication of, those personal data.
• Right to restriction of processing: The User’s right to restrict the processing of their personal data. The User has the right to obtain restriction of processing where they contest the accuracy of the personal data; the processing is unlawful; the Controller no longer needs the personal data for the purposes of processing, but the User needs them for the establishment, exercise or defense of legal claims; or the User has objected to processing.
• Right to data portability: Where processing is carried out by automated means, the User has the right to receive from the Controller their personal data in a structured, commonly used and machine-readable format, and to transmit those data to another controller. Where technically feasible, the Controller shall transmit the data directly to that other controller.
• Right to object: The User’s right to object to the processing of their personal data or to have such processing ceased by Konsultan Kit.
• Right not to be subject to a decision based solely on automated processing, including profiling: The User’s right not to be subject to a decision based solely on automated processing of their personal data, including profiling, except where current legislation provides otherwise.

Therefore, the User may exercise their rights by means of a written communication addressed to the Controller with the reference «GDPR-https://grahamkeeley.com/«, specifying:

• Name and surname(s) of the User and a copy of the ID document. Where representation is permitted, identification by the same means of the person representing the User will also be required, as well as the document accrediting such representation. The photocopy of the ID document may be replaced by any other legally valid means that proves identity.
• The request, with the specific reasons for the application or the information to be accessed.
• Address for notification purposes.
• Date and signature of the applicant.
• Any document supporting the request being made.

This request and any other attached document may be sent to the following address and/or email:

Postal address: Calle Roses, 16 – Bajos, 08850 Gavà (Gavà Mar), Barcelona

Email: grkeeley@gmail.com

Links to third-party websites

The Website may include hyperlinks or links that allow access to third-party websites other than Konsultan Kit, and therefore are not operated by Konsultan Kit. The owners of such websites will have their own data protection policies, and they will be responsible, in each case, for their own files and their own privacy practices.

Complaints to the supervisory authority

If the User considers that there is a problem or infringement of current regulations in the way their personal data are being processed, they have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular, in the Member State of their habitual residence, place of work, or place of the alleged infringement. In Spain, the supervisory authority is the Spanish Data Protection Agency (https://www.aepd.es/).

II. ACCEPTANCE AND CHANGES TO THIS PRIVACY POLICY

The User must have read and agreed to the conditions regarding the protection of personal data contained in this Privacy Policy, and must accept the processing of their personal data so that the Controller may proceed with such processing in the manner, within the time limits, and for the purposes indicated. Use of the Website implies acceptance of its Privacy Policy.

Konsultan Kit reserves the right to modify its Privacy Policy, at its own discretion, or as a result of legislative, case-law or doctrinal changes of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is recommended to consult this page periodically to be aware of the latest changes or updates.

This Privacy Policy was updated to adapt to Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.

This Website Privacy Policy document was created using the online free website privacy policy template generator on 02/26/2026.