Privacy Policy

Version 01.00

01.05.2024

The protection of your personal data and the transparency of its processing is a priority and constant objective for us and our corporate policies.

Below, we inform you of our Privacy Policy, which we have summarised by sections in order to make it easier to read and understand. Please read it carefully. If you do not agree with this policy, you should not use this platform and our services.

 

Introduction

This document contains our Privacy Policy, prepared in compliance with current legislation, in which we inform you of our general corporate policies on personal data protection, as well as our specific policies that affect users of our platform (hereinafter the “platform”), applications and services, and this in relation to the personal data that may be processed or collected from them through or in relation to said platform, applications and services, so that users are aware of the same and determine, freely and voluntarily, whether they wish to use them and that their data may be processed in accordance with the purposes indicated.

The Privacy Policy shall apply to the processing of personal data of users of our platform, applications and services, including both data provided directly by the users themselves, as well as data that may be collected automatically or provided by third parties during the use of this platform and its utilities, provision of any product or service and/or in the development of a contractual relationship with us. Additional terms and conditions may also apply to your interaction with us, depending on the products and services you request and use from time to time.

The access, use and maintenance of our platform, applications and services entails the processing of personal information of its users in accordance with the purposes informed in this policy. The user is informed in this policy of the way in which we treat and protect the personal data provided to us or to which we have access and process through the use of its various tools, options, applications, content and navigation.

The browsing or use of our platform, applications and services, as well as its options, contents and functionalities, implies the user’s agreement with its terms and conditions and with our Privacy Policy. The provision of any required information implies the acceptance of its treatment in a manner consistent with the purpose for which it was provided and its conformity with these conditions and policies. Likewise, the acceptance of our conditions and policies through any of the options provided implies full and unreserved acceptance of all its terms and conditions.

You should read our policy carefully to ensure that you understand it in full. We have tried to include in its wording all legally required aspects from a global and protectionist approach, although, given its length, in case you have any questions, you can contact us directly at the address we have enabled for this purpose: privacy@kumori.systems. If you do not agree with our policies and conditions, please exit this platform and do not use this platform, its applications, products and services.

Data controller

The owner of this web platform and responsible for the processing of your personal data while browsing and using this platform, its applications and services is Kumori Systems, S.L. (hereinafter “Kumori”), with NIF no. B98684624, postal address for notification purposes at Avenida de Menéndez y Pelayo, 5, CP 46010 Valencia (Spain), and email address privacy@kumori.systems. If you require further information or wish to make any request or complaint regarding data protection, you may address it directly to our privacy officer at the e-mail address indicated below.

Data processed

The data that we process while browsing and using this platform and any of its contents, services and options are the browsing data itself, as well as your identification, corporate and contact data such as name, telephone number and email address in order to manage your contact, information or test requests. In the event of registration, subscription or contracting of any of our services, together with identification and contact data, we may process data relating to your personal circumstances such as date of birth, DNI/NIF, professional data (organisation you represent or work for), commercial, economic, payment and banking data such as account number and any other additional data that may be necessary to collect within the framework of the operation, functionality and management of the platform or for the registration, subscription or supply of any of our products and services made available to you. The data requested from interested users for their registration/subscription that are necessary to make the platform, its applications and services available to them will be indicated in this way. Other data is provided on a voluntary basis. If you provide us with data of third parties, for example, of users or customers, you must have their consent, exempting Kumori from any liability arising therefrom.

The personal data you provide when filling in contact forms, test request, online assistance, subscription to services, registration or access as a user that are identified as “mandatory” are necessary to respond to your request, provide information, content, product or service requested, manage your registration and/or maintain contact, depending on their nature. The fields marked in forms with an asterisk (*) are compulsory and failure to complete them will make it impossible to deal with your request or application. The data you provide to subscribe to information services, demonstrations, news or commercial contact will initially be limited to your name, company and email address.

We also inform you that we may process data from users of our platform, applications and services that we manage, through our interactions with and through them. The data we may collect about your interactions, use, requests and experiences with our products and services depends on the context of your interactions, features you use, data you provide and, where applicable, choices you make, including managing preferences and settings.

The data processed may be collected a) Directly from the user when you provide them to us within the framework of our platform, applications, products and services, either personally, by telephone or electronically, for example when you provide them when you register, create an account, fill in a form, make a subscription or use certain applications and services; b) Automatically, through your access and use of our platform, applications, products and services, and the tools and utilities available to them, for example user identifiers; c) From third parties, for example and where applicable, the entity to which the user belongs.

The information we collect and may process may include, but is not limited to, identifying information (such as name, image, email address and telephone number), professional information (job title, company), business information (business, products, services, customers, suppliers, contacts), financial information and financial transaction information, technical and location information (such as IP address, operating system or browser), usage and activity information when using the functionalities and utilities of our web platform, applications and services, as well as other information that can be inferred about a user inherently or in association therewith or that identifies or can reasonably be associated with a user. We do not process data relating to the credit card of our users when they use this means of payment, insofar as it is managed by a payment gateway managed by a trusted third party.

When we request personal data from a user, the user may refuse to do so, although most of our services and utilities that may be made available to the user may require some personal data for their provision, access and use, so that, in these cases, if you choose not to provide the data required to provide you with a content, service or utility, you may not be able to access or use them. Similarly, when we need to collect or verify personal data by law to manage a subscription or enter into a contract, fulfil or maintain it, if it is not provided, we cannot enter into or maintain it, and we may be obliged to suspend or cancel it if it has been entered into, and we will inform you of this when the case arises. If the provision of personal data is optional and a user chooses not to provide it, the services, functions and utilities related to such data, e.g. personalisation, are likely not to work for the user.

Purpose of processing

The data will be processed, depending on the purpose for which they are provided, collected and/or requested, in order to allow you to browse and use the platform, manage and respond to your requests for information, manage your registration and subscription to services, allow you to test certain applications and services and their demo versions that you request, provide you with the services to which you subscribe and contract, manage your orders, shipments and payments and manage the administrative, legal, accounting and tax obligations of Kumori associated with all of the above. Contact details will be used to communicate with you.

The data will also be processed to serve and manage our legitimate interests and activities, in a manner consistent with your rights and preferences, which may require processing of your data to maintain contact, respond to your queries and suggestions, provide you with updates and information, learn more about our users, their interests and preferences, improve and personalise your experience, authenticate our users (if applicable), analyse our performance, develop our work capacity, develop, deliver and improve our products and services, carry out studies, innovate and research, communicate offers and promotions, manage and personalise advertisements, report errors and functional defects, security purposes as well as internal purposes, such as auditing and data analysis. In this regard, we inform you that we carry out analysis of the use made of the platform and services, as well as the preferences and behaviour of users in order to improve them and offer you the best information, applications and services, as far as possible, adapted to your preferences.

Where applicable, the profiles on social networks, platforms and channels to which we have access will not entail any processing of data beyond that which the social network, platform or channel itself allows for corporate profiles, except in the case of users who register with their profiles on said networks. In this sense, we may use these profiles to inform users of the same subscribed to our profile, platform, network or channel about our activities, events, services, offers, promotions or news, as well as to share information of interest on current topics. We do not extract any data directly from these networks, platforms or channels, except in the cases that are expressly and previously informed to the user.

The data will also be processed in order to comply with the legal obligations to which Kumori is subject.

 

Legitimation

The legal basis for the processing of your data is the fulfilment of our commitments and contractual obligations, the proper management and maintenance of the relationship and contact, to allow you to use the platform, applications, options and tools and to provide you with the information, products, services, utilities and content made available to you through the same that you request, in accordance with your own requests and consent.

We may also process your data on the basis of the individual consents you have given us, as well as where necessary, to comply with legal obligations and, where applicable, to meet our stated legitimate interests, if doing so is consistent with your rights and appropriate to the context, such as providing satisfactory services and experiences to our users, continuous improvement, monitoring performance and functionality, reporting and correcting errors, internal analysis of our activity, preventing misuse, security or our own business interests. We only process personal data where we have a legal basis for doing so.

The legal basis for sending you any content or informative and/or commercial communication is your own request or subscription to our services, as well as the legitimate commercial interests of Kumori. The legal basis for analysing the visits and preferences of users of the platform is our own interest in adapting and offering a better browsing, information and service experience. The processing of user data that we may carry out at a commercial level is also based on our own legitimate interest as recognised by the current legal framework. In any case, we consider that we have your consent to the processing of your data for the purposes indicated from the moment you provide them to us by telephone, electronically or by post, or fill in and send any application, registration, subscription or contact form that is made available to you or that has products or services that inherently entail the processing of your data. 

Duration of treatment

The data will be processed and kept for the time necessary to fulfil the purposes for which they were collected unless the user revokes their consent, requests their deletion, the limitation of processing, their portability, their opposition to their processing or, in the case of registered users, requests their deregistration, with the exception of those that it is necessary to keep for longer periods legally provided for, in order to meet any obligation or liability, legal or contractual, that may arise from the relationship maintained and/or processing. The data as a user of a trial version will be processed during the activation period, and will be deleted once the activation period is over, with the exception of those data that it is legally or contractually necessary to keep. In the event that your data is used for more than one purpose for which the periods are different, we will store your data for the longest retention period.

The data of users who register for or subscribe to information, news or regular content download services will be processed until the user requests to unsubscribe from these services. We periodically review the personal data we hold to determine whether it is appropriate to retain it.

Minors

This platform and its contents, services, applications, tools and utilities are aimed and oriented to companies and professionals (adults and legal persons), who must have the legal personality and capacity necessary to contract and bind themselves, as well as to authorise the processing of their data and to use the products and services they intend to use. The request or subscription to any service or acquisition of any content must be made by persons with the legal capacity to do so.

We do not knowingly process data of minors. If we become aware that personal data of a user under this age has been provided or collected in or through our services, we will take the appropriate measures to delete them as soon as possible, reserving the right to suspend or terminate the services and use of the same that may be being made. The parents or guardian of a minor who is a user of any of our services or applications may contact us at privacy@kumori.systems to discontinue the services they use and delete their data.

Kumori is not responsible for acts performed by persons without the necessary legal capacity or by altering or concealing their conditions that render them incapable of performing such acts.

 

Data communication

Personal data will not be disclosed to third parties except in the cases provided for by law, or when authorised or necessary for the management of any request, provision of any content, provision of any service and/or for the operation of the platform, its options, services, utilities and/or functionalities and exclusively in that context. Kumori does not sell the personal data of its users.

User data may be communicated to and/or processed by third parties to enable the provision of the information, content, products and/or services you request and to enable our administrative, operational, IT, commercial, economic, fiscal and security management, including our service providers related to Kumori that involve such processing as part of their services, such as hosting service providers, cloud infrastructure, online support tools, content management systems, database administration or others. These service providers are not authorised by us to use or disclose the data, they are only authorised to process the data on our behalf within the framework of their services and for this sole purpose, and we require them to take reasonable and appropriate confidentiality and security measures.

The user is informed that download services and telephone/electronic communications inevitably involve automated operations and technical procedures of interconnection, transit and storage, as well as communications, transfers and interconnections with third parties, especially with platforms, networks and operators that involve the processing of sender and receiver data.

The platform may contain links to information, services, content and applications operated by third parties subject to their own privacy policies which you should consult before requesting them. We recommend that you read the privacy policies of such third party websites before browsing them and providing them with your data. Kumori is not responsible for the acts or actions of such third parties in relation to the use of your personal data or otherwise.

The publication of data on the platform or its provision so that it may be accessible to the general public or users of the same, implies your agreement with all of the above, exonerating Kumori from any responsibility for the use that third parties who have access to the same may make of said data.

In the event of a merger or sale or if all or part of our business assets are acquired by or merged with a third party entity or in the context of a planned change of control, we reserve the right, in any such circumstances, to transfer or assign the data we have collected from users as part of such merger, acquisition or change of control, in particular to ensure continuity of services and applications, subject to the applicable legal framework.

 

Security measures

Kumori undertakes to comply with its obligation of confidentiality and secrecy of the personal data it processes and adopts the security measures required by current legislation on privacy, in order to reasonably ensure their protection and prevent their alteration, loss, unauthorised processing or access, taking into account the state of technology at all times. However, Kumori cannot fully guarantee the absolute invulnerability of its security systems or those of third parties, given that no security measure that is currently installed is absolutely unbreakable, and therefore Kumori shall not be liable under any circumstances for any incidents that may arise in relation to personal data when they arise from an attack or unauthorised access to its systems in such a way that it is impossible to detect it by the security systems in place, without prejudice to the possible obligation to communicate the event suffered to the competent authorities and affected users.

 

User rights

Users may exercise control over their data and revoke at any time they so wish any particular consent they have given for the processing of their data under the legally established terms, which may result in the impossibility of using the services and utilities made available to users of this platform that require such consent. The revocation of consent shall not affect the processing carried out up to that time.

Likewise, you may exercise the rights legally recognised by current legislation with respect to your personal data, including, among others, the rights of access, rectification and, where appropriate, deletion, portability, limitation of processing or opposition, by sending a written request to Kumori: Plaza Fray Luis Colomer, nº 9-18, CP 46021 Valencia (Spain). All of the above is without prejudice to the rights of the user to make any claim in defence of their rights and interests before the Spanish Data Protection Agency. The user will not be discriminated against under any circumstances for exercising any of his or her rights recognised by current legislation.

The request to exercise any right will be handled immediately and must be resolved within a maximum period of one calendar month from the time you provide us with the information necessary to do so, whether it is a decision granting or rejecting the request.

Some international legal systems also recognise their right to establish guidelines for the retention, deletion and transfer of a user’s personal data after his or her death, and we will also address the exercise of any rights that may be exercised in this regard.

 

User commitments

The user must keep the data provided duly updated, and shall be liable for any damages that Kumori and/or third parties may suffer as a result of the lack of truthfulness, inaccuracy, lack of validity and authenticity of the data provided. Kumori is exonerated from any type of responsibility derived from the lack of veracity and currency of the information provided, as well as from any damage or harm that the user may suffer as a consequence of this. Kumori reserves the right to delete or destroy the information provided by the user that may be contained in its files without prior notice, especially if it detects a lack of truthfulness, accuracy or timeliness of the same.

 

Commercial and promotional communications

Kumori may process your personal data provided to send you postal or electronic communications with informative, commercial or promotional content, which may include information relating to products, services, promotions, offers, events or news relevant to users of the platform and its services. When any communication of this type is made, it is addressed solely and exclusively to those users who have requested such information or, by virtue of the previous relationship established as a user of the platform, have not expressed their refusal or limitation to the receipt of the same. However, if you wish to stop receiving any commercial or promotional communication from us, you can request to unsubscribe by clicking on the link provided for this purpose in the body of such communications or by sending an email to the address privacy@kumori.systems. Likewise, you can indicate your refusal to receive them by ticking the box that may be enabled on the data collection forms, according to their nature and purpose.

Use of help or support functions

The platform may enable help or user support tools to offer you another way to contact us and deal with any questions you may have as quickly as possible. During our opening hours, you can contact us and get an answer to your questions through our support area. In this case, in order to constantly improve the quality of our service to the user, we may record the history of requests, queries and doubts for analysis and improvement in a completely anonymous way, being eliminated once evaluated.

 

International data transfers

The platform, its services and associated data are hosted, managed and operated in the EU. Kumori hosts, operates and supports its platform in the European Union (EU). We do not initially make international transfers of data processed on our servers in Europe and, in the event that such transfers may be made in the future or processed outside the European Economic Area (EEA), they will be carried out in accordance with and through transfer mechanisms authorised by the current European legal framework. The use of suppliers located in other countries would be carried out in full compliance with the provisions of the data protection regulations in force at any given time.

 

Consultations, requests and complaints

If you have any questions, requests or complaints, please contact us at: privacy@kumori.systems.

 

Update

This privacy policy may be updated periodically or modified in the future, especially to adapt it to the legislation in force at any given time, corporate codes or codes of conduct to which we adhere, instructions, guides and resolutions of the national, European and international administrative and judicial authorities on privacy or changes in our policies and practices, so we recommend that users of the platform periodically consult the same, in order to know the modifications that may occur, without prejudice to the notices that we may publish in this regard.

IMPORTANT: In the event of differences or contradictions between the versions of this policy published and/or translated into other languages, the version published in Spanish shall prevail in all cases.