Privacy Policy 

This personal data protection policy covers any data processing that may occur when browsing or interacting with any of our websites or social networks in which we may have a presence (Facebook, Twitter, Instagram, etc.). At the end of this document, special information is specified in the case of the use of social networks. It will also apply to any internal company procedure that requires the collection of data, whether in paper forms or any other system.

In any of these media, you can consult information, and in some cases fill out forms, answer surveys, participate in contests, make inquiries, send photographs, make comments, etc.… and, therefore, provide us with personal data information. All processing is subject to our privacy policy.

Who is responsible for the processing of your personal data?

By means of this notice, KELMIA, owned by THEY SAY TRACKING S.L (hereinafter “THEY SAY”) with Tax Identification Number B-86645660, a company registered in the Commercial Registry of Madrid and with address at Calle Escalonia, 15 Portal 9 Bajo A. 28231 Las Rozas, Madrid, owner of the website http://theysay.me and the registered trademark KELMIA, confirms that it is responsible for the processing of personal data provided by users or customers through the portal and informs and communicates to the users of the portal its Privacy Policy on the Protection of Personal Data in accordance with current legislation on the matter and the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 and Law 34/2002 on Information Society Services.

What data is collected, its purpose and legitimacy for its processing?

KELMIA and THEY SAY collect the following data:

• Email
• "Contact us" form: name, email, phone number and address.

The purpose is to send email alerts, information and newsletters about new offers and services. Users of the website freely, voluntarily and with their express consent, decide to accept our privacy policy, allowing KELMIA and THEY SAY to access their personal data.

KELMIA and THEY SAY declare that the personal data provided by their owner will be used for the following specific and concrete purposes:

• Management of the relationship with KELMIA and THEY SAY.
• Management of queries.
• Registration on the portal as a registered user.
• Email alerts about new offers and opinions.
• Suggestion of new offers and services of the company.
• Sending commercial advertising, newsletters, news or periodic reports, through any means, including electronic.

The personal data provided will not be used for profiling or for automated decision-making.

Communication of personal data

KELMIA and THEY SAY declare that the data will not be shared with third parties unless required by law. There are also no international data transfers.

Conservation of personal data

KELMIA and THEY SAY will store your data as long as the user does not exercise their right to delete or cancel it.

In the event of deletion or cancellation and in accordance with the legal provisions established in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of Personal Data, KELMIA and THEY SAY will retain them, even after the contractual relationships have ended and, in any case, during the legally established periods, solely and exclusively to make them available to administrative or judicial authorities if necessary and when they expressly request it.

Rights of access, rectification, cancellation or opposition

The owner's acceptance for their data to be processed is always revocable, in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016. Consequently, the user who owns the data may exercise their rights of access, rectification, limitation, deletion and cancellation at any time under the terms set out in the GDPR, by contacting us at ia@kelmia.com

In this communication, the owner is obliged to indicate and provide their identification data, National Identity Document number or documentation of a similar nature, postal address, telephone number, contact person, email and a text explaining the right to exercise, as well as its causes.

If you consider that we have not treated your data appropriately, you can always file a claim with the Spanish Data Protection Agency (www.agpd.es).

Access

You can consult the personal data managed by KELMIA.

Rectification

You may modify your personal data when it is inaccurate.

Deletion

You may request the deletion of your personal data.

Objection

You may request that your personal data not be processed.

Limitation of processing

You may request the limitation of the processing of your data in the following cases:

• While the accuracy of the data is being verified.
• When KELMIA and THEY SAY do not need to process your data, but it is necessary for the execution or defence of claims.

Portability

You may receive the data that you have provided us electronically.

Confidentiality and security measures

KELMIA and THEY SAY guarantee the utmost privacy and confidentiality of the communications they carry out with the user, as well as the due and diligent processing of the personal data that the user provides.

KELMIA and THEY SAY undertake not to disclose any confidential information, nor to disclose any information that is being processed, except in cases where this is expressly required by law, or when requested by the competent public authorities in accordance with the applicable legal and regulatory provisions.

KELMIA and THEY SAY undertake to apply technical and organisational security measures, in accordance with the state of technology, to guarantee the security of personal data.

Accuracy of personal data

In any case, the user will be responsible for the accuracy of the data provided, with KELMIA and THEY SAY reserving the right to exclude from the registered services any user who has provided false, inaccurate or incomplete data, without prejudice to any other actions that may be taken under the law.

The user expressly declares that he/she is the owner of the data provided to KELMIA and THEY SAY. Otherwise, they assume any liability that may arise.

Social networks

The operation of social networks is not under the control of KELMIA and THEY SAY, so the published information will be shared with all users who access them. Likewise, these networks allow interaction with other users, so a series of prerequisites that must be taken into account are detailed below.

The objective of using social networks is to give visibility to the KELMIA and THEY SAY service.

In principle, the same data protection policy specified in this document applies, regarding the collection, processing and transfer of data.

The user undertakes to:

• Not publish information that does not comply with the requirements of authenticity, public interest and respect for the dignity of people. In particular, the user must avoid any conduct that may violate the principle of non-discrimination based on sex, race, religion, ideology or any other personal or social circumstance, as well as against privacy, honour and self-image, being ultimately responsible for the authenticity and legality of the content they publish.
• Do not take or publish images, videos or any other type of file without the consent of the protagonists.

KELMIA and THEY SAY do not identify with the opinions expressed by others, nor with the ideology of the profiles of those they are friends with on any social network.

KELMIA and THEY SAY reserve the right to remove from their social networks any information published by third parties that violates the law, instigates it or contains messages that violate the dignity of people or institutions. In addition, the owner of the profile of the messages in question may be blocked or reported.

Recommendations for the user:

• Review and read the general conditions of use and the privacy policy of the social network when registering.
• Learn to communicate with the user.