Privacy and Cookies Policy

1. Who is responsible for processing your data?

Dunder Mifflin Paper Company SL
B13867270
C/Aribau 171, 5-2, 08036 Barcelona

2. Who is KARMINA's Data Protection Officer (DPO)?

The DPO is responsible for protecting the fundamental right to personal data protection at KARMINA, as well as for compliance with this regulation. You can contact the DPO:

• By email to hola@agenciakarmina.com, or
• Through postal mail or in person at C/Aribau 171, 5-2, 08036 Barcelona.

3. For what purpose do we process your personal data?

Simply by visiting our websites, no personal data that identifies the user is recorded.
KARMINA is a company dedicated to teaching digital marketing and positioning, and is also a digital strategy and marketing agency. Regardless of the two activities we carry out at our company, we process the information you provide us for the following purposes:

In our teaching activities, with your consent to provide us with your data, we will inform you about:

1. Booking of the courses and seminars we offer.
2. Communication of course materials and tasks to be completed.
3. Improve your experience and satisfaction as a student of KARMINA's courses (through statistics, surveys, market research, etc.)
4. The amount to be paid for the courses and the billing period, if necessary, since many of our courses are eligible for a bonus.
5. Report on the other business branches that KARMINA (digital strategy and marketing agency) carries out.

If you are a client of our digital marketing and strategy agency, your data will be used for the following purposes:

1. 1. Report on the contracted marketing and digital strategy services.
   2. Send documentation regarding the contracted marketing and digital strategy services.
   3. Report on the results of online marketing strategies implemented.
   4. Inform about new products or services we offer in terms of digital marketing and strategy.
   5. Provide information on billing details for contracted services and payment methods.

4. How long do we keep your data?

The personal data you have provided will be retained for as long as necessary to ensure the operation of the agreement with KARMINA.

The data will be deleted within a maximum period of 5 years from the end of your relationship with KARMINA, and for the purposes of complying with tax and sector regulations.
For all other personal data, the retention period will be 2 years.

5. What is the legitimacy for processing your data?

1. Regarding the school:
   The basis that legitimizes us to use your data is your consent, whether through registration for any of the courses we offer, through acceptance of the cookie policy or privacy policy, and, above all, for receiving information. Likewise, KARMINA is authorized to use your personal data for the purposes for which it was provided, such as receiving information about our courses, teaching materials, and news about them.
   You, as a user, by accepting this policy, certify that you are of legal age and have full capacity to accept it. KARMINA is exonerated from liability for lack of capacity on the part of the policyholder.
   Your data, during its validity, may be used to inform you of KARMINA news, as well as the services the company offers, focusing primarily on marketing and digital strategy.
2. Regarding the digital marketing and strategy agency:
   In this regard, the data requested by KARMINA is necessary for the proper execution of the contract in which you or your company, as the client, are part of the salary. Consequently, you must provide all the required information, which must be accurate and up-to-date.

In this regard, the data requested by KARMINA is necessary for the execution of the contract to which the user, whether a natural or legal person, is a party and, consequently, for the proper provision of the service, the user must provide the required data.

KARMINA must have a legal basis for processing your personal data. In most cases, this will be:

1. • To fulfill our contractual obligations to you as a client, such as to implement the contracted digital strategy. Failure to provide this information may prevent or delay the fulfillment of these contractual obligations.
   • For failing to comply with our legal obligations, for example, obtaining proof of your identity that allows us to comply with our anti-money laundering obligations.
   • To fulfill our legitimate interests, such as seeing the results of our digital strategy work. Where we process information to fulfill our legitimate interests, we implement robust safeguards to ensure your privacy is protected and also to ensure our legitimate interests are not overridden by your rights or fundamental rights and freedoms.
   • In any case, whether for the school or the digital strategy agency, we may obtain your consent to collect and use certain types of personal information when required by law (for example, in connection with our direct marketing activities, cookies, and tracking and tracing technologies). If we request your consent to process personal information, you may withdraw that consent at any time by contacting us. Please also note that KARMINA may be required by legal regulations to collect certain personal information about you or your company, as well as about any contractual relationship we have with you or your company.

6. But, will KARMINA share my data with third parties?

With your consent, KARMINA will use your data to communicate all updates and news regarding the course(s) you have enrolled in and any developments in KARMINA's activities as a digital marketing and strategy agency. To do so, KARMINA will use the well-known individual notification methods: regular mail and email.
KARMINA will only share your data to ensure your successful completion of the corresponding qualification and the proper execution of the digital strategy service contract. For example, regarding courses, since these are eligible for subsidies, if necessary, KARMINA must share your data with the corresponding administration to ensure the completion of the course.
Regarding digital marketing and strategy, the data you have provided must be transferred to an email marketing server to implement the strategy agreed upon in this case, always complying with the necessary due diligence regarding the processing of such data.
We also inform you that your data may be transferred to administrative or judicial bodies whenever there is a legal obligation to do so.

7. What are your rights when you provide us with your data?

Anyone has the right to obtain information about how KARMINA is processing your personal data.
Interested parties have the right to access their personal data, as well as to request the rectification of inaccurate data or, where appropriate, request its deletion when, among other reasons, the data is no longer necessary.
Under certain circumstances, the data subject may request that data processing be restricted. In this case, KARMINA will only retain the data for the purpose of exercising or defending legal claims.
Likewise, in certain circumstances and for reasons related to their particular situation, data subjects may object to the processing of their data. In such cases, KARMINA will cease processing them, except for compelling reasons or for the exercise or defense of potential legal claims.
Interested parties may request the right to data portability for the data they have previously provided to KARMINA.
To exercise these rights, as the interested party, you must send your duly completed request, accompanied by identifying documentation, to hola@agenciakarmina.com or to the DPO at C/Aribau 171, 5-2, 08036 Barcelona.
As an interested party, you may withdraw your consent at any time, without affecting the lawfulness of processing based on consent prior to its withdrawal.
In any case, as an interested party, you may file a complaint with the Spanish Data Protection Agency (https://www.agpd.es), Calle Jorge Juan, 6 (28001), Madrid, Telephone 901100099.

8. Where does your data come from?

We have obtained your data with your interest and consent, through our website, when we received information regarding the training courses offered by KARMINA and, more specifically, when you registered for them.
Regarding our digital marketing and strategy agency activities, we have obtained your data through your interest and consent, either through the service provision contract signed between the two parties or through the website where we offer our services.

9. categories of data we collect.

1. Name or company name.
2. Last name
3. Postal and electronic address.
4. DNI, NIE, CIF or NIF.
5. Contact phone number(s).
6. Economic data: IBAN and/or credit card.
7. Cookies.
8. Any other data necessary for the provision of services by KARMINA.
9. Use of Cookies.

Access to our website involves the use of cookies to recognize registered users and offer them better and more up-to-date service, as well as technical information.
Cookies do not allow access to personal data or, in general, data on the hard drive.
Specifically, cookies are small text files that are stored on your hard drive or in the memory of the computer used by each user so that the server remembers certain information that can be used later.
If you, as a user, do not wish to receive cookies or want to be informed before they are stored on your computer, you can configure your browser accordingly:

• Microsoft Internet Explorer menu Tools > Internet Options > Privacy > Settings
• Google Chrome menu Tools > Settings > Show advanced options > Privacy (Content Settings) > Cookies
• Firefox > Tools menu > Options > Privacy > Cookies

However, KARMINA thanks you for activating and accepting these cookies, as they help us obtain more accurate data that allows us to improve the content and design of the website and adapt it to your preferences. KARMINA does not guarantee the correct functioning of the website or the services it offers if these cookies are not accepted.
In the event that KARMINA provides any type of special service that specifies specific provisions different from these regarding the use of cookies, the application of the specific rules indicated for that particular service will prevail over these rules, in the event of any inconsistency or contradiction.

11. Google Analytics

Google Analytics is Google's free web analytics tool that helps website owners understand how visitors interact with their websites. Google Analytics collects information anonymously and, much like footprints in the sand, reports on website trends without identifying individual visitors. Google Analytics uses its own cookie to track visitor interactions. The cookie is used to store information such as the time of the current visit, whether the visitor has previously visited the site, or the website they came from. Google Analytics customers can access a variety of reports on how visitors interact with their websites so they can improve them and make them more discoverable.
Google Analytics captures user interactions with the website (time of visit, whether the user has been to the page before, what site recommended the user to visit the website in question, IP address, etc.)
Google Analytics does not provide KARMINA with information about the user's actual IP address; it only provides statistical information regarding visits (unique visitors, number of visits, pages viewed, average visit duration, percentage of new and returning visits, frequency, pages visited), demographic data (language, country, city), or system (browser, operating system, Internet access provider, device type).

To disable Google Analytics cookies at any time, you can do so by:

1. Installing the Google Analytics Opt-Out Add-on in your browser, which prevents Google Analytics from collecting information about your visits to accessible websites: https://tools.google.com/dlpage/gaoptout?hl=es.
   In this regard, you need to inform yourself about the aforementioned tool, Google Analytics Opt-out Add-on and other information about Google Analytics privacy: http://www.google.com/privacy_ads.html#toc -faq)
2. Through the browser, as detailed in section 10 regarding the policy on the use of cookies.

KARMINA informs its users that:

1. The collection of information about the use made of the website by our users through Google Analytics is only done by Google on its own behalf, KARMINA does not, at any time, have access to such information (but only to aggregated information that is not associated with any IP address);
2. Google is the one who determines the purpose of the processing and use of the information collected by Google Analytics at all times, as well as the operation and duration of the cookies;
3. According to the information provided by Google, the user can prevent the collection of this information by rejecting the installation of cookies and configuring their browser to do so.
4. Only countries in the European Union share – as a general rule – similar standards regarding cookies and personal data protection.

KARMINA expressly warns that it cannot control nor is responsible for the content and veracity of the terms and conditions and privacy policies of Google referenced in this privacy policy, and more specifically, the one referring to the use of cookies.

12. Third-party and analytical cookies

KARMINA websites may contain links to other websites. KARMINA does not control and is not responsible for the cookies used by these external websites. For more information about cookies on third-party websites, we recommend reviewing their cookie policies.

13. Responsibilities.

KARMINA declines any responsibility for the information contained on this website from sources outside the company, as well as for content not created by it.

Likewise, third-party data provided by clients to KARMINA for digital strategy and marketing purposes must be accurate and obtained in compliance with current data protection legislation, especially with the unequivocal consent of the person providing their data. KARMINA is exonerated if any of the aforementioned data was not obtained in accordance with current regulations, or if the person has requested its deletion, rectification, or portability, and this has not been communicated to KARMINA.

In cases where a client of the digital strategy and marketing branch receives a request from a user to exercise their rights, especially those of rectification, cancellation and/or portability, they must notify KARMINA as soon as possible by emailing: hola@agenciakarmina.com so that KARMINA can take the necessary action to protect the user's data.

14. Links.

KARMINA cannot guarantee that links to other sites are accurate at the time of access. However, KARMINA maintains strict control over access to the company's websites and their respective links.
If it is proven that the problem with the links is not attributable to KARMINA but to third parties, the company will be exonerated from any liability in this regard.

15. Copyright

This website includes, but is not limited to, software, text, graphics, logos, anagrams, button icons, images, audio files, and designs. All are the property of Dunder Mifflin Paper Company SL and are protected by national and international industrial and intellectual property laws. Access by the user to this website does not grant them any ownership rights over them.

Any other use of the content of this website, including any reproduction, copying, modification, distribution, transmission, subsequent publication, display or performance of the content in whole or in part, is strictly prohibited.

In the event that you observe any content on this website that could violate or violate intellectual or industrial property rights, related to the defense of consumers and users, advertising, telecommunications, right to honor, privacy and the same image, data protection and financial regulations, we ask that you immediately inform us. Dunder Mifflin Paper Company SL, by sending an email to the following address: hola@agenciakarmina.com

KARMINA reserves the right to make, at any time and without prior notice, any modifications, variations, deletions, or cancellations to the content and its presentation that it deems necessary, whether temporary or permanent, ensuring that the user is using the updated version at all times. This right does not entitle users to compensation for damages.

16. Legal information

Each time you access KARMINA's web pages you should ensure that you have reviewed the content of this page.

Last updated: 16/05/2024.

17. General Information
    

Dunder Mifflin Paper Company SL
C/Aribau 171, 5-2, 08036 Barcelona*
Email: hola@agenciakarmina.com
CIF: B13867270