PRIVACY POLICY - Kisetsu

At KISETSU S.L., we are interested in ensuring that the processing of users’ personal data is carried out in a transparent and secure manner, so that our users know at all times how we treat their personal data and how they can exercise their rights.

By browsing the website www.kisetsu.es (the ‘Website‘) or by accessing, requesting information, completing any of its forms, or making any purchase of products or services, KISETSU S.L. collects your personal data as a user (the ‘User(s)‘) in accordance wi th this privacy policy (the ‘Privacy Policy‘) and any other that may replace it in the future.

Any user who does not agree with the Privacy Policy, the Legal Notice, and/or the Cookie Policy must refrain from accessing, requesting information, or contracting any of the products or services offered on the Website.

This Privacy Policy is published in Spanish, Catalan, and English. In case of discrepancy between the versions, the Spanish version shall prevail.

1. Data Controller

The data controller for the collection and processing of personal data on the Website is KISETSU S.L. (‘KISETSU’), with N.I.F. B-67384826, address at C/ Marina, 91 – ESC. DH. P. 5 PTA. 2, 08018 Barcelona (Spain), and contact email address: info@kisetsu.es

2. What personal data do we process?

KISETSU collects and processes different information from Users. This information may often constitute personal data of the Users. This information may constitute, in many cases, personal data of the Users. This information will be considered personal data when it can directly identify or allow the identification of a natural person, such as the name and surname or contact details.
This personal data may have been directly provided by the User when interacting on the Website or completing any of the available forms.
Specifically, the personal data that KISETSU may process on the Website consists of:
- Identifying and contact information of the Users, including their name and surname, postal address, telephone number, email address, national identity document, tax identification number, or passport.
- Additional information (contractual data) that Users may provide us when purchasing any products or services through the Website, including personal data related to the processing and management of the purchase, personal or professional address, and payment-related data.
Likewise, KISETSU may record the visits made to the Website and its links or when clicking on content, interacting, or in any other way using the Website, through cookies and other similar technologies. For more information in this regard, Users can refer to our Cookie Policy.
We remind Users that they are responsible for ensuring that the personal data they provide is true and accurate, and they undertake to notify any changes or modifications. Any loss or damage caused to the Website, KISETSU, or any third party by the communication of erroneous, inaccurate, or incomplete information will be the sole responsibility of the User.
If the data considered necessary is not provided, it may not be possible to proceed with the request for information or the management of requests intended by the User.

3. For what purpose and on what legal basis do we process the personal data of Users?

KISETSU will not make automated decisionsbased solely on the automated processing of User’s personal data, without human intervention and that produce legal effects or significantly affect Users, which may fall within the cases provided for in Article 22 of Regulation 2016/679, of April 27, regarding the protection of individuals with regard to the processing of personal data and the free movement of such data, as well as the regulations that complement or replace it. It also does not carry out complex or automatic profiling. Any automated decision or complex profiling will be subject to the explicit, express and separate consent of the User.
KISETSU processes Users’ personal data for different purposes depending on the actions they carry out on the Website. Below, we indicate the specific purposes for which we process Users’ personal data, as well as the legal basis that legitimizes their use in each case:

Contracting of our products and services
Legal basis: Execution of pre-contractual measures and subsequent contract and legitimate interest of KISETSU. Refusal to provide personal data for these purposes will make it impossible to process and manage orders for the products and services offered by KISETSU.

When you purchase a product or service from KISETSU through its Website or by completing forms and accepting the corresponding checkbox, KISETSU may process personal data for purposes related to the management and processing of the order: manage the order of the corresponding products and/or services and their billing, send the purchased products, manage and access the web platform where online content is taught, manage the in-person events offered (courses, workshops, retreats, cultural experiences, therapies, etc.), analyze possible fraud and impersonation (including money laundering and terrorism financing), respond to inquiries and requests, conduct quality or satisfaction surveys, communicate in relation to the products and services purchased, as well as in the context of the exercise and defense of legal actions that assist KISETSU.
Handling of inquiries and requests
Legal basis:User’s consent when directing inquiries to KISETSU for the attention of requests through the different contact channels and KISETSU’s legitimate interest in processing and managing User’s inquiries.

KISETSU may process User’s personal data to handle inquiries that the User directs when contacting us through any of the available User support channels, in relation to the products or services offered and/or contracted with KISETSU.
Compliance with legal obligations and requirements of different organizations
Legal basis: Compliance with legal obligations applicable to KISETSU.

KISETSU will also process User’s personal data to comply with any applicable and enforceable legal obligations, respond to requests from any organization, court or public administration.
Website management and analysis of its use
Legal basis: Legitimate interest in analyzing the use of the Website, to improve the services provided to Users and offer them greater security.

KISETSU may also process User’s personal data through the performance of analysis, studies, statistics, surveys, usage metrics, market trend analysis, use of data for fraud prevention, either by itself or through third parties. To the extent possible, the information used for this purpose will be aggregated statistical information, without User identification.
Sending of commercial communications
Legal basis:Legitimate interest in the case of customers or consent in the case of potential customers, users who complete the form enabled on the Website to receive commercial communications or those who have ceased to be customers.

KISETSU may process User’s personal data for the purpose of sending commercial communications regarding promotions, offers, and discounts related to the products and services offered. To carry out commercial communications, KISETSU may use User’s personal data and those collected during the provision of services to personalize commercial information and send the User communications that may be of interest and meet their needs and preferences.

4. How long do we process and retain User's personal data?

KISETSU will not store User’s personal data for a longer period than necessary to fulfill the aforementioned purposes.
Subsequently, User’s data will be kept for the legal periods applicable in each case, taking into account the type of data, as well as the purpose of the processing. On the other hand, once the purposes have been fulfilled, KISETSU will keep the personal data duly blocked, to the extent that liabilities may arise for KISETSU or as required by applicable regulations.

5. Who can access User's personal data?

KISETSU will not grant access to User’s personal data to third parties other than those indicated in this Privacy Policy. Specifically, such access will occur in the following cases:
- Service providers
  KISETSU may use other companies to provide certain services under its guidelines, including but not limited to, customer service, debt collection, marketing, sales, consulting, auditing, or IT maintenance.
  
  KISETSU guarantees that, in such cases, these third parties will have limited access to Users’ personal data to the extent necessary to perform the assigned tasks and will be obliged not to disclose the information or use it for purposes other than the provision of the corresponding service.
- Disclosures required by law
  KISETSU may disclose Users’ personal data when required by law, in a judicial proceeding, to investigate suspicious activity, or in any other way to protect its own rights and those of the Users.

6. What security measures does KISETSU apply?

KISETSU will adopt the necessary technical and organizational measures to guarantee the confidentiality, integrity, and security of personal data, and to prevent its loss, alteration, unauthorized access or processing, taking into account the state of the technology and the nature of the stored data. Additionally, KISETSU periodically monitors its systems to detect possible vulnerabilities and attacks.
However, Users are aware that security on the Internet is not impregnable and that there is no guarantee that personal data cannot be accessed, disclosed, altered, or destroyed if there is a breach in any of the installed security measures. In any case, KISETSU is not responsible for any data breach caused by factors beyond its control or resulting from misuse by the User.

7. What rights can Users exercise?

In accordance with the applicable legislation at any given time, Users may request the exercise of their rights of access to personal data, rectification or deletion, limitation of processing, opposition to processing, as well as the right to data portability, and to withdraw consent. In particular, the rights available to Users are as follows:

Access to data	Users may request access to their personal data and the processing carried out by KISETSU at any time, along with a copy of the processed information.
Rectification of data	Users may request the modification of their personal data when it is inaccurate or incomplete.
Deletion of data	Users may request the deletion of their personal data if: (i) it is no longer necessary for the purposes for which it was collected or otherwise processed; (ii) if they withdraw their consent; (iii) if they believe it has been processed unlawfully; or (iv) if otherwise legally established.
Limitation of processing	Users may request the limitation of the processing of their personal data when they believe the processing is unlawful, when their personal data is no longer necessary for the purposes for which it was collected, but is necessary for the formulation, exercise or defense of claims, or in case of opposition while we verify the applicability of their right.
Objection to processing	Users may object to the processing of their personal data, for reasons related to their particular situation, when their personal data is subject to processing based on legitimate interest, including profiling. In such cases, KISETSU will be obliged to stop processing their personal data, unless there are legitimate reasons that prevail or their personal data is necessary for the formulation, exercise or defense of claims.
Portability	Users may request to receive their personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller, when the processing of their personal data is based on consent or the performance of a contract and the processing is carried out by automated means.
Withdrawal of consent	Users may also withdraw their consent at any time (for example, to receiving commercial communications as provided in this Privacy Policy). The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

Users may exercise these rights at any time by communicating clearly the right they are exercising, by postal mail to the address of KISETSU indicated in this Privacy Policy or through the following email address: info@kisetsu.es
If necessary for the unequivocal identification of the User, KISETSU may request a copy of their ID card, passport, or other valid document that identifies them.
In any case, Users may also file a complaint with the competent supervisory authority, which in the case of Spain is the Spanish Data Protection Agency (www.aepd.es).

8. Changes to the Privacy Policy

KISETSU reserves the right to modify this Privacy Policy as a result of new processing of personal data, or the modification of existing processing, as well as in response to new legislative or regulatory requirements, for security reasons, or to adapt the policy to the instructions of the data protection authorities or new processes.
Whenever significant changes are made to this Privacy Policy, KISETSU will duly inform Users through the Website to offer them the opportunity to review the changes and, if necessary, accept them before they become effective.

9. Contact

For any questions or inquiries regarding this Privacy Policy, please do not hesitate to contact us through the postal address of KISETSU collected in this Privacy Policy or through the following email address: info@kisetsu.es.

Last updated: 25/03/2024