The Privacy and Personal Data Protection Policy of KENFAY
1. Who is the controller of your personal data?
Name: KENFAY (hereinafter referred to as KENFAY)
Tax Identification Code (CIF): B-45441953
Postal address: C/ Felix Boix nº 7, 1ª planta, 28036 Madrid
Tel: 0800 021 1843
Email address: firstname.lastname@example.org
2. Why do we process your personal data?
At KENFAY, we process the personal information (personal data) provided by customers, consumers of our products: (i) to manage the commercial relationship with the customers, issue invoices, send the products and render the contracted service; and (ii) to send advertising messages, if the customer grants his/her consent for such purpose.
Processing means any operation carried out on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise, making the data available and alignment or combination, restriction, erasure or destruction thereof;
Automated decision-making and profiling based on the information provided by the users will not be carried out.
3. What authorisation is required to process your personal data?
Authorisation refers to the legal basis for the personal data processing that is carried out by KENFAY according to the intended purpose, as explained below:
a) The authorisation for processing your personal data in order to manage the commercial relationship with customers is legally based on Article 6.1.b) of the General Data Protection Regulation (EU) 2016/679, since data processing is required to execute the product acquisition agreement in which the data subject is a party or to implement pre-contractual measures requested by such party.
Spanish Royal Legislative Decree 1 of 16 November 2007, which approved the Redrafted Text of the General Consumer and User Protection of the Spanish Act. Book Two. Contracts and guarantees (Articles 59 – 91); Title III. Distance contracts (Articles 92 – 127).
In addition, the Spanish Act 34/2002 on information society services and electronic commerce (Articles 23 – 29).
The disclosure of your personal data is legally required to enter into a purchase agreement with KENFAY. The data subjects are therefore obliged to provide their personal data, since they would otherwise be unable to purchase the products shown on KENFAY’s website.
The “SIGN-UP” option will be displayed when placing an order through KENFAY’s website where you will find a form to enter the required personal data. If you do not enter the necessary personal data you will be unable to create an account on KENFAY’s website nor access it or operate through it.
b) The authorisation for processing your personal data in order to receive commercial messages is legally based on the General Data Protection Regulation (EU) 2016/679: Article 6.1.a) related to data subjects granting their consent to processing their personal data and specifically receiving advertising messages.
The consent granted to process your data can be revoked at any time. Under no circumstances will withdrawing your consent affect the execution of the agreement entered into with KENFAY.
4. How long will we keep your personal data?
The personal data provided by users will be kept by KENFAY for as long as the commercial relationship lasts between the parties and their deletion has not been requested by the data subject or there is a legal obligation to do so.
KENFAY will adopt the appropriate security measures to protect the integrity of the information and confidentiality of the personal data and to prevent infringement thereof during the time they are kept, which is limited to the requirements stipulated by law.
The customer’s bank details requested during the purchasing process will not be saved or kept by KENFAY. The customer will be transferred to an external bank payment platform to make a purchase and pay for it. Only the payment providers will store such data in order to render their services.
5. To whom will your data be disclosed?
The personal data collected through the “SIGN-UP” or “CONTACT” form will not be disclosed to any other enterprise and your data will not be posted on KENFAY’s website; they will only be processed for the purposes outlined in these privacy terms and conditions.
The personal data obtained will not be assigned to third companies unless there is a legal obligation to do so. The data collected are solely for KENFAY’s use.
6. What are your rights if you provide us with your data?
Users who have provided their personal data to KENFAY are granted the following rights:
o The right to request access to the data subject’s personal data.
o The right to request the rectification or erasure of the data.
o The right to request the restriction of processing.
o The right to object to processing.
You can request access to the data at any time and obtain confirmation of the processing carried out by KENFAY.
Data subjects are entitled to access their personal data and request the rectification of data that are inaccurate or, when appropriate, to request the erasure of the data when, among other reasons, the personal data are no longer required for the purposes for which they were collected.
In certain cases, and for reasons related to their specific situation, data subjects may request restriction of the personal data processing, in which case the data will only be kept in order to file or defend claims.
Data subjects may object to the data being processed at any time. KENFAY will inform the data subject about the consequences of this and will stop processing the data, except in cases when it is necessary due to a legal requirement in order to file or defend possible claims.
If you do not enter the personal data that are marked as compulsory in the order or contact form, this may result in KENFAY being unable to render the service you wish to obtain.
Data subjects who have granted their consent for a specific purpose will also be entitled to revoke such consent at any time. This will not affect the legality of the processing based on the consent granted prior to such revocation.
7. How can data subjects exercise their rights?
Data subjects can exercise their rights to access, rectify, erase, restrict or object to processing by sending a letter to KENFAY., with address at C/ Felix Boix nº 7, 1ª planta, 28036 Madrid or by using the following email address: email@example.com.
Moreover, you may also file a claim with the Spanish Data Protection Agency if you consider you have been unable to exercise your rights. You can find all the necessary information at www.agpd.es.
In order to settle any consumer issues, you can also use the online dispute settlement process through the following link:
8. What security measures do we adopt to protect your data?
KENFAY has adopted the appropriate technical and organisational security measures to guarantee the integrity of the information and confidentiality of the data, in accordance with the obligations stipulated in Article 5.f), Article 24 and related articles of the General Data Protection Regulation (EU) 2016/679, as described in the security document, pursuant to the company’s data protection policy.
The security measures that have been adopted include specifying and identifying the persons who are allowed access to the data and IT systems, recording this information in the security document, informing the persons with access to the data about the non-disclosure commitment, implementation of access control measures, keeping a record of incidents and applying a system for obtaining back-up copies and information recovery.