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Privacy policy

Last updated: 20 September 2026

This is a courtesy translation. In the event of any discrepancy, the Spanish version shall prevail. Ver versión en español.

I. Privacy and data protection policy

In accordance with current legislation, Kamay (hereinafter, also the Website) undertakes to adopt the technical and organisational measures necessary, according to the level of security appropriate to the risk of the data collected.

Laws incorporated in this privacy policy

This privacy policy is adapted to the Spanish and European regulations in force on the protection of personal data on the internet. Specifically, it complies with the following regulations:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, GDPR; in Spanish, RGPD).
  • Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (Ley Orgánica de Protección de Datos Personales y garantía de los derechos digitales, LOPD-GDD).
  • Spanish Royal Decree 1720/2007 of 21 December approving the Regulation implementing Organic Law 15/1999 of 13 December on the Protection of Personal Data (Reglamento de desarrollo de la Ley Orgánica de Protección de Datos de Carácter Personal, RDLOPD).
  • Spanish Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (Ley de Servicios de la Sociedad de la Información y de Comercio Electrónico, LSSI-CE).

Identity of the controller of personal data

The controller of the personal data collected on Kamay is: Maria Karla Mendoza Mena, holder of Spanish tax identification number (NIF): 29614005X (hereinafter, the Controller). Their contact details are as follows:

Register of personal data

In compliance with the GDPR and the LOPD-GDD, we inform you that the personal data collected by Kamay through the forms on its pages will be incorporated into and processed in our file in order to facilitate, expedite and fulfil the commitments established between Kamay and the User, or to maintain the relationship established in the forms the User completes, or to deal with a request or enquiry from the User. Likewise, in accordance with the GDPR and the LOPD-GDD, unless the exception provided for in Article 30(5) of the GDPR applies, a record of processing activities is kept which specifies, according to their purposes, the processing activities carried out and the other circumstances established in the GDPR.

Principles applicable to the processing of personal data

The processing of the User's personal data shall be subject to the following principles set out in Article 5 of the GDPR and in Article 4 et seq. of Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights:

  • Lawfulness, fairness and transparency: the User's consent shall be required at all times, following completely transparent information on the purposes for which the personal data are collected.
  • Purpose limitation: personal data shall be collected for specified, explicit and legitimate purposes.
  • Data minimisation: the personal data collected shall be only those strictly necessary in relation to the purposes for which they are processed.
  • Accuracy: personal data must be accurate and always kept up to date.
  • Storage limitation: personal data shall only be kept in a form which permits identification of the User for as long as necessary for the purposes of the processing.
  • Integrity and confidentiality: personal data shall be processed in a manner that ensures their security and confidentiality.
  • Accountability: the Controller shall be responsible for ensuring that the above principles are complied with.

Categories of personal data

The categories of data processed on Kamay are identification data only. Under no circumstances are special categories of personal data within the meaning of Article 9 of the GDPR processed.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. Kamay undertakes to obtain the User's express and verifiable consent to the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw their consent at any time. It shall be as easy to withdraw consent as to give it. As a general rule, withdrawal of consent shall not affect the use of the Website.

Whenever the User must or may provide their data through forms in order to make enquiries, request information or for reasons related to the content of the Website, they will be informed if completing any of them is mandatory because the data are essential for the proper performance of the operation carried out.

Purposes for which personal data are processed

Personal data are collected and managed by Kamay in order to facilitate, expedite and fulfil the commitments established between the Website and the User, or to maintain the relationship established in the forms the User completes, or to deal with a request or enquiry.

Likewise, the data may be used for commercial purposes of personalisation, operational and statistical purposes, and activities within Kamay's corporate purpose, as well as for data extraction, data storage and marketing studies in order to adapt the Content offered to the User and to improve the quality, operation and navigation of the Website.

At the time the personal data are obtained, the User will be informed of the specific purpose or purposes of the processing for which the personal data will be used, that is, of the use or uses to which the information collected will be put.

Retention periods of personal data

Personal data shall only be retained for the minimum time necessary for the purposes of their processing and, in any case, only for the following period: 18 months, or until the User requests their erasure.

At the time the personal data are obtained, the User will be informed of the period for which the personal data will be stored or, where that is not possible, the criteria used to determine that period.

Recipients of personal data

The User's personal data will not be disclosed to third parties, unless there is a legal obligation to do so or it is necessary for the provision of a service expressly requested by the User, in which case the User will be informed in advance.

For the operation of the Website, Kamay relies on providers that may act as processors: the web hosting and email provider, and Google Ireland Limited for audience measurement services (Google Analytics and Google Tag Manager) and form protection (reCAPTCHA), which are only activated if the User accepts the corresponding cookies. Google may transfer data to the United States under the EU-US Data Privacy Framework and the standard contractual clauses approved by the European Commission.

Should the Controller intend to transfer personal data to a third country or international organisation, at the time the personal data are obtained the User will be informed of the third country or international organisation to which the data are intended to be transferred, as well as of the existence or absence of an adequacy decision by the Commission.

Personal data of minors

In accordance with Article 8 of the GDPR and Article 7 of Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights, only persons over 14 years of age may lawfully give their consent to the processing of their personal data by Kamay. In the case of a minor under 14, the consent of their parents or guardians shall be required for the processing, and it shall only be considered lawful to the extent that they have authorised it.

Secrecy and security of personal data

Kamay undertakes to adopt the technical and organisational measures necessary, according to the level of security appropriate to the risk of the data collected, so as to guarantee the security of personal data and prevent the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised disclosure of or access to such data.

The Website has an SSL (Secure Socket Layer) certificate, which ensures that personal data are transmitted securely and confidentially, as the transmission of data between the server and the User, and vice versa, is fully encrypted.

However, since Kamay cannot guarantee that the internet is impregnable or the complete absence of hackers or others fraudulently accessing personal data, the Controller undertakes to notify the User without undue delay when a personal data breach occurs that is likely to result in a high risk to the rights and freedoms of natural persons. In accordance with Article 4 of the GDPR, a personal data breach means a breach of security leading to the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised disclosure of or access to such data.

Personal data shall be treated as confidential by the Controller, who undertakes to inform of and guarantee, by means of a legal or contractual obligation, that such confidentiality is respected by its employees, associates and any person to whom it makes the information accessible.

Rights arising from the processing of personal data

The User has, and may therefore exercise against the Controller, the following rights recognised in the GDPR and in Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights:

  • Right of access: the User's right to obtain confirmation as to whether or not Kamay is processing their personal data and, if so, to obtain information about their specific personal data and the processing that Kamay has carried out or is carrying out, as well as, among other things, the information available on the source of such data and the recipients of the communications made or planned.
  • Right to rectification: the User's right to have their personal data modified where they prove to be inaccurate or, taking into account the purposes of the processing, incomplete.
  • Right to erasure ("right to be forgotten"): the User's right, provided that current legislation does not establish otherwise, to obtain the erasure of their personal data when they are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn their consent to the processing and there is no other legal basis for it; the User objects to the processing and there is no other legitimate reason to continue it; the personal data have been unlawfully processed; the personal data must be erased in compliance with a legal obligation; or the personal data have been obtained as a result of a direct offer of information society services to a minor under 14. In addition to erasing the data, the Controller, taking into account available technology and the cost of implementation, shall take reasonable steps to inform the controllers processing the personal data of the data subject's request for erasure of any links to those personal data.
  • Right to restriction of processing: the User's right to restrict the processing of their personal data. The User has the right to obtain restriction of processing when they contest the accuracy of their personal data; the processing is unlawful; the Controller no longer needs the personal data but the User requires them for the purposes of legal claims; and when the User has objected to the processing.
  • Right to data portability: where the processing is carried out by automated means, the User shall have the right to receive their personal data from the Controller in a structured, commonly used and machine-readable format and to transmit them to another controller. Where technically feasible, the Controller shall transmit the data directly to that other controller.
  • Right to object: the User's right that their personal data not be processed, or that Kamay cease processing them.
  • Right not to be subject to a decision based solely on automated processing, including profiling: the User's right not to be subject to an individual decision based solely on the automated processing of their personal data, including profiling, unless current legislation provides otherwise.

Accordingly, the User may exercise their rights by written communication addressed to the Controller with the reference "RGPD-grupokamay.es", specifying:

  • The User's first name and surname(s) and a copy of their national identity document (DNI). Where representation is permitted, identification of the person representing the User by the same means shall also be required, as well as the document evidencing the representation. The copy of the DNI may be replaced by any other legally valid means of proving identity.
  • Request stating the specific grounds for the request or the information to be accessed.
  • Address for notification purposes.
  • Date and signature of the applicant.
  • Any document supporting the request made.

This request and any other attached document may be sent to the following postal and/or email address:

  • Postal address: Calle Rodríguez de Valcárcel, 9, 07840 Santa Eulària des Riu (Illes Balears)
  • Email: info@grupokamay.es

Links to third-party websites

The Website may include hyperlinks or links that provide access to web pages of third parties other than Kamay, which are therefore not operated by Kamay. The owners of those websites will have their own data protection policies and shall, in each case, be responsible for their own files and their own privacy practices.

Complaints to the supervisory authority

If the User considers that there is a problem or infringement of current regulations in the way their personal data are being processed, they shall have the right to effective judicial protection and to lodge a complaint with a supervisory authority, in particular in the State of their habitual residence, place of work or place of the alleged infringement. In Spain, the supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos).

II. Acceptance of and changes to this privacy policy

The User must have read and agree with the conditions on the protection of personal data contained in this Privacy Policy, and accept the processing of their personal data so that the Controller may carry it out in the manner, for the periods and for the purposes indicated. Use of the Website shall imply acceptance of its Privacy Policy.

Kamay reserves the right to modify its Privacy Policy at its own discretion, or as a result of a legislative or case-law change or a change in the doctrine of the Spanish Data Protection Agency. Changes or updates to this Privacy Policy will not be explicitly notified to the User. The User is advised to consult this page periodically in order to be aware of the latest changes or updates.

This Privacy Policy was updated to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR) and with Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights.