Privacy policy
Last updated: [DATE]
This policy explains how Kialy processes the personal data of people who visit kialy.com, request a demo or contact us. It is governed by Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD).
1. Data controller
- Controller: Chiarapp Tech, S.L.U. (“Kialy”)
- Tax ID (NIF): B26872762
- Address: [DOMICILIO SOCIAL]
- Privacy email: [EMAIL DE PRIVACIDAD]
Kialy is not required to appoint a data protection officer. For any privacy question, write to the email above.
2. What data we process, why, and on what legal basis
| Situation | Data | Purpose | Legal basis | Retention |
|---|---|---|---|---|
| Demo request through Calendly | Name, work email, company or hotel, job title, phone (optional), chosen date and time, and anything you tell us in the form | Arranging and running the demo and following up on that request | Steps taken at your request before entering into a contract (art. 6.1.b GDPR) | For as long as the business relationship lasts and, if no contract follows, up to 2 years after the last contact |
| Contact by email | Name, email and whatever you include in your message | Answering your enquiry | Legitimate interest in answering the messages we receive (art. 6.1.f GDPR) | As long as needed to resolve the enquiry and up to 1 year afterwards |
| Browsing the website | IP address and technical browser data in server logs | Providing the website, keeping it secure and preventing abuse | Legitimate interest in the security and operation of the site (art. 6.1.f GDPR) | According to the hosting provider’s retention periods, 30 days at most |
| Visitor statistics | Aggregated, anonymous data (page views, country, device type, referrer). No cookies are used and the full IP address is not stored | Understanding how the website is used in order to improve it | Legitimate interest (art. 6.1.f GDPR) | The data is aggregated and identifies no one |
We do not use your data for profiling or make automated decisions that affect you. We will not send you newsletters or marketing unrelated to your request unless you give separate consent.
The data you give us must be accurate. If you give us data about other people, such as a colleague who will join the demo, you must have told them first.
3. Who we share data with
We do not sell or disclose personal data to third parties unless required by law. To provide the service we use these providers, which process data on Kialy’s behalf as processors under a contract that complies with article 28 GDPR:
| Provider | Service | Location | Transfer safeguard |
|---|---|---|---|
| Cloudflare, Inc. | Website hosting and cookie-free visitor statistics | United States, with a server network in the European Union | EU-US Data Privacy Framework and standard contractual clauses |
| Calendly, LLC | Demo booking | United States | EU-US Data Privacy Framework and standard contractual clauses |
| [PROVEEDOR DE EMAIL] | [LOCATION] | [SAFEGUARD] |
When you book a demo, Calendly may also process data on its own account, for example through cookies on its own pages. That processing is governed by Calendly’s privacy policy.
4. Your rights
You can exercise these rights at any time by writing to [EMAIL DE PRIVACIDAD] and stating which right you are exercising:
- Access: find out what data about you we process.
- Rectification: correct inaccurate or incomplete data.
- Erasure: ask us to delete your data when it is no longer needed.
- Objection: object to processing based on legitimate interest.
- Restriction: ask us to keep your data without processing it, in the cases provided by law.
- Portability: receive your data in a structured, commonly used format.
- Withdrawal of consent: where processing is based on consent, without affecting processing carried out before.
We will reply within one month, which may be extended by two further months in complex cases; we will tell you if that happens. If we cannot verify your identity, we may ask you for more information.
If you believe we have not handled your rights properly, you can complain to the Spanish Data Protection Agency (www.aepd.es).
5. Security
We apply appropriate technical and organisational measures to protect data, such as an encrypted connection (HTTPS) across the whole website, restricted access to data and the choice of providers with security guarantees.
6. Minors
The website is aimed at hospitality professionals. We do not knowingly collect data from children under 14.
7. Changes to this policy
We may update this policy to reflect changes in the law or in the service. The date of the last update is always shown at the top.
This English version is provided for convenience. If it differs from the Spanish version, the Spanish version prevails.