Global Privacy Policy

This Privacy Policy applies to any processing of Personal Data carried out by ELECTRONICA KELD. The Policy is intended to be worldwide, although it may be further supplemented by local provisions in relation to the processing of data carried out by ELECTRONICA KELD companies located or operating in certain countries.

The Policy is intended to answer any questions you may have regarding the processing of your Personal Data as a Data Subject, although in case you need more information, you can contact: .

It is important for you to read this Policy carefully in order for you to make an informed choice when providing us with your Personal Data. 

What definitions do I need to know in order to better understand the Policy?

We would like to provide you with the definition of some of the terms that you will find throughout this document:

  • “Activities, Products and/or Services” – Refers to invitations to commercial, informative, sports or recreational events, promotions, contests, raffles and commercial information on ELECTRONICA KELD’s products and services, and through different channels.
  • “Anonymization” – use of a set of techniques aimed at removing the ability to associate data with an identified or identifiable natural person by means of a “reasonable” effort. This “reasonableness test” must take into account both objective aspects (time, technical means) and contextual elements, which may differ from case to case (exceptional nature of a phenomenon taking into account, for example, the density of the population and the nature and volume of the data).
  •  “Communication of data” – means any disclosure of data to a natural or legal person, public authority, service or other body, whether or not it is a Third Party.
  • “Standard Contractual Clauses” – a mechanism that makes it possible, through the signing of a contract based on the model approved by the European Commission, to regulate international transfers of Personal Data to countries outside the European Economic Area.
  • “Consent” – free, unequivocal, specific and informed manifestation of will to the processing of Personal Data.
  • “Cookies” – Cookies are small files or devices that are installed in the user’s browser in order to store, retrieve or update information. Through them, the editor of a website can try to know the preferences of users when browsing its website and customize the services offered based on those preferences. You can find more information in the ELECTRONICA KELD Cookies Policy. 
  • “Personal Data”– any information about a natural person that identifies him/her or makes him/her identifiable (first and last name, address, telephone number, e-mail address, etc.).
  • “Data Protection Officer” – data protection specialist who informs and advises the ELECTRONICA KELD group on the processing of Personal Data and related obligations under the GDPR.
  • “Recipient” – means a natural or legal person, public authority, service, or other body to whom Personal Data is disclosed, whether or not it is a Third Party.
  • “Profiling” – means any form of automated processing of Personal Data consisting of using Personal Data to evaluate certain personal aspects of a natural person, to analyze or predict aspects relating to that natural person’s professional performance, financial situation, health, personal preferences, interests, reliability, behavior, location or movements.
  • “Data processor” – a natural or legal person, public authority, service, or body that carries out a processing operation on behalf of a third party (the Data Controller). Sometimes it is ELECTRONICA KELD for all its subsidiaries or third-party suppliers since we have a centralized management of most of the matters related to organization and business.
  • “Geolocation” – means any data processed in an electronic communications network that indicates the geographic position of a Data Subject’s terminal equipment of a publicly available electronic communications service.
  • “Data Subject” – for the purposes of this Policy, shall mean any natural person who is the owner of the processed data.
  • “Binding Corporate Rules” – Personal Data protection policies undertaken by a controller or processor established in the territory of a Member State for transfers or a set of transfers of Personal Data to a controller or processor in one or more third countries, within a corporate group or a union of undertakings engaged in a joint economic activity.
  • “Pseudo-anonymization” – means the processing of Personal Data in such a way that they can no longer be attributed to a Data Subject without the use of additional information, provided that such additional information is separately identified and is subject to technical and organizational measures designed to ensure that the Personal Data are not attributed to an identified or identifiable natural person.
  • “Data controller” – means the natural or legal person, public authority, service or body that decides what data to process, why and how.
  • “Online Services” – includes any site environment, website, channels, applications, promotions.
  • “Third Party” – natural or legal person, public authority, service or body other than the Data Subject, the Controller, the Processor and the persons authorized to process the Personal Data under the direct authority of the Controller and/or the Processor.
  • “International Transfers” – those cases where Personal Data is processed outside the European Economic Area (EEA).
  • “Processing” – operation or set of operations performed on Personal Data or sets of Personal Data, whether or not, by automated procedures, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, communication by transmission, dissemination or any other form of enabling access, alignment or interconnection, restriction, erasure or destruction.

How will the Personal Data be processed?

Your Personal Data will be processed in accordance with the provisions of current Personal Data protection regulations and, particularly:

(i) 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 and repealing Directive 95/46/EC – General Data Protection Regulation (hereinafter referred to as “GDPR”);

(ii) Organic Law 3/2018, of December 5, 2018, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter, “LOPDGDD”);

(iii) any national legislation, of any country, that regulates the processing of Personal Data;

(iv) or any regulation that modifies, develops, or replaces the previous ones.

Who is the Data controller of the Personal Data?

In general, the ELECTRONICA KELD company with which you have dealings will be the Data controller.

With whom will we share the Personal Data?

As a general rule, the Data controller will not share your Personal Data with third parties.

When we identify that we will be required to communicate your Personal data to a Third Party, we will inform you at the time of collection about the identity or categories of the potential Recipients to whom we may need to communicate your Personal data. Generally speaking, we will be referring to the following Recipients:

 i. Competent authorities and bodies, courts, tribunals, or any other legitimate Third Parties according to applicable regulations;

ii. Third party holders of files for the fulfillment of monetary obligations, when the client incurs in a default of payment, and the legitimizing requirements established in article 20 of the LOPDGDD are met;

iii. Third Parties that own services or products that the Data Subject voluntarily requests;

Furthermore, it is also possible that Third-Party suppliers may have access to the Data Subject’s Personal Data in order to provide services to the Data controller, related to the purposes about which you are being informed (including, but not limited to, companies operating in the following sectors: technology, legal advice, marketing, multidisciplinary professional services, IT services, etc.). These suppliers will only access the Personal Data to carry out their services on behalf of the Data controller, under obligation of confidentiality and always following the Data controller’s instructions, without at any time using such data for their own purposes and/or unauthorized purposes.

Finally, and during an internal investigation, the data may be communicated to the Ethics and Conduct Committee of ELECTRONICA KELD.

What are the Data Subject rights?

At any time, you may exercise a series of rights regarding the processing of your Personal data. We will inform you at the time of collection of the Personal data as they may be different according to the local regulations These rights are inherent to each person and, therefore, are inalienable and are as follows as long as they are recognized in accordance with local regulation:

Right of access

The right to access Personal data processed by the Data controller according to Article 15 of the GDPR.

Right to rectification

The right to request that the Data controller rectify certain personal of the Data Subject according to Article 16 of the GDPR.

Right to object

The right to object to Processing based on consent or on the existence of a legitimate interest (including, but not limited to, the sending of commercial communications), according to Article 21 of the GDPR. In cases that the Processing is based on the existence of a legitimate interest, the Data Subject will have the right to request the balancing test carried out by the Data controller. Furthermore, when the Processing is for the purposes of sending own or third-party commercial information, the Data Subject may opt-out free of charge and voluntarily to an advertising opt-out mechanism (more information can be found here: https://www.listarobinson.es/).

Right to erasure

The right to request that the Data controller deletes all or part of the Data Subject’s Personal data according to Article 17 of the GDPR.        Please note that while the commercial and/or contractual relationship that we maintain with you continues to be in force, there is a series of Personal Data that is necessary for us to process in order to comply with the contract, so while it lasts we cannot delete, block or cancel them, because otherwise it would prevent us from complying with the contract.

Right to the limitation to the processing

The right to limit the Data Controller’s processing of your Personal data, provided that one of the conditions established in Article 18 of the GDPR are met.

Right to withdraw consent

For the types of processing identified in the section on Processing based on the consent from the Data Subject, without such withdrawal of consent having a retroactive effect, according to Article 7.3 of the GDPR.

These rights may be exercised by sending a communication to the address of the Data Controller or through the following address:  

What are your responsibilities?

You are responsible for all of the data you provide to us, for the veracity, accuracy, validity, updating, and authenticity of said data, as well as for the consent you give us so that your data may be used/processed. You are also responsible for third-party data you provide to us and for which, you undertake to obtain their consent and making available the information we usually provide our users for any data processing as well as our privacy policy.

You are responsible for regularly checking this Policy and any updates made to it.  Further, if your job involves the processing of Personal Data, you are responsible for ensuring that you do so in accordance with the applicable privacy regulations and local legislation.