Privacy Policy
Last updated: 31/10/2025
This Privacy Policy explains how Kulma (hereinafter, "Kulma" or "we") treats the personal data of users who visit our portfolio and contact us.
1. Data Controller
- Controller: Daniel Sánchez Martínez
- NIF/CIF: 45387561M
- Address: Paseo de las Delicias Nº7, Portal 3, 4B, 11406 Jerez de la Frontera, Cádiz (Andalucía, España)
- Email: info@kulma.es
- Phone: 660 99 26 69
- Website: https://kulma.es
Our portfolio is purely informative (showcase of work) and a contact channel. We do not sell online nor process payments.
2. Data We Process and How We Obtain It
We only process minimal and adequate data to serve you:
- Identification and contact information: name, surname, email, phone, company and position (if applicable), as well as the content of the message you send us.
- Basic technical access data (server logs): IP address, date/time, requested URL and browser, necessary for the security and functioning of the site.
Data origin: you provide them directly through the form or by email; logs are automatically generated by the server.
3. Purposes and Legal Bases
| Purpose | Legal Basis |
|---|---|
| Addressing your inquiries, information requests and quotes. | Consent (Art. 6.1.a GDPR) and/or pre-contractual measures (Art. 6.1.b). |
| Ensuring security, maintenance and proper technical functioning of the site (logs). | Legitimate interest in security and operability (Art. 6.1.f). |
| Compliance with legal obligations (e.g., if a contract is formalized: billing/accounting). | Legal obligation (Art. 6.1.c). |
We do not perform profiling nor automated decision-making with legal effects.
4. Retention Periods
- Inquiries/Contact: up to 12 months from the last interaction or while the negotiation of a possible project lasts.
- Documentation derived from contracts (if there is ultimately a relationship): during the validity of the contract and legal retention periods (5–6 years generally in fiscal/commercial matters).
- Server technical logs: for the time strictly necessary for security and diagnostics (usually 30–90 days).
5. Security
We apply reasonable technical and organizational measures to protect your data (access control, encryption in transit via TLS/HTTPS, backups and internal procedures). Although no system is completely infallible, we work to minimize risks.
6. User Rights
You can exercise your rights of access, rectification, erasure, objection, restriction of processing and portability, as well as withdraw your consent at any time (without retroactive effects).
How to exercise them: write to info@kulma.es indicating "Data Protection" and providing proof of identity.
If you consider that we have not addressed your rights, you can file a complaint with the Spanish Data Protection Agency (AEPD).
7. Accuracy and Updating of Data
You commit to providing truthful, accurate and up-to-date data. If they change, please notify us to keep them up to date.
8. Social Media and Portfolio
We display work and projects on our portfolio and on social media profiles (e.g., Instagram, TikTok, YouTube, LinkedIn) based on contracts, authorizations and/or legitimate interest to disseminate our professional activity, respecting applicable image rights.
Interaction on these platforms is governed by their own policies. If you wish to object to the publication of specific material (when possible) or revoke an authorization, write to us at info@kulma.es.
9. Changes to the Privacy Policy
We may update this Policy to reflect legal or processing changes. We will publish the current version with its update date.
