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Privacy Policy


Produccions d’Empatia Digital, SL («KOTOC») is owner of the website at (hereinafter, the «Website») is committed to protecting the personal data of users («User/s») who use the Website and provide us their personal data through it. This policy is also applicable to processing of your data when referenced by email or other communications with KOTOC.

Through this Privacy Policy, and in compliance with Regulation (EU) 2016/679 («GDPR») and Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights («LOPDPGDD»), KOTOC informs Users who communicate with KOTOC through the Website about how their personal data may be collected and processed by KOTOC in order for Users to decide, freely and voluntarily, if they wish to provide the requested information.

Data Controller

The Data Controller for processing personal data on and in communications with us is Produccions d’Empatia Digital, SL, with address at Via Augusta 128, Entresuelo, Pª 108, Barcelona, Spain. All communications regarding the processing of personal data by KOTOC shall be directed to our email address:

Data collected, purpose and legal basis

Through our Website, we collect and process the following data:

Data Purpose
In our “Contact” form: your name, email address, subject, and message Business contacts and commercial opportunities.
In our “Job” form: your name, email address, subject, and other information indicated therein. Professional contacts for job opportunities and otherwise working with KOTOC.

The legal basis for the processing of this data is the consent given by the User in each case. You have the option at any time to withdraw your consent to the processing of this data. To do so, you may, at any time, exercise your right of erasure by sending an e-mail or post to the addresses indicated in section 7 of this Privacy Policy.

Please ensure that the personal data we store about you is accurate and up to date. It is your responsibility to ensure that the information you provide to us is correct.

Data sharing and international transfers

KOTOC processes your personal data with strict confidentiality in accordance with applicable law. However, we shall disclose any personal or other data you provide us in compliance with a legal obligation or in order to correctly perform other obligations in accordance with applicable regulations. KOTOC will ensure that your identity will be kept strictly confidential and will not be passed to a third party outside of what has been stated and agreed herein.

KOTOC uses third party technology services to ensure the operation of this Website, which may process your personal data collected through the forms on the Website, as data processors. These entities are in the EU. We also use Forms for collecting certain data, which are hosted by Google LLC, with whom we have entered into an agreement that includes appropriate safeguards in accordance with applicable law, including Standard Contractual Clauses («SCCs»). More information about the personal data processing by Google for us is at and

Likewise, KOTOC may share your professional contact data with our clients and commercial partners in joint activities where you are involved, as well as to make the personal data available to any company interested in purchasing or that purchases KOTOC or a part of its business and, consequently, to give access to any national or international auditors in order to carry out its «due diligence» whenever such processing is indispensable for the satisfactory achievement of the corporate operation. As indicated in article 21 LOPDGDD, if the operation is not completed, the data will be immediately deleted by the receiving entity.

Data retention

KOTOC will retain the personal data submitted through the contact and job forms as long as needed to fulfil the purposes for which it is collected, including any commercial discussions and relations and employment and contracting opportunities. Once such personal data is no longer used for these purposes, it will be deleted, however KOTOC may retain business contact details for 2 years after termination of active communications with you for archiving purposes. Also KOTOC may retain personal data beyond the aforementioned periods for legal or administrative reasons, such as defending our responsibility and complying with mandatory legal obligations, subject to applicable law.

Security Measures

KOTOC undertakes to adopt the appropriate technical and organizational measures in accordance with current regulations so as to ensure the security of personal data and prevent accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to them. Personal data shall be treated as confidential by the KOTOC, who undertakes to inform and to ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any other person to whom it makes the information available.

Data subject rights

You have the following rights under data protection laws in relation to your personal data:

  1. Request access to your personal data (commonly known as a «data subject access request»).
  2. Request correction of the personal data that we hold about you, Request erasure of your personal data.
  3. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party).
  4. Request restriction of processing of your personal data.
  5. Request the transfer of your personal data to you or to a third party (right to data portability).
  6. Withdraw consent at any time where we are relying on consent to process your personal data.
  7. Submit a complaint to the competent authority, in this case the Spanish Data Protection Agency (, C/. Jorge Juan, 6, 28001 Madrid, Spain.

The aforementioned rights may be effective by contacting us at or at KOTOC with address set out above, provided that you include a digital copy of your identification document such as your ID card or passport.

Version update: 18/06/2021

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