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01

Privacy policy

This policy explains how personal data collected through karmina.ai, the Karmina AI Studio website, as well as the data that interested parties provide when they contact Karmina through the forms or email addresses published on the website.

The information has been written to be clear and accessible. It does not replace the contracts, processing agreements or specific information that may correspond to a specific project.

02

Responsible for the treatment

Dunder Mifflin Paper Company, S.L. CIF: B13867270 Domicile: Carrer d’Aribau, 171, 5-2, 08036 Barcelona General contact of privacy and administration: gerencia@agenciakarmina.com

Karmina AI Studio is a vertical of Karmina. The person responsible for the processing of the data collected on this website is the company indicated in this section.

03

What data we can process

Depending on how a person uses the website or contacts Karmina, we can treat:

  • Identification and contact data: name and surname, email and telephone.
  • Professional data: company or organization, position, department, sector and needs of the project.
  • Information included voluntarily in the comments field or in the emails we receive.
  • Data related to a training consultation or FUNDAE, such as the area to be trained, the approximate number of participants or interest in the management of the bonus.
  • Data of applications sent through the Jobs form or to jobs@agenciakarmina.com, such as curriculum, experience, training, availability, collaboration modality, time zone and professional links provided voluntarily.
  • Technical and navigation data, if the corresponding cookies have been accepted: consulted pages, interactions, device, browser, origin campaign and online identifiers generated by the analytical tool.
  • Minimum attribution data associated with a query: landing page source, form, CTA and UTM parameters available.

We do not ask that personal data of third parties, confidential information, special categories of data or sensitive documentation be included in the forms. If it is necessary to work this information within a project, the need, permits, security measures and contractual conditions will be defined in advance.

04

Where the data comes from

The data comes mainly from the interested party when:

  • Fill out a form on the website.
  • Write to one of the published email addresses.
  • Request information about a service, an agent, a training or FUNDAE.
  • Send a nomination.
  • Maintain a professional or contractual relationship with Karmina.

The technical and analytical data come from the device or browser, in accordance with the chosen cookie preferences.

05

What we use the data for and for what legal basis

Consultations on projects, services and agents

We use the data to understand the query, answer it, assess its fit, prepare a meeting or proposal and follow up strictly related to the request.

The legal basis is the application of pre-contractual measures at the request of the person concerned and, where applicable, the legitimate interest in properly managing the professional relationship initiated by that person.

Training and FUNDAE

We use the data to answer queries, guide on a training, prepare a proposal, estimate the fit of the project and, if the service is contracted, manage the organization and documentation.

The FUNDAE guidance calculator works without name, mail or registration. The result is informative and does not amount to the official consultation of the credit or guarantee a bonus.

The legal basis is the application of pre-contractual measures, the execution of the contract when it exists and compliance with the legal obligations applicable to the management of the bonus training.

Relationship with customers, suppliers and collaborators

We use data to manage projects, communications, contracts, billing, payments, suppliers, documentation and administrative obligations.

The legal basis is the execution of the contract, compliance with legal obligations and, in certain cases, the legitimate interest in the management and continuity of the professional relationship.

Candidates, collaborations and talent network

Data sent through Jobs or a jobs@agenciakarmina.com are used to assess the candidacy, respond to a proposal for collaboration and manage a specific professional process. Each opportunity will indicate if it is an open offer, a possible collaboration per project or an incorporation into the talent network.

The legal basis for managing a candidacy linked to a specific opportunity is the application of pre-contractual measures at the request of the person concerned. The preservation of the profile for future opportunities is based on a separate, optional and non-premarked consent, which can be withdrawn at any time.

Commercial communications

We will only send general commercial communications when there is a legal basis that allows it. When consent is required, it will be requested with a separate, optional and non-pre-marked box. It can be withdrawn at any time.

Filling out a form to request information does not imply automatically subscribing to any newsletter.

Web analytics

If the person accepts analytical cookies, we will use Google Analytics 4, implemented through Google Tag Manager, to understand in aggregate form how the web is used, which contents are useful and which routes facilitate contact.

The legal basis is consent. The analytical tools will not receive names, companies, emails, telephones or the content of the forms.

Safety and prevention of abuse

We can process minimum technical data to protect the web, detect attempts of improper access, prevent automated shipments and maintain the availability of the service.

The legal basis is the legitimate interest in ensuring the security of the website and, where applicable, compliance with legal obligations.

06

Is it mandatory to provide the data?

The fields marked as mandatory are necessary to manage the consultation. If they are not facilitated, it may be impossible to respond or properly prepare the contact.

The comments and other optional fields help to better understand the need, but they are not mandatory.

In the Jobs form, the necessary fields will be mandatory to identify the person, contact them, understand the opportunity and evaluate their professional fit. Links to profiles, portfolios or repositories will be optional. The person must not include in the curriculum or in the comments special categories of data or information that is not necessary for the candidacy.

07

To whom we may communicate the data

We do not sell personal data or transfer it to third parties for their own commercial purposes.

They can access the data, under the corresponding conditions:

  • Providers of hosting, maintenance, security and web infrastructure.
  • Microsoft 365, Microsoft Lists, SharePoint, and Power Automate used to privately manage internal queries, candidates, documents, and flows.
  • Providers of analytics and consent management, only when the corresponding cookies have been accepted.
  • Professional legal, tax, labor, accounting or technological advice.
  • Entities linked to the management of FUNDAE when necessary and the company concerned has been previously informed.
  • Public administrations, courts or competent bodies when there is a legal obligation.

When a provider processes data on behalf of Karmina, it acts as the processor and is subject to a contract and documented instructions.

08

International transfers

Some technology providers may process data from countries outside the European Economic Area. In these cases, Karmina will apply the guarantees required by the regulations, such as an adequacy decision of the European Commission, standard contractual clauses or other legally recognized mechanisms.

The cookie policy will identify the specific providers linked to the tracking technologies that are finally activated.

09

How long we keep the data

  • Consultations and opportunities: up to two years from the last significant interaction, unless the relationship continues or is requested prior to deletion.
  • Customers and suppliers: during the contractual relationship and, later, during the periods necessary to comply with legal obligations or meet possible responsibilities.
  • Candidates linked to a specific opportunity: during the process and up to six months after it ends, unless it is necessary to keep them for a different period to meet obligations or possible responsibilities.
  • Talent Network: for a maximum of 12 months from consent. After this period, the profile will be deleted or a new consent will be requested. The person can request the deletion before.
  • Commercial communications based on consent: until the consent is withdrawn or the withdrawal is requested.
  • Analytics: according to the deadlines indicated in the cookies policy and the configuration of the provider, applying minimization criteria.

When the data is no longer necessary, it will be deleted or blocked during the periods in which legal responsibilities may arise.

10

What rights can be exercised

Anyone can apply for:

  • Access to your personal data.
  • Rectification of inaccurate data.
  • Delete when data is no longer needed.
  • Limitation of treatment in the cases provided by law.
  • opposition to certain treatments.
  • Data portability where applicable.
  • Withdrawal of consent at any time, without affecting the legality of the previous treatment.

The application can be sent to gerencia@agenciakarmina.com, indicating the right to be exercised and the information necessary to identify the request. We will only ask for additional identification documentation when it is essential to verify identity.

You can also file a complaint with theSpanish Data Protection Agency.

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Automated decisions and use of artificial intelligence

The forms on this website are not used to make automated decisions that produce legal effects or significantly affect people.

Karmina can use AI tools as internal support to sort, summarize or prepare information, always under criteria of minimization, permissions and human review. Personal or confidential data will not be entered in unauthorized tools nor will the AI be used to automatically decide if a query, application or company should be accepted or discarded.

12

Security

Karmina applies technical and organizational measures appropriate to the risk to protect the data against unauthorized access, loss, alteration or improper disclosure. Internal access is limited to people who need the information to perform their functions.

No system is completely invulnerable. If an incident that may affect people is detected, it will be acted in accordance with the applicable management and notification obligations.

13

Minors

This website is aimed at companies, organizations, professionals and adults. It is not designed to knowingly collect data from minors.

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Cookies

The cookies necessary for the operation and security of the website can be activated without consent when the regulations allow it. Analytical or other non-essential cookies will only be activated after the person has accepted the use.

The cookies policy will inform each technology, provider, purpose, duration and mechanism to withdraw or modify consent.

15

Links and third-party services

The website may contain links to external websites, such as agenciakarmina.com, utopiq.io or other sources and tools. Each site has its own privacy policy. We recommend reviewing it before providing data.

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Changes to this policy

We may update this policy to reflect regulatory, organizational or technical changes. The current version will always indicate the date of the last update.

Last update: 29 August 2026.