Privacy Policy

The controller of personal data collected through this website is:

MARCO DE FARIA, a self-employed natural person trading under the brand KAIROS Precision Growth Systems.
Tax ID: 09240804W
Address: URB. COSTALITA II, EDF. SALINAS, BLQ 2E, 1C, ESTEPONA, 29680, MALAGA
Contact email: [email protected]

No Data Protection Officer has been appointed because no current obligation to appoint one has been identified for this activity.

We may process information you voluntarily provide when contacting KAIROS or using the Diagnostic form, including:

• name and contact details;
• company or organisation;
• email address;
• phone number and website, where provided;
• sector, business context, needs, problems or other information voluntarily entered into the form;
• technical information necessary to deliver and protect the request through our infrastructure.

The form is not designed to collect patient data, health information or other special-category personal data. Do not include such information in free-text fields.

Fields identified as required are necessary to process the enquiry. If they are not provided, we may be unable to receive or handle the request correctly. Optional fields may be left blank.

We process data to:

1. receive and respond to enquiries initiated by the data subject;
2. understand the business need described and, where appropriate, prepare a conversation, diagnostic, proposal or pre-contractual relationship;
3. manage professional communications with businesses and professionals;
4. maintain the security, availability and technical integrity of the site and communication channels;
5. handle data-subject requests and applicable legal obligations.

Submitting a Diagnostic enquiry does not, by itself, subscribe you to newsletters or unrelated marketing.

Where an individual requests information or steps prior to a possible contract, processing necessary to handle that request is based on Article 6(1)(b) GDPR.

Where a professional contact acts in the context of a company, sole trader or professional activity and processing is limited to managing that professional relationship, KAIROS may rely on legitimate interests under Article 6(1)(f) GDPR and, where applicable, Article 19 of Spain's LOPDGDD. The legitimate interest pursued is to manage and maintain B2B professional relationships and respond to communications connected with the contact's professional role or activity, without extending that use to unrelated marketing.

Where a specific legal obligation applies, processing will rely on Article 6(1)(c) GDPR.

Any future consent for unrelated commercial communications will be separate, specific and withdrawable.

KAIROS currently uses the following providers or services to operate the site and manage enquiries:

• Cloudflare, for website hosting, networking and website functions;
• SMTP2GO, for transactional delivery of messages generated by the form;
• Lark Suite, as the primary corporate mailbox where a copy of enquiries may be stored;
• Google/Gmail, as a secondary backup mailbox where an additional copy may be stored.

KAIROS does not sell personal data to advertisers and currently does not use Google Analytics, Meta Pixel, LinkedIn Insight Tag, TikTok Pixel, GTM or Hotjar on the main website route.

Some providers operate international infrastructure.

The primary organisational data residency configured for the Lark environment used by KAIROS is Japan. Japan is currently recognised by the European Commission as providing adequate protection for transfers covered by the adequacy decision.

Cloudflare and other international providers may process data in different locations under their applicable contracts, transfer mechanisms and subprocessors.

Google/Gmail may involve international processing under the terms and transfer mechanisms applicable to the service used.

Where a provider involves a transfer to a country without an applicable adequacy decision, the safeguards or transfer mechanisms recognised by the GDPR that are applicable to the specific service and processing will be used. You may request further information about the applicable safeguards by writing to [email protected].

KAIROS does not claim that all data remains exclusively in one country.

Enquiries that do not become clients are retained for 12 months from the last substantive interaction, with a quarterly review process.

This rule applies to active copies controlled by KAIROS in the recipient mailboxes used for Diagnostic.

If the enquiry becomes a client relationship, necessary data moves to the relevant contractual, accounting or legal file and is retained under the periods applicable to that relationship.

Where a claim, legal obligation or need to establish liability exists, specific data may be restricted or blocked for the applicable legal period and destroyed afterwards.

Technical providers may temporarily retain copies, logs or backups according to their own technical cycles and obligations.

You may request access, rectification, erasure, restriction, objection or portability where applicable by writing to:

[email protected]

Requests are free except in the exceptional cases allowed by law. KAIROS will generally respond within one month. Where necessary because of the complexity or number of requests, that period may be extended by up to two additional months; in that case, you will be informed of the extension and the reasons for it within the first month.

We may request reasonable information to verify your identity before acting on a request.

You may also lodge a complaint with the Spanish Data Protection Agency.

The Diagnostic form currently does not make legal-effect automated decisions, individual scoring, profiling of data subjects or decisions governed by Article 22 GDPR.

When KAIROS enables a social integration and the user chooses to connect it, the integration may process, depending on the platform and permissions actually granted, account or page identifiers, access tokens, permissions, content authorised for publication and operational data required to execute and record the requested actions.

Before an OAuth authorisation begins, KAIROS must clearly explain the platform, purpose, requested data categories or permissions, when the data will be collected, how it will be used, how authorisation can be withdrawn and how deletion can be requested. Further details are provided on the Social Publishing page (/en/social-publishing/). Mentioning a platform does not mean that it is active or connected.

KAIROS applies technical and organisational measures proportionate to the risk and seeks to limit access to people and providers that need the data to provide the service or comply with legal obligations.

No system can guarantee absolute security. This policy will be updated if the technical architecture or providers materially change.

KAIROS may update this Privacy Policy to reflect legal, technical or service changes. The current version will be the one published at this URL.