Privacy Policy

In accordance with the provisions of data protection regulations, GRUPO K REFRIGERACIÓN establishes as an essential requirement for accessing this website that the user must be over 14 years of age. If you are under 14 and have accessed this website, you must not provide us with any of your data. Responsibility for the veracity of this information lies with you. In the event that GRUPO K REFRIGERACIÓN verifies that the aforementioned requirement is not met, it has the authority to disregard the request for information submitted. Under no circumstances will data relating to the professional or economic situation or the privacy of other family members be collected from a minor without their consent.

The data controller for your data is GRUPO K REFRIGERACIÓN, S.L. with CIF B71241558, located at Polígono Landaben, Calle A nº 2, 31012, Pamplona (Navarra), telephone: +34 948 188 100 and email address: rgpd@koxka.com.

From the GRUPO K REFRIGERACIÓN website, we process the personal information that the user provides to us directly.

In general, we will process identifying data (such as first and last name, email, telephone, postal code, city, or IP address).

The user guarantees the authenticity, accuracy, and veracity of all information provided, committing to keep personal data updated so that it reflects their real situation at all times. The user shall be solely responsible for false or inaccurate statements and for any damages they may cause.

The data you provide may be used for one or more of the purposes indicated below, which will be determined by factors such as your relationship with GRUPO K REFRIGERACIÓN or the means used to submit the data. Below, we outline the processing activities referred to in this policy, without prejudice to others for which you may be informed or requested for the appropriate authorization:

a) Compliance with legal obligations

It may be necessary to process personal data to comply with relevant legal requirements. Specifically, to comply with data protection, tax, statistical, insurance legislation, etc.

b) Contractual fulfillment: the data you provide as a customer, supplier, or employee of ours will be used to fulfill the contractual relationship established, along with all legal obligations derived from it.

c) Communication-contact

The data you send us via email or instant messaging applications are used to respond to the request submitted.

d) Sending commercial communications by any means in case of additional consent

If you explicitly consent, your data may be transferred to our collaborating entities for the purpose of informing you by any means for promotional purposes regarding this project.

Any modification that may occur in personal data must be reported by the data subject, who shall be responsible in any case for the veracity and accuracy of the data provided at all times.

e) Job board

We will process your data to include your CV in our job board for the purpose of involving you in job offers that may fit your profile. We will process your data to evaluate and manage your job application.

f) Video surveillance:

Images captured by security cameras located at our facilities are processed for the purpose of guaranteeing the security of the facilities, assets, and people, as well as for labor control.

g) Whistleblowing channel

The data provided will be processed to respond to the inquiry raised or, where appropriate, to process the report made in accordance with our internal information system adapted to Law 2/2023.

We collect your personal information through different means, but you will always be informed at the time of collection through informative clauses regarding the data controller, the purpose and legal basis for processing, the entities receiving the data, and the retention period of your information, as well as how you can exercise your data protection rights.

In general, the personal information we process is limited to identifying data.

Through our website, we collect personal information related to your browsing through the use of cookies. To clearly and precisely understand the cookies we use, their purposes, and how you can configure or disable them, please consult our Cookies Policy.

We only retain your information for the period necessary to fulfill the purpose for which it was collected, comply with the legal obligations imposed on us, and address any potential liabilities that may arise from the fulfillment of the purpose for which the data were collected. Your personal data will be kept for the duration of the legal relationship and, subsequently, provided you have not exercised the right to erasure, they will be kept taking into account the legal limitation periods for liabilities applicable in each specific case, considering the type of data and the purpose of the processing.

In the event that you exercise a right to erasure and it is applicable, in compliance with Art. 32 LOPDGDD, the data will be blocked, remaining available only at the request of Courts and Tribunals, the Ombudsman, the Public Prosecutor’s Office, or competent Public Administrations during the limitation period for any resulting actions; once this period has elapsed, they will be completely deleted.

We process your data in a lawful, fair, transparent, adequate, relevant, limited, accurate, and updated manner. Therefore, we commit to adopting all reasonable measures so that data is deleted or rectified without delay when it is inaccurate.

Depending on the relationship we maintain and therefore the purpose of the processing, the legal basis may differ. Below, we outline the different bases applicable depending on the processing carried out:

• CONTRACTUAL RELATIONSHIP: To be able to provide our business services.
• APPLICATION OF PRE-CONTRACTUAL MEASURES: When you send us your CV for inclusion in our job board.
• LEGITIMATE INTEREST: Among others, for profiling, quality or opinion surveys, and website maintenance. Labor control through video surveillance.
• LEGAL OBLIGATION: For compliance with obligations established in any applicable regulations.
• CONSENT: When you provide us with your data through forms, instant messaging applications, or for sending commercial communications by electronic means. You should know that for processing where consent is requested, its non-granting or eventual subsequent withdrawal will not have negative consequences for you.
• MISSION IN THE PUBLIC INTEREST: regarding images taken to guarantee the security of facilities and people.

In the event that third-party data is provided, you declare that you have the consent of the data subjects for said communication of data or, where appropriate, hold their legal representation, exempting the partners and collaborators of GRUPO K REFRIGERACIÓN from all liability.

The categories of data we process are:

• Execution of a contract: identifying data (name, surname, ID number, telephone, email, postal address), economic data (bank account numbers).
• Pre-contractual Measures: identifying data, personal characteristics data, academic and professional data, employment detail data.
• Contact: identifying data (name, telephone, email, and IP address).
• Commercial communications-newsletter: identifying data (email).

Depending on the services we provide to you, your personal data may be communicated to third parties, such communication being necessary for the proper fulfillment of legal and/or contractual obligations. These provider entities will not process your data for their own purposes that have not been previously informed by GRUPO K REFRIGERACIÓN.

In cases where, for better management and provision of our professional services, access to data occurs on behalf of third parties, GRUPO K REFRIGERACIÓN guarantees the maintenance of confidentiality in the processing of personal data and the signing of a data processor contract or, where appropriate, a confidentiality commitment with these providers.

Likewise, your data may be transferred to:

• WhatsApp®: if you use this instant messaging system to communicate with us, you should know that your data will be processed by WhatsApp Ireland Limited.
• Financial entities for the management of collections and payments.
• On certain occasions, it is necessary to rely on other entities or service providers; in this case, these professionals will be recipients of your data, but this will always be done with contracts and guarantees subject to the models approved by the authorities.
• In other cases, it will be necessary to send data to public bodies, registries, and other types of public administrations. These communications are always due to a legal obligation.
• Lawyers and Solicitors.
• Notaries.
• Courts and Tribunals.
• IT service providers.
• Web development and maintenance service providers.
• System maintenance service providers.
• Entity entrusted with the management of occupational risks.
• Entity entrusted with management before Fundae for worker training.
• Insurance companies.

• You have the right to withdraw consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
• The maximum period for resolution is one month from the receipt of your request, which may be extended for a further two months depending on the number of requests received or their complexity.
• If you believe that your request has not been correctly addressed, you may contact the Spanish Data Protection Agency (www.aepd.es) and file a claim.
• To exercise your rights, please accompany your request with a copy of your ID card, NIE, Passport, or other document proving your identity.
• The exercise of these rights is free of charge.

These rights are characterized by the following:

• Their exercise is free of charge, unless the requests are manifestly unfounded or excessive (e.g., repetitive nature), in which case GRUPO K REFRIGERACIÓN may charge a fee proportional to the administrative costs incurred or refuse to act.
• You can exercise your rights directly or through your legal or voluntary representative.
• We must respond to your request within one month, although, taking into account the complexity and number of requests, the period may be extended by a further two months.
• We have the obligation to inform you about the means to exercise these rights, which must be accessible, and we cannot deny you the exercise of the right solely for choosing another means. If the request is submitted by electronic means, the information will be provided by these means whenever possible, unless you request otherwise.
• If GRUPO K REFRIGERACIÓN does not act on the request, it will inform you, at the latest within one month, of the reasons for its non-action and the possibility of complaining to a Supervisory Authority.

At GRUPO K REFRIGERACIÓN, we are committed to protecting your personal information. We use physical, organizational, and technological measures, controls, and procedures that are reasonably reliable and effective, aimed at preserving the integrity and security of your data and guaranteeing your privacy. Furthermore, all personnel with access to personal data have been trained and are aware of their obligations regarding the processing of your personal data.

All these security measures are reviewed periodically to ensure their adequacy and effectiveness.

However, absolute security cannot be guaranteed and no security system is impenetrable; therefore, in the event that any information subject to processing and under our control is compromised as a result of a security breach, we will take appropriate measures to investigate the incident, notify the Supervisory Authority and, where appropriate, those users who may have been affected so that they can take appropriate measures.

GRUPO K REFRIGERACIÓN informs you that it complies with Law 34/2002 of July 11, on Information Society Services and Electronic Commerce and does not engage in SPAM practices; therefore, it will request your consent for the processing of your email or mobile phone for commercial purposes at all times.

We use the ReCaptcha service provided by Google Inc. (Google®) to protect and verify that the use of our data collection forms has been carried out by a human or a computer program. This service allows differentiating data sent by people from automated messages and is performed by evaluating the IP address, as well as other data required by Google for the use of the recaptcha service (e.g., time the visitor remains on the website, mouse movements). For this purpose, the collected data will be sent to Google and encrypted by the latter. In the member states of the European Union, as well as in states associated with the European Economic Area. Only in some exceptional cases will IP addresses be transmitted to the Google server in the United States for encryption.

For more information about Google Recaptcha and Google’s privacy policy, please consult the following link: https://policies.google.com/privacy?hl=en

GRUPO K REFRIGERACIÓN reserves the right to modify its data protection policy or conditions of use of its services for reasons of adaptation to current legislation, or other reasons; when this occurs, we will notify you of any changes and ask you to re-read the most recent version of our policy and, where appropriate, confirm your acceptance. Absolute confidentiality and privacy of the personal data collected are ensured, and therefore security measures have been adopted to prevent alteration, loss, unauthorized processing or access, and thus guarantee its integrity, availability, and security. However, GRUPO K REFRIGERACIÓN shall not be responsible for incidents that may arise regarding personal data when these derive from: either an attack or unauthorized access to systems in such a way that it is impossible to detect or prevent it even with the adoption of measures according to the current state of technology.

Last updated on June 19, 2025