Online-Marketing Agency


Plaça Gal·la Placidia, 3-5
8o2a, 08006 Barcelona

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Privacy Policy | Terms and conditions

Copyright © 2022 Karma Response.
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Privacy Policy

This Webpage is the property of KARMA RESPONSE, S. L., holder of NIF B66925538 whose registered offices are in Plaça Gal·la Placidia, 3-5; 8o2a, 08006 Barcelona and registered in the Companies Register of Barcelona, Tomo 46160 Página 129 Inscription B-511438.

For any consultation or proposal, please contact us at

Likewise, we place at your disposal a Data Protection Officer who will not only be responsible for supervising all the data processing carried out in our entity, but who will also be able to attend to you for any question related to the processing of personal data. The contact details of our Data Protection Officer are Lant Abogados (Lant Advisors, S.L.P.)

This Webpage is governed by law solely applicable in Spain and both national and foreign users of this Website are subject to same.

The USER’s access to our Webpage is free of charge and contingent upon reading and fully and expressly accepting without reservation these GENERAL CONDITIONS OF USE that are in effect at the time of access, which we would ask you to read carefully. When using our portal, its contents or services the USER expressly accepts and submits to the general conditions for the use of same. Should the user not be in agreement with these Conditions of Use, they must refrain from using this portal and operating via same.

We may modify the presentation and configuration of our Webpage, expand or reduce the services and even remove it from the Internet at any time, together with the services and contents provided, unilaterally and without prior notice.


All the content, texts, images and source codes are our property or third parties for which the exploitation rights were acquired and are protected by Intellectual and Industrial Property rights. The user is solely entitled to make private, not for profit use of same, and requires express authorisation to modify, reproduce, exploit or distribute them or exercise any other right belonging to the owner.


Access to our Webpage is free of charge and no prior subscription or registration is required. Any personal data sent implies express acceptance on the USER’s part of our privacy policy. The user must access our Webpage in good faith, in accordance with public order and these General Conditions of use. Access to our Website is at the sole liability of the user who shall be liable for any damages they may cause to us or to third parties.

Taking into account the impossibility of controlling the information, contents and services contained on third-party websites which are accessible via the links on our webpage, we inform you that we will not be liable for any damages of any nature which may arise from the use of these third-party webpages by the user.


The confidentiality and security are core values of KARMA RESPONSE, S.L. and we therefore undertake to ensure the User’s privacy at all times and not to gather any unnecessary information. Below we provide all the information necessary regarding our Privacy Policy in relation to the personal data collected, explaining:

- Who is the processor of your data.
- The purpose for which we gather the data requested.
- What is the legitimisation for their processing.
- The length of time we store the data.
- Who your data are assigned to.
- What your rights are and how you can exercise them.

1. PARTY RESPONSIBLE: See information in the heading.


• List of Advertisers from whom you may receive emails.

- Fossil Europe GmbH
- GmbH
- Verisure
- AllSaints Retail Limited
- Bill Buddy
- Bill Switchers
- Boots Hearingcare
- Clear Energy Switching
- ECHO Lloyds Pharmacy
- Evergen Solar
- Funeral Planning Experts
- GoGroopie
- Magnet Kitchens
- Marriage Tax Online
- Pharmacy2U
- Phlo Pharmacy
- Quotezone
- SkinLabo S.r.l
- Switchd Ltd
- The Medical Negligence Experts
- Whisky Scotland Investment
- Neilson Financial Services (British Seniors Insurance)
- Neilson Financial Services (Smart Insurance)

• Contact form.

Purpose: To answer your requests for information or suggestions, resolve your doubts, queries or requests and to send you information on our products, services and activities via digital media (Email, SMS, WhatsApp), if you check the acceptance box.

Legitimisation: The user’s consent when requesting information via our contact form and checking the acceptance box for the sending of commercial communications.

Retention: Until resolution of your request or email query, if no new processing has been generated and, if applicable, until you request to unsubscribe from further commercial information.

• Sending emails.

Purpose: To answer your requests for information or suggestions and deal you’re your doubts and queries regarding our service or products.

Legitimisation: The user’s consent when requesting information via our email address.

Retention: Once your email request has been answered, if no new processing has been generated. Obligation to provide your personal data and the consequences for a failure to do so. The supply of personal data requires a minimum age of 14 years, or, if applicable, sufficient legal capacity to enter into a contract.

The personal data requested are necessary to manage your requests and failure to do so signifies we cannot attend to your correctly or fulfil the purposes described above.

We reserve the right to decide whether or not to process your personal data.

Your data are confidential and will not be transferred to third parties unless legally required.

When consent is the basis for the data processing, it shall be revocable at all times and under no circumstance may withdrawal of consent condition the execution of the contracts or relations arising previously. You may also exercise the following rights:

• Request access to your personal data or rectification of same when inaccurate.
• Request their deletion when, amongst other reasons, they are no longer necessary for the purpose for which they were governed.
• Request the limitation of processing in certain circumstances.
• Request opposition to the processing of your data due to your particular situation.
• Request data portability when so provided in law.
• Other rights recognised in applicable law.

Where and how to exercise your Rights: By writing to the Data Controller (indicated at the beginning of the privacy policy) with the reference “Personal Data” or similar and indicating the right to be exercised and with regard to which processing at the postal or electronic address shown in section 1.

In the event of any dispute with the company with regard to the processing of your data you may lodge a claim before the Data Protection Authority (

In order to safeguard the security of your personal data, we inform you that we have adopted all the necessary measures of a technical and organisational nature to ensure the security of your personal data against alteration, loss and non-authorised processing and access.

It is important you inform us whenever there has been any modification so we may update your personal data; otherwise we cannot be liable for the accuracy of same.

We shall not be liable for the privacy policy regarding the personal data you may supply to third parties via the links on our webpage.

This privacy policy has been modified on 14/06/2021. We may modify these privacy conditions to adapt them to any modifications made to our website together with any legal or jurisprudential modifications regarding personal data which may appear, and you are therefore requested to read this policy every time you supply your data via this Website.


By placing this Webpage at the disposal of the user, we wish to offer a quality service by applying the maximum diligence to the provision of same and to the technological means used. However, we shall not be liable for the presence of virus or other elements that may damage the user’s computer system.

We do not warrant that the availability of the service be is continuous or uninterrupted.

The user is prohibited from any action on our site that results in excessive operational overload our computer systems and the introduction of viruses, or installation of robots, or software that alters the normal operation of our website, or ultimately to cause damage to our computer systems.

The USER accepts full liability for the use of our webpage.

The USER acknowledges that they have understood all the information relating to the conditions of use of our portal and that they are sufficient to exclude any error from same and therefore expressly acc


1. How we used cookies

Cookies are files that are installed for the aforementioned purposes in the system from which a user accesses our website. KARMA RESPONSE. S.L. (abbreviated KARMA) is able to modify its Cookie Policy in accordance with legislative requirements standards in order to better secure the data specified by the Spanish Agency.

2. Types of cookies

In general, cookies are used for identification (which could access in the information used for registration without having to introduce again); gathering statistical data on user usage; analyzing models of user behavior and aiding in the management of user visits, advancement, and participation in promotions.

On our website, we record and keep track of user registration throughout navigation, including IP address, navigation templates, and user activity. You can install the following Cookies whenever you visit our website: Session Cookie: are activities during the session. These cookies are deleted when the session expires or is terminated when the browser window is closed.

Persistent cookies: Maintain memory in computer even after browser is closed. Persistent cookies activate every time the user visits the website that generated them.

Proprietary Cookies: Even if users access data on their hard drives using the aforementioned cookies, the anonymous cookies we utilize nevertheless acquire personal information about them. User identity is not inserted directly in cookie and, therefore, it is impossible to identify.

Third-party cookies: Third-party cookies are not installed by KARMA but by its collaborators. Some of these cookies analyze your usage of our website to improve your navigational experience. To place online advertising in the most suitable locations, others might be installed by the advertising network with whom we partner. The following is a list of the third-party cookies we might use:

3. Deactivation of Cookie

You can deactive the cookies on your computer as follows:

4. Contacts

If you need more information on usage of cookies, you can contact us at the following email address: …, or by means of a letter addressed to Audience Serv…

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Terms and conditions

§1. Preamble

1. For contracts between the Karma Response and their customers, these terms and conditions apply exclusively. Terms and conditions of the customer are hereby contradicted. Karma Response shall not recognize any conflicting or deviating conditions of the customer, unless Karma Response has expressly agreed to them in writing.

2. These General Terms and Conditions apply to all contractual relationships, including all future contracts.

3. Karma Response is entitled to change these terms and conditions with effect for the future business relationship with the customer after notification. The change will be considered approved if the customer has not submitted a written objection to Karma Response within two weeks of notification of the change. Karma Response will point this out in the announcement.

4. Karma Response markets online advertising on websites on the Internet or via e-mail marketing through its network. Karma Response enables the entire process of planning, placing and monitoring online advertising on online advertising space.

§2 offer & contract

1. Offers by Karma Response are always non-binding and subject to change.

2. Orders of the customer are binding. Karma Response may accept this within two weeks of receipt, either in writing by an order confirmation, verbally or by commencement of performance.

3. Karma Response reserves the right to refuse orders without giving any reason or cancel current campaigns. In the case of a rejection of an order or the termination of a campaign, the customer has no claims for damages or any other claims against Karma Response.

4. Karma Response is entitled to make the delivery or delivery of advertising material dependent on an advance payment and, if applicable, the settlement of outstanding invoices.

5. Unless otherwise agreed, no cancellation is possible for already booked campaigns.

6. Karma Response receives a commission from the customer for its services. The commission may be based on the following remuneration models: a. Commission CPM: The customer pays Karma Response a pre-determined amount per insertion or per e-mail of a promotional item that belongs to the customer's campaign. In orders, the commission is stated in CPM (per 1,000 impressions).

b. Provision CPC: The customer pays Karma Response a pre-determined amount per click of a visitor to a promotional material of the campaign from the customer.

c. Commission CPL / CPA: The customer pays Karma Response a pre-determined amount per user action. Before concluding a contract with Karma Response, the customer determines what action a visitor must take to ensure that the lead can be accepted as valid. An action may be e.g. enrolling in the customer's newsletter, downloading software, completing and submitting a survey, or doing something completely different.

d. Commission CPO: The customer pays Karma Response a predetermined percentage of the revenue generated by Karma Response. This is always the case when a visitor recruited by Karma Response makes a purchase on the customer's website. The Karma Response commission is then calculated according to the specified percentage of the net order value of the recruited customer.

e. Commission Fixed Price: The customer pays Karma Response a pre-determined fixed price.

f. There are also combinations of commission models possible. A subsequent change in the commission amount is only possible by separate agreement between the customer and Karma Response in individual cases and requires the written consent of Karma Response.

G. Commission type, amount of commission (price) and other conditions are listed in the offer.

§3 Carrying out the campaign

1. Karma Response takes over the delivery and distribution of the advertising material for all campaigns alone and independently. Karma Response will deliver the advertising in its sole discretion or may discontinue advertising and campaigns if they fail to achieve the desired result.

§4 Lead and Sale campaigns

1. When placing lead and sale campaigns, it is necessary to include a specific tracking code in the customer's website. The tracking code must be installed in place of the website, from which the user action is deemed to have been carried out.

2. The tracking code will be sent to the customer via e-mail and must not be changed. Furthermore, it is not permitted to display the code only partially and in certain circumstances not to display it.

3. For the duration of the campaign and for 30 days beyond this, the customer must implement the named code properly in his website and not remove it before this deadline. This is necessary for the sake of proper billing.

4. Unless otherwise agreed in the offer, all leads or sales counted by Karma Response through the tracking code are considered valid and must be provisioned. If the offer has been agreed that the customer is entitled to validate the leads and sales, all invalid leads and sales must be canceled by the 5th of the following month at the latest. Cancellations can only be made on the basis of OrderIDs and only with a reason for cancellation. Karma Response must approve the conditions on when a lead or sales is canceled before the campaign begins. If the leads are not canceled after expiration of the deadline or if the reason for the cancellation is not comprehensible, the lead or sale is valid and must be provisioned.

5. In the event of culpable violation of the provisions of §4 by the customer, he shall forfeit a contractual penalty pursuant to §6 (6).

§5 Billing

1. Relevant for the billing of the advertising measures are the systems of Karma Response.

2. Karma Response is entitled to invoice its compensation immediately after the conclusion of the contract and to begin payment after receipt of the service.

3. Should Karma Response begin to perform without prior invoicing, Karma Response may at any time submit an invoice for all or part of the performance and, if applicable, for the part to be rendered.

4. Unless otherwise agreed in the offer, the payment deadline is net, net 14 days.

§6 Warranty and liability, contractual penalty

1. Karma Response will operate within the scope of its technical capabilities. An assurance of any kind cannot be given.

2. Karma Response is liable for damages by Karma Response or its legal representatives or vicarious agents against contractual agreements or stipulations in these Terms and Conditions only in cases of intent or gross negligence. This does not affect the liability of Karma Response for damages resulting from injury to life, limb or health.

3. The liability of Karma Response is in each case limited in amount to the amount that is measured for the period of the breach of contract according to the average monthly commissions of customers within the last 6 months, as far as the damage does not result from the breach of essential contractual obligations.

4. Karma Response assumes no liability for the websites marketed by Karma Response or the advertisements switched by Karma Response. For the contents of the web pages the operator of the respective website is alone responsible. For the contents of the advertisement the respective customer is exclusively responsible. The fact that the mediation, switching and billing by Karma Response does not give rise to any claims - even third parties - against Karma Response or legal liabilities of Karma Response towards third parties.

5. The customer indemnifies Karma Response from any claims of third parties arising from advertising through violations of copyright law, the law against unfair competition, the trademark law, other fair competition and property laws or other protective regulations and applicable law asserted to Karma Response. The customer will reimburse Karma Response for all damages and costs (including reasonable legal costs).

6. If the customer culpably violates §4 of these General Terms and Conditions, a contractual penalty in the amount of EUR 10,000, - per violation is agreed. The contractual penalty will not count towards any damage suffered by Karma Response as a result of the breach of contract.

§7 Final provisions

1. Verbal collateral agreements are not met. Changes, additions and additions are only valid if they are agreed in writing between the parties.

2. Should a provision of these Terms and Conditions be or become ineffective, this shall not affect the validity of the Terms and Conditions otherwise. The parties are obliged to replace the ineffective provision by an effective provision that comes closest to the economic purpose of the invalid provision. The same applies in the case of an oversight.

3. For all claims, the place of jurisdiction is London. English law applies.

This translation is only to facilitate the understanding of the document, but has no legal value in a strict sense.