Implest Privacy Policy

Last updated: 16/06/2026

Version: Implest Privacy Policy v1.0

1. Introduction

KOMANECA, S.L. is committed to protecting the privacy and personal data of users, clients, partners, prospects, leads and other individuals who interact with Implest, access the website, complete forms, connect tools, contract services or participate in the Implest Partner Program.

This Privacy Policy explains how Implest collects, uses, stores, shares and protects personal data in connection with its website, services, commercial activity, partner program, onboarding processes, LinkedIn outreach operations, calendar connections, forms, payment processes and related digital services.

This Privacy Policy applies to the website https://implest.com/ and to the services, forms, communications, onboarding processes and digital tools operated by Implest.

This Privacy Policy does not apply to third-party websites, platforms or services that may be linked from Implest. Implest does not control such third-party websites and is not responsible for their privacy practices, content or policies.

2. Data controller

The data controller for the processing activities described in this Privacy Policy is:

KOMANECA, S.L.
Tax ID: B21790761
Registered address: Calle Balmes 191, 6º 1ª, 08006 Barcelona, Spain
Website: https://implest.com/
Privacy contact email: legal@implest.com

Hereinafter, “Implest”, “we”, “us” or “the Company”.

3. Applicable data protection laws

This Privacy Policy has been prepared in accordance with applicable Spanish and European data protection regulations, including:

Regulation (EU) 2016/679, General Data Protection Regulation (“GDPR”).
Spanish Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (“LOPDGDD”).
Spanish Law 34/2002 on Information Society Services and Electronic Commerce (“LSSI-CE”).
Any other applicable data protection, privacy, electronic communications or digital services regulations.

4. Categories of individuals whose data may be processed

Implest may process personal data relating to the following categories of individuals:

Website visitors.
Potential clients requesting information.
Clients who contract Implest services.
Representatives, employees or contacts of client companies.
Partners or potential partners participating in the Implest Partner Program.
Professional LinkedIn profiles contacted in commercial outreach campaigns.
Leads, prospects or business contacts generated through campaigns.
Users who complete forms, onboarding questionnaires or Tally forms.
Users who connect LinkedIn, Google Calendar, Microsoft Calendar or other tools.
Suppliers, collaborators, service providers or business contacts.

5. Categories of personal data processed

Depending on the relationship with Implest, we may process the following categories of personal data:

Identification data: name, surname, company name, job title, professional role.
Contact data: email address, phone number, LinkedIn profile URL, professional profile links.
Company data: company name, website, sector, country, city, business activity, target market.
Billing data: tax identification details, billing address, invoice information, payment status.
Partner data: application details, professional experience, LinkedIn profile, ability to issue invoices, fiscal information, commission-related data.
Client onboarding data: value proposition, ideal customer profile, target sectors, commercial goals, tone of voice, booking configuration and campaign preferences.
Campaign data: segmentation criteria, messages sent, replies received, conversation status, lead status, scoring, intent classification and activity logs.
Tool connection data: account identifiers, provider IDs, authorization status, calendar provider, connected email, technical tokens or integration metadata where applicable.
Payment data: payment confirmation, transaction status, subscription status and payment provider references. Implest does not store full card details.
Technical data: IP address, browser, device, cookies, logs, timestamps, event identifiers and system activity.
Communication data: emails, LinkedIn messages, support requests, form submissions and other communications with Implest.
Aggregated or anonymized data used for reporting, analytics or service improvement.

6. Sources of personal data

Personal data may be obtained from the following sources:

Data provided directly by users through the website, forms, onboarding questionnaires or emails.
Data provided by clients during contracting, onboarding or service configuration.
Data provided by partners during application, onboarding, acceptance of terms or participation in campaigns.
Data obtained from publicly available professional sources, including LinkedIn or company websites.
Data generated through Implest systems during campaign operation, reporting, scoring, logging or automation.
Data received from connected tools or third-party providers when authorized by the user or client.
Data received from payment providers, calendar providers, forms, CRM, email systems, hosting providers or other service providers.

7. Purposes of processing

Implest may process personal data for the following purposes:

To manage access to the website and respond to contact requests.
To provide information about Implest services.
To manage the contracting, onboarding and provision of Implest services.
To configure and operate B2B LinkedIn outreach campaigns.
To manage conversations, replies, classifications, lead status and commercial opportunities.
To generate reports, dashboards and operational metrics.
To manage the Implest Partner Program, partner applications, acceptance of terms, LinkedIn connections, commissions, invoices and payments.
To process payments, invoices, subscriptions, renewals, failed payments, refunds or billing incidents.
To connect and operate authorized integrations with LinkedIn, Google Calendar, Microsoft Calendar or other tools.
To schedule meetings, send booking links and create calendar events where applicable.
To provide technical support and respond to requests or incidents.
To comply with legal, tax, accounting, commercial and administrative obligations.
To prevent fraud, misuse, security incidents, duplications, technical errors or unauthorized access.
To improve the quality, security, performance and functionality of Implest systems.
To send commercial communications about Implest services when legally permitted.
To maintain internal records, evidence of acceptance, logs and audit trails.

8. Legal bases for processing

Implest processes personal data based on one or more of the following legal bases:

Performance of a contract: where processing is necessary to provide the contracted service, manage onboarding, billing, support, campaign operation or partner collaboration.
Pre-contractual measures: where processing is necessary to respond to requests, assess partner applications, prepare proposals or manage onboarding before contracting.
Consent: where users submit forms, authorize tool connections, accept cookies, subscribe to communications or provide explicit consent for specific processing.
Legal obligation: where processing is necessary to comply with tax, accounting, commercial, administrative, legal or regulatory obligations.
Legitimate interest: where processing is necessary for B2B commercial activity, service improvement, fraud prevention, security, internal management, reporting, partner management, client relationship management or direct marketing of Implest services, provided that such interests are not overridden by the rights and freedoms of the data subject.

9. B2B outreach and LinkedIn-related processing

Implest provides B2B managed outreach services that may involve processing professional data from LinkedIn profiles, company websites or other publicly available business sources.

This processing may include professional identification data, job title, company, LinkedIn profile URL, professional interests, business context, messages sent, replies received, conversation status and classification of commercial interest.

The purpose of this processing is to enable professional B2B communication, lead qualification, business development and the generation of commercial opportunities for Implest or its clients.

Where Implest acts on behalf of a client in relation to the client’s campaign data or leads, Implest may act as a data processor and the client may act as the data controller. Where Implest determines the purposes and means of processing for its own commercial activity, partner program, internal operations or service improvement, Implest acts as data controller.

Implest applies reasonable operational limits, controls and security measures when operating outreach campaigns. However, LinkedIn and other platforms are third-party services outside Implest’s control and may apply their own policies, limits, restrictions or technical decisions.

10. Artificial intelligence and automated processing

Implest may use artificial intelligence, automated rules, scoring systems, intent classification, prompts, response generation, workflow automation and other technical systems to support service delivery.

These systems may be used to classify replies, draft suggested responses, detect interest, determine next actions, generate summaries, support reporting and improve operational efficiency.

Implest does not intend to make solely automated decisions that produce legal effects or similarly significant effects on individuals without human intervention where such intervention is legally required.

Automated outputs may be reviewed, configured, limited or supervised according to the nature of the service and operational context.

11. Payment processing

Payments may be processed through Stripe or other equivalent payment providers.

Implest may receive information such as payment status, customer identifier, subscription status, billing email, invoice status, failed payment notices or transaction references.

Implest does not store full payment card details. Card processing and payment security are managed by the corresponding payment provider under its own terms and privacy policy.

12. Tool connections and integrations

Implest may allow clients, partners or authorized users to connect third-party tools such as LinkedIn, Google Calendar, Microsoft Calendar, email services, forms or other business tools.

When a user connects a tool, Implest may process technical identifiers, authorization status, provider account IDs, calendar email, meeting configuration, availability data, event metadata or other data necessary to provide the service.

The specific data processed will depend on the tool connected and the permissions granted by the user or client.

Users may request disconnection of tools where applicable. Disconnection may affect the availability or functionality of the service.

13. Forms and onboarding tools

Implest may use forms, including Tally or similar providers, to collect client onboarding information, partner applications, fiscal details, acceptance of terms, payment details, campaign preferences, consent records or support requests.

Data submitted through such forms will be processed for the purpose indicated in each form and in accordance with this Privacy Policy.

14. Data recipients and service providers

Implest may share personal data with third-party providers only where necessary for the purposes described in this Privacy Policy.

Such providers may include:

Hosting and infrastructure providers.
Database and backend providers.
Automation and workflow providers.
Artificial intelligence providers.
LinkedIn integration or account connection providers.
Payment providers such as Stripe.
Form providers such as Tally.
Email and communication providers.
Google Calendar, Microsoft Calendar or other calendar providers.
CRM, analytics, dashboard, monitoring or reporting providers.
Legal, accounting, tax, administrative or professional advisors.
Public authorities, courts or regulators where legally required.

Implest does not sell personal data to advertisers or third parties.

Where providers act as processors, Implest shall seek to ensure that appropriate contractual, technical and organizational safeguards are in place.

15. International data transfers

Some service providers used by Implest may be located outside the European Economic Area or may process data from countries that do not provide the same level of data protection as the European Union.

Where international transfers occur, Implest will seek to rely on appropriate safeguards under applicable data protection laws, such as adequacy decisions, Standard Contractual Clauses, contractual safeguards or other legally recognized mechanisms.

The use of certain providers may involve international data processing depending on their infrastructure, sub-processors and service configuration.

16. Data retention

Personal data will be retained only for as long as necessary for the purposes for which it was collected, and thereafter for the periods required to comply with legal, tax, accounting, contractual or liability obligations.

In general:

Website contact data will be retained while the request is being managed and, where applicable, for follow-up periods permitted by law.
Client data will be retained during the contractual relationship and for the period necessary to comply with legal and contractual obligations.
Billing and accounting data will be retained for the legally required retention periods.
Partner data will be retained during participation in the program and for the period necessary to manage commissions, tax obligations, legal claims and audit evidence.
Campaign and lead data will be retained for the time necessary to provide the service, generate reporting, avoid duplications, manage legal obligations and resolve incidents.
Technical logs may be retained for security, audit, troubleshooting and operational control purposes.
Consent and acceptance records may be retained as evidence for as long as necessary to demonstrate compliance.

When data is no longer necessary, Implest will delete, anonymize or block it in accordance with applicable law and operational requirements.

17. Data subject rights

Data subjects may exercise their rights under applicable data protection laws, including:

Right of access.
Right of rectification.
Right of erasure.
Right to restriction of processing.
Right to data portability.
Right to object to processing.
Right to withdraw consent where processing is based on consent.
Right not to be subject to solely automated decisions producing legal effects or similarly significant effects, where applicable.

To exercise these rights, data subjects may contact Implest at:

legal@implest.com

The request should include sufficient information to identify the data subject and specify the right being exercised.

Where legally required, Implest may request additional information to verify the identity of the requester.

18. Complaints before the supervisory authority

If a data subject considers that the processing of their personal data infringes applicable data protection regulations, they may lodge a complaint with the competent supervisory authority.

In Spain, the supervisory authority is the Spanish Data Protection Agency:

Agencia Española de Protección de Datos (AEPD)
Website: https://www.aepd.es/

19. Security measures

Implest applies reasonable technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, loss, misuse or destruction.

These measures may include access controls, authentication systems, role-based permissions, encrypted connections, logging, monitoring, backups, supplier controls, internal procedures and operational security measures.

However, no digital system is completely risk-free. Users and clients are responsible for maintaining the confidentiality of their credentials, accounts and connected tools.

20. Confidentiality

Implest will treat personal data and confidential information with due confidentiality and will only process or disclose it where necessary for the purposes described in this Privacy Policy, where authorized, where required by law or where necessary to protect legitimate rights and interests.

21. Cookies and similar technologies

The Implest website may use cookies or similar technologies for technical, analytical, personalization or marketing purposes.

Further information about the use of cookies is available in the Implest Cookie Policy.

22. Commercial communications

Implest may send commercial communications about its own services, updates or related business opportunities where legally permitted, based on consent, legitimate interest or an existing contractual relationship.

Recipients may opt out of commercial communications at any time by using the unsubscribe mechanism where available or by contacting Implest at legal@implest.com.

23. Minors

Implest services are intended for professional and B2B use and are not directed at minors.

Implest does not knowingly collect personal data from minors for the provision of its B2B services.

If Implest becomes aware that personal data of a minor has been collected improperly, it will take reasonable steps to delete or block such data where applicable.

24. Third-party links

The website or communications from Implest may include links to third-party websites, services or platforms.

Implest is not responsible for the content, security, privacy policies or data processing practices of such third-party websites or services.

25. Changes to this Privacy Policy

Implest may update this Privacy Policy from time to time to reflect legal, technical, operational or business changes.

Where changes are material, Implest may notify users, clients or partners through the website, email or other reasonable electronic means.

The version published on the website shall be the applicable version at any given time.

26. Language

This Privacy Policy is drafted in English.

In case of translation into other languages, the English version shall prevail, unless expressly agreed otherwise in writing.

27. Contact

For any privacy-related question, request or complaint, you may contact Implest at:

KOMANECA, S.L.
Calle Balmes 191, 6º 1ª, 08006 Barcelona, Spain
Email: legal@implest.com