PRIVACY POLICY - INVENTRIP APPLICATION

THIS IS AN AUTOMATED TRANSLATION - THE ORIGINAL IS IN SPANISH

In accordance with Regulation (EU) 2016/679, of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (General Data Protection Regulation – RGPD), Sismotur, S.L., informs the users of the INVENTRIP application (hereinafter, the Application), about the processing of personal data, which they have voluntarily provided during the registration process, access and use of the service.

1. IDENTIFICATION OF THE RESPONSIBLE FOR THE TREATMENT


Sismotur, S.L. CIF/NIF B82726415 with address at C/ Arturo Soria, 331, 3ºB, Madrid (Madrid), 28033 and communications email info@sismotur.com.

Registered in Registro Mercantil de Madrid, Volume 15681, Folio 90, Section 8, Sheet M-264134



2. PURPOSE OF DATA PROCESSING


To proceed with the registration, access and subsequent use of the Application, the User must provide - on a voluntary basis - personal data (essentially, identification and contact), which will be incorporated into automated media, owned by Sismotur, S.L.

The collection, storage, modification, structuring and, where appropriate, elimination, of the data provided by Users, will constitute processing operations carried out by the Controller, with the purpose of guaranteeing the correct functioning of the Application, maintaining the relationship of provision of services and/or commercial with the User, and for the management, administration, information, provision and improvement of the service.

The personal data provided by the User - especially the email or e-mail - may also be used to send newsletters, as well as commercial communications of promotions and/or advertising of the Application, as long as the User has provided prior express consent to receive these communications electronically.

Specifically, the Inventrip app requires access to the user location, in order to connect them to the tourist destinations geofences and connected signs.
The location will be performed in background mode, so it will be active even when the app is not in use. The purpose is to enable Geofences and Beacons: both will trigger notifications when the user enters tourist zones based on their location, even when the app is not in use. Geofences work based on your position, and Beacons on the proximity of the smartphone to a bluetooth emitter.

3. LEGITIMACIÓN


The processing of the User's data is carried out with the following legal bases that legitimize it:

In the event that the User does not provide Sismotur, S.L. your data, or do so in an erroneous or incomplete manner, it will not be possible to proceed with the use of the Application.



4. CONSERVATION OF PERSONAL DATA


The personal data provided by the User will be kept in the systems and databases of the Data Controller, as long as the User continues to use the Application, and as long as he or she does not request its deletion.

In order to clarify possible responsibilities arising from the processing, the data will be kept for a minimum period of five years.

No personal data will be kept related to geolocation.



5. RECIPIENTS


The data will not be communicated to any third party other than Sismotur, S.L., except under legal obligation or, in any case, upon request of the User's consent.

On the other hand, Sismotur, S.L. may give access or transmit the personal data provided by the User to third party service providers, with whom it has signed data processing commission agreements, and who only access said information to provide a service in favor of and on behalf of the Controller.



6. DATA RETENTION


Sismotur S.L. informs the User that, as a data hosting service provider and by virtue of the provisions of Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (LSSI), retains for a maximum period of 12 months the essential information to identify the origin of the hosted data and the moment in which the provision of the service began.

The retention of this data does not affect the secrecy of communications and may only be used in the framework of a criminal investigation or to safeguard public security, making it available to judges and/or courts or to the Ministry that requires it.

The communication of data to the State Security Forces and Corps will be done in accordance with the provisions of the regulations on the protection of personal data, and with the utmost respect for it.



7. PROTECTION OF HOSTED INFORMATION


The Data Controller adopts the necessary measures to guarantee the security, integrity and confidentiality of the data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, relating to the protection of natural persons with regard to trafficking