This Privacy Policy explains how ValenciaLink ("we", "us", "our") collects, uses, stores and protects personal data when you use our mobile application (the "App") and related services. We are committed to protecting your privacy in compliance with the General Data Protection Regulation (GDPR) — Regulation (EU) 2016/679 and the Spanish Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD).
1. Data Controller
The data controller is ValenciaLink, based in Valencia, Spain. For data protection inquiries, please contact us via the Contacts page or by email at [email protected].
2. What Personal Data We Collect
We may collect and process the following categories of personal data through the App:
- Identity data: name, surname, username.
- Contact data: email address.
- Technical data: device type, operating system version, app version, unique device identifiers, time zone setting.
- Usage data: screens viewed, features used, interaction patterns within the App.
- Location data: approximate geolocation derived from IP address or, with your explicit consent, precise location from your device to provide location-based features (e.g. nearby places, map functionality).
- Account data: login credentials, preferences, saved places, subscription status.
- Purchase data: subscription type and status (we do not have access to your full payment details; all payments are processed securely by Apple).
We do not intentionally collect special categories of personal data (health, ethnicity, political opinions, etc.).
3. How We Collect Data
- Directly from you: when you create an account, set preferences, submit content or contact us.
- Automatically: through the App’s functionality when you use features, navigate screens, or interact with content.
- From Apple: subscription and purchase status information provided through Apple’s in-app purchase system.
4. Legal Bases for Processing (GDPR Art. 6)
We process your data based on one or more of the following legal bases:
- Consent (Art. 6(1)(a)): for precise geolocation, push notifications and optional analytics.
- Contractual necessity (Art. 6(1)(b)): to provide the App’s functionality, manage your account and process subscriptions.
- Legitimate interest (Art. 6(1)(f)): to improve the App, ensure security and prevent fraud.
- Legal obligation (Art. 6(1)(c)): where required by Spanish or EU law.
5. Purposes of Processing
- Providing and personalising the App (curated recommendations, saved preferences, location-based features).
- Managing your account and subscription status.
- Sending push notifications (only with your consent).
- Analysing usage patterns to improve content, design and functionality of the App.
- Ensuring the security and integrity of the App.
- Complying with legal and regulatory obligations.
6. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:
- Account data: for the duration of the account and up to 12 months after deletion request.
- Usage data: typically anonymised or aggregated within 26 months.
- Legal and financial records: as required by law (up to 6 years under Spanish commercial law).
7. Data Sharing and Third-Party Processors
We may share your data with the following categories of recipients, all under appropriate data processing agreements:
- Hosting and infrastructure providers: for server infrastructure and content delivery.
- Analytics providers: anonymised usage data to help us improve the App.
- Apple: as part of the in-app purchase and subscription system.
- Push notification services: to deliver notifications you have opted into.
- Legal and regulatory authorities: when required by law.
We do not sell your personal data to third parties.
8. International Data Transfers
Some of our service providers may process data outside the European Economic Area (EEA). In such cases, we ensure adequate protection through:
- Standard Contractual Clauses (SCCs) approved by the European Commission.
- Adequacy decisions by the European Commission.
- Other lawful transfer mechanisms recognised under GDPR.
9. Your Rights Under GDPR
You have the following rights regarding your personal data:
- Right of access (Art. 15): obtain confirmation of whether we process your data and receive a copy.
- Right to rectification (Art. 16): correct inaccurate or incomplete data.
- Right to erasure (Art. 17): request deletion of your data ("right to be forgotten"), subject to legal retention requirements.
- Right to restriction (Art. 18): restrict processing in certain circumstances.
- Right to data portability (Art. 20): receive your data in a structured, machine-readable format.
- Right to object (Art. 21): object to processing based on legitimate interests.
- Right to withdraw consent (Art. 7(3)): withdraw consent at any time without affecting the lawfulness of prior processing.
- Right to lodge a complaint: file a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es or with your local supervisory authority.
To exercise any of these rights, contact us via the Contacts page. We will respond within 30 days.
10. Data Security
We implement appropriate technical and organisational measures to protect your personal data, including:
- HTTPS encryption for all data in transit.
- Access controls and authentication for internal systems.
- Regular security assessments and vulnerability monitoring.
- Data minimisation — we collect only what is necessary.
11. Children’s Privacy
The App is not directed to children under 16 years of age. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected such data, contact us and we will delete it promptly.
12. Changes to This Policy
We may update this Privacy Policy from time to time. The updated version will be posted on this page with the revised "Last updated" date. We encourage you to review this page periodically.
13. Contact
For any questions, concerns or requests regarding this Privacy Policy or your personal data, please contact us via the Contacts page or by email at [email protected].
You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos — AEPD) at www.aepd.es.