PRIVACY POLICY FOR MOBILE APPLICATIONS (APPS)

Date of last update: 04/04 /2024

In accordance with Regulation (EU) 2016/679, of the European Parliament and of the Council, of April 27, 2016, on the protection of individuals with regard to the processing of personal data and the free movement of these data (General Data Protection Regulation - RGPD), PAFOBA, S.L. informs those registered in the application GADDEX (henceforth, the Application or GADDEX), regarding the processing of personal data, which they have voluntarily provided during the registration process, access and use of the service.

1. IDENTIFICATION OF THE PERSON RESPONSIBLE FOR THE TREATMENT.

PAFOBA, S.L., with CIF B01701341, address Paseo Bonanova 30, 08022, Barcelona and contact email hola@gaddexapp.com, is the entity responsible for the processing of the data provided by the customers of the Application (hereinafter, the Registrant (s)). You will be responsible for the processing of the data that is necessary to carry out the administrative, fiscal and accounting procedures necessary for the company under current legislation and the management and improvement of the application, as well as if consent is available to send commercial communications.

In relation to Registrant data (Administrators, Managers and Users) contained within the Application, it will be Data Processor because it provides the management service of the company's personnel management platform and allows them to have a space to create events, talk through an individual or group chat, purchase activities, manage teams and have a bulletin board. Between both parties, there is a data processor contract regulated in the terms and conditions.

2. PURPOSE OF DATA PROCESSING.

2.1 The data to proceed with the registration, access and subsequent use of the Application

El Registered you must provide, on a voluntary basis, personal data:

  • Administrators
    - basic data (name and surname, company name, address, DNI/NIF, telephone number, email)
    - financial data (bank card number)
  • Managers and users
    - basic data (name and surname, date of birth, office, email)
    - financial data (bank card number)

If you decide to register with your Google or Microsoft account, your data can be retrieved from the indicated provider. By clicking on “Sign in with (...)”, you accept that the latter provide us with the necessary data to register.

2.2 Purposes and data processing

All personal data will be incorporated into automated media owned by PAFOBA, S.L. with appropriate technical and organizational measures to ensure an optimal level of security. The collection, storage, modification, structuring and, where appropriate, elimination, of the data provided by Registrants will constitute processing operations carried out by the Data Controller, with the purpose of:

  • ensure the proper functioning of the Application,
  • maintain the service provision relationship with the Registrant
  • for the management, administration, information, provision and improvement of the service
  • If the Registrant has consented to this, the personal data provided by the Registrant - especially the email - may also be used to send newsletters (newsletter), as well as commercial communications of promotions and/or advertising of the Application.
  • If the Registrant has so requested, the personal data provided by the Registrant may be used to respond to queries raised through the contact form.
  • If the Registrant has so requested, the personal data provided by the Registrant may be used to chat.
  • If the Registrant has so requested, the personal data provided by the Registrant may be used to make a purchase.

2.3 Information about access to device resources or functions

To access certain features of the Application, you may be asked for your permission to place the partner's image on your profile. If you want to upload a photo, the Application will ask for your permission to access the camera and its image gallery.

You can always revoke your permission from your device settings.

3. LEGITIMATION.

The processing of Registrant data is carried out based on the free, specific, informed and unambiguous consent of the Registrant, made available to them through this privacy policy, which they must accept through clear affirmative action, by checking the corresponding box. If the Registrant does not provide GADDEX with their data, or does so incorrectly or incompletely, it will not be possible to proceed with the use of the Application. This legal basis justifies the processing of data. Prior to the request for information and/or the contracting of the Application services, the terms and conditions that govern this Application will be made available to the registrant.

4. CONSERVATION OF PERSONAL DATA.

The personal data provided by the Registrant will be kept in the systems and databases of the Data Controller, as long as the Data Controller continues to use the Application, and provided that they do not request its deletion. In order to clarify the possible responsibilities derived from the treatment, the data will be kept for a minimum period of five years.

5. RECIPIENTS.

The data will not be communicated to any third party outside GADDEX, except for legal obligation or, in any case, upon the request of the Registrant's consent. On the other hand, GADDEX may grant access or transmit the personal data provided by the Registrant to third party service providers, with whom it has signed data processing order agreements, and who only access such information to provide a service for and on behalf of the Data Controller. If you give your consent to the sending of commercial communications, these will be made through TWILIO Inc., located in the USA and which has binding corporate regulations.

6. DATA RETENTION.

GADDEX informs the Registrant that, as a data hosting service provider and in accordance with the provisions of Law 34/2002 of July 11 on Information Society and Electronic Commerce Services (LSSI), it retains for a maximum period of 12 months the information essential to identify the origin of the hosted data and the time when the provision of the service began. The retention of these data does not affect the secrecy of communications and may only be used in the framework of a criminal investigation or for the safeguarding of public safety, making them available to judges and/or courts or to the Ministry that so requires. The communication of data to the State Security Forces and Bodies 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. INFORMATION PROTECTION.

The Data Controller adopts the necessary measures to guarantee the security, integrity and confidentiality of data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, on the protection of individuals with regard to the processing of personal data and the free movement of such data. Although the Responsible Party makes backup copies of the content hosted on its servers, however, it is not responsible for the loss or accidental deletion of data by Registrants. In the same way, it does not guarantee the total replacement of the data deleted by Registrants, since the said data could have been deleted and/or modified during the period of time that has elapsed since the last backup copy. The services provided or provided through the Application, except for services specific to Backup, do not include the replacement of the contents kept in the backup copies made by the Data Controller, when this loss is attributable to the Registrant; in this case, a fee will be determined according to the complexity and volume of the recovery, always with prior acceptance by the Registrant. The replacement of deleted data is only included in the price of the service when the loss of the content is due to causes attributable to the Responsible Party.

8. RIGHTS OF THOSE REGISTERED.

GADDEX informs the Registrant that they have at their disposal the rights of access, rectification, limitation, deletion, opposition and portability, which they can exercise by sending a request to the email address: hola@gaddexapp.com. In addition, the Registrant has the right to revoke the consent initially provided, and to file claims for rights with the Spanish Data Protection Agency (www.aepd.es).

9. COMMERCIAL COMMUNICATIONS BY ELECTRONIC MEANS.

In application of the LSSI (Information Society Services Act), GADDEX will not send advertising or promotional communications by email or other equivalent electronic means of communication that have not previously been requested or expressly authorized by the recipients of the same. In the case of Registrants with whom there is a previous contractual, legal or service relationship, the Data Controller is authorized to send commercial communications regarding products or services of the Data Controller that are similar to those that were initially contracted with the customer. If the Registrant wishes to unsubscribe when receiving the above-mentioned communications, they can do so by sending their will by e-mail to the following e-mail address: hola@gaddexapp.com.