1. Identity of the Data Controller
In compliance with Regulation (EU) 2016/679 (General Data Protection Regulation - RGPD), Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) and other applicable regulations, the user is informed of the following data:
Responsible for the treatment
TOURINY S.L.
CIF: _______________________ (Pending)
Registered office
Can Barrera Street 119 A
07141 Marratxi
Balearic Islands (Spain)
customerservice@touriny.com
Phone
+34 686 274 795
2. Purpose of this Policy
This Privacy Policy explains how TOURINY S.L. collects, uses, stores and protects the personal data of users who use:
- the Touriny mobile application;
- the website www.touriny.com;
- any service related to Touriny.
Our objective is to guarantee maximum transparency regarding the processing of personal information.
3. What data we collect
Depending on the user's use of the application, we may process the following categories of data.
3.1 Identification data
- Name.
- Surnames (when provided by the access provider).
- Email address.
- Unique user identifier.
- Profile photograph (when the user accesses through Google or Facebook and authorizes its transfer).
3.2 Authentication data
When the user logs in using:
- email and password
authentication is done using Firebase Authentication.
Touriny does not store passwords on its own servers.
Credentials are managed through the secure infrastructure provided by Firebase.
3.3 Location data
For the application to function correctly, it is necessary to access the device's location.
The location is used exclusively for:
- show the user's position;
- calculate the tourist route;
- guide the user between different points of interest;
- determine when the user has arrived at each stop on the tour.
Location is not used for commercial profiling, selling information, or advertising tracking.
The location will only be used while the user uses the functions that require it.
3.4 Technical data
May be collected automatically:
- device model;
- operating system;
- app version;
- language;
- time zone;
- technical identifiers;
- IP address;
- operating incidents;
- error logs (logs).
These data allow us to improve the stability and security of the service.
3.5 Usage data
We may know information related to the use of the application, such as:
- visited destinations;
- tours started;
- tours completed;
- usage time;
- functions used;
- visited screens;
- interaction with the application.
This data is used solely for statistical and service improvement purposes.
3.6 Data related to the Pro version
When the user acquires Touriny Pro, we may store information related to:
- subscription or license status;
- purchase date;
- transaction identifier;
- platform used (Google Play or Apple App Store).
Touriny does not store complete bank card data or financial information.
Payments are managed entirely by Google Play or Apple App Store.
4. Data we DO NOT collect
Touriny does not knowingly request or process:
- biometric data;
- medical data;
- complete bank details;
- information about ideology;
- religion;
- sexual orientation;
- union membership;
- criminal data.
5. Purpose of the treatment
Personal data will be used to:
- create user account;
- allow login;
- offer tourist tours;
- show maps and routes;
- guide using geolocation;
- improve user experience;
- maintain the security of the platform;
- detect fraud;
- resolve technical incidents;
- provide support;
- manage the purchase of Touriny Pro;
- comply with legal obligations.
6. Legal basis of processing
The processing of personal data is based on:
Contract execution
When the user uses Touriny.
Consent
For:
- location sharing;
- accept cookies where applicable;
- receive commercial communications, if the user requests them.
Legitimate interest
For:
- improve the application;
- prevent fraud;
- ensure security;
- perform anonymous statistics.
Compliance with legal obligations
When it is necessary to retain certain information due to legal requirements.
7. Third party services
To correctly provide our services we use different technology providers.
Firebase
We use Firebase to:
- authentication;
- data storage;
- application infrastructure.
Firebase belongs to Google LLC.
Google Maps Platform
We use Google Maps to:
- show maps;
- calculate routes;
- guide the user.
Google AdMob
The free version of Touriny displays advertising through Google AdMob.
Specifically, the user must view advertisements to access certain free tours in accordance with the operation described in the conditions of use.
Google may process certain data in accordance with its own Privacy Policy.
Matomo Analytics
We use Matomo to obtain usage statistics.
Our goal is to know:
- errors;
- performance;
- most used functionalities;
- aggregated user behavior.
Whenever possible, analyzes will be carried out minimizing the personal information processed.
Google Tag Manager
Google Tag Manager is used only to manage technical labels related to the measurement and operation of the service.
Facebook Login
When the user accesses through Facebook, we will only receive the information expressly authorized by the user themselves.
Google Sign-In
When the user uses Google to log in, we will only receive the data authorized by said provider and by the user.
8. Data retention
Personal data will be kept for as long as:
- there is an active account;
- it is necessary to provide the service;
- there is a legal obligation.
When the user deletes their account, the data will be deleted or anonymized except for those whose retention is required by law.
9. Data recipients
The data may be communicated only when necessary to:
- technology providers;
- public authorities;
- judicial bodies;
- security forces and bodies, when there is a legal obligation.
Touriny does not sell personal data.
Touriny does not rent personal data.
Touriny does not trade with user information.
10. International transfers
Some technology providers used by Touriny may process information outside the European Economic Area.
When this occurs, said transfers will be made using the guarantees provided for in the General Data Protection Regulation, such as:
- adequacy decisions of the European Commission;
- standard contractual clauses;
- other legally recognized mechanisms.
11. User rights
The user may exercise the following rights at any time:
- Access.
- Rectification.
- Deletion.
- Opposition.
- Limitation of treatment.
- Portability.
- Withdrawal of consent.
To do this, simply send a request to:
customerservice@touriny.com
The request must allow the applicant to be reasonably identified.
12. Account deletion
The user can delete their account directly from the Touriny application, accessing the Profile > Delete account section.
Deleting the account will begin the process of deleting the personal data associated with it, except for those whose conservation is necessary to:
- comply with legal obligations;
- meet the requirements of competent authorities;
- prevent fraud or illicit uses;
- resolve pending claims;
- exercise or defend legal rights of TOURINY S.L.
Deleting the account will entail, among other consequences:
- cancellation of access to the application through said account;
- the deletion or anonymization of personal data that does not need to be legally retained;
- the loss of information associated with the account, except that which must be maintained by legal obligation.
The deletion of the account carried out at the user's initiative will not give the right to a refund, in whole or in part, of the amount paid for the Touriny Pro license, when it has been activated and used, as it is digital content whose provision begins immediately after purchase.
The user acknowledges that the voluntary deletion of their account constitutes a personal decision and that such action does not affect the validity of the previously made purchase nor does it generate the right to any financial compensation, without prejudice to the non-waivable rights that may correspond to them in accordance with applicable legislation.
In the event that the user deletes his or her account and subsequently creates a new one, restoration of the Touriny Pro license will only be possible when the distribution platform (Google Play or Apple App Store) allows it and the purchase can be correctly associated with the same user account or the same purchase identifier, in accordance with the policies of said platforms.
13. Security
TOURINY S.L. applies technical and organizational measures aimed at protecting personal information against:
- loss;
- unauthorized access;
- destruction;
- alteration;
- improper disclosure.
However, no system connected to the Internet can guarantee absolute security.
14. Protection of minors
The application is not intended for children under 14 years of age.
Minors who must have authorization from their legal representatives in accordance with applicable regulations must not use the application without said authorization.
If Touriny becomes aware that personal data of a minor has been collected without the necessary authorization, it will proceed to adopt the appropriate measures to eliminate it.
15. Automated decisions
Touriny does not adopt automated decisions that produce legal effects on users nor does it create profiles intended for automated individual decision-making.
16. Changes to this Policy
TOURINY S.L. may modify this Privacy Policy to adapt it to legal, technical or functional changes.
When changes are relevant, users will be informed by appropriate means before they come into force, provided that it is enforceable in accordance with applicable regulations.
17. Control Authority
If the user considers that the processing of their personal data violates the applicable regulations, they may file a claim with the competent data protection authority, without prejudice to any other administrative or judicial remedy that may apply.
