PhotoPills App Privacy Policy

1. Identification of the controller

PHOTOPILLS, S.L. is responsible for the processing of your personal data in order to provide you with the services identified in this Privacy Policy (“App”).

PHOTOPILLS, S.L., is a company located at Calle Ses Gerreries, 25, 07760, Ciutadella de Menorca, Spain and its NIF number is B57788705 (“PhotoPills”).

At PhotoPills we are committed to the fundamental right to the protection of your personal data and this privacy policy aims to inform you of your rights under the General Data Protection Regulations ("GDPR").

2. Essential points of our policy

In this privacy policy we explain each of the services offered by PhotoPills that require the processing of your personal data.

Therefore, you will be informed of:

  1. The purposes of processing your personal data or what PhotoPills is processing your personal data for.
  2. The legal basis justifying such processing for each purpose.
  3. If there is any communication of your data to third parties or an international transfer of them. In this regard, we inform you that we do not transfer your data to third parties unless there is a legal obligation (arising from a request from the Spanish State Security Forces or Spanish Courts) or unless it is essential to provide a service, in which case, we will inform you.
  4. The period of time your data is kept which is necessary to maintain the relationship or to provide you with the service or function you have requested. Therefore, if we do not need your data to provide you with any service, they will be blocked and will only be accessible by the Spanish Public Authorities in the event of legal, administrative or tax claims, in accordance with the time limits established by each regulation. After the blocking period, the data will be completely deleted.

3. What information will we collect from you?

You should know that there are different ways to collect personal data:

a) The data you provide us with directly.

We collect information about you when you open and use the App.

All the data the App obtains from the use you give it, as well as the data we ask you to upload your photos to the App, are necessary to provide you with our services, so not providing any of them could make it impossible for you to receive the requested services. You must provide true information, impersonation or the use of aliases or anonymous names is prohibited.

You may not, when providing any data that may be requested when using the App, choose expressions that are offensive, coincide with brands, commercial names, names or pseudonyms of public figures or celebrities for whose use you are not authorized.

It is essential that you keep your reference data, passwords and access codes generated at all times. You will be solely responsible for the use of your personal account, and in this respect you undertake to make diligent use of this information, not to make it available to third parties, and to inform us, without delay, of its loss or theft.

So that the information provided is always up to date and does not contain errors, you must inform PhotoPills, as soon as possible, of any changes to your personal data that occur via the following email support[at]photopills[dot]com.

b) The data obtained indirectly.

You should know that the services contained in the App, always under the USER's acceptance, allow us to monitor and analyze the web traffic and can be used to know more about your behavior when using the App. To do this we use Firebase Analytics, a statistical service provided by Google LLC, which will collect data on how many times you open the App and how you use it.

Firebase Analytics can share data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. All these tools are identifiers for mobile devices or tablets similar to cookies, and are necessary for Firebase Analytics to work properly, thanks to which we can provide a better service for you to take your pictures in the best locations and in the way that best suits your use of the App.

To learn more about how Google LLC uses data, please see the Firebase Terms of Service.

4. What is the origin of your data?

We consider that all the data processed by PhotoPills has been freely provided to us.

In case the personal data provided is from a third party, you guarantee that you have informed them of this App Privacy Policy and obtained their authorization to provide the data to PhotoPills for the purposes indicated above. Likewise, you guarantee that the information provided is accurate and updated, and you are responsible for any direct or indirect damage or harm that may be caused as a result of failure to comply with this obligation.

5. How will we use your personal information? What services do we provide to you?

PhotoPills acts as controller of personal data for the following purposes: 

  1. Manage and maintain the contractual relationship.
  2. Manage the contests organized by PhotoPills.
  3. Manage your data in case you have accessed through social networks.
  4. Statistical purposes for monitoring and analyzing web traffic.

6. What is the legal basis for the processing of your data? 

PhotoPills will treat your personal data in accordance with the following legal bases, depending on the type of data that is provided, as well as the interactions that you, as a user, have with PhotoPills:

  1. The processing of your data for the purposes related to the management and maintenance of the contractual relationship, to the management of the tenders organized by PhotoPills, and to the management of your data provided through social networks is based on the maintenance of the legal relationship established between both parties and, where appropriate, on the legitimate interest of PhotoPills.
  2. The processing of your data for the purposes related to the monitoring of the use you give to the App is based on the legitimate interest of PhotoPills to provide its services and manage the operation of the App in an optimal way. 

7. Data assignment and international transfers 

As long as you have accepted the use of statistics collection through Firebase Analytics, we at PhotoPills communicate your personal data to third parties for the processing of the same for the purposes described, in order to provide you with the services offered by our App. For this same purpose, your data will be transferred to the United States of America, where Google LLC has its servers, under the protection of the EU-US Privacy Shield.

Beyond this communication, we do not transfer your personal data to third parties for processing, unless there is a legal obligation to do so, in which case they may be communicated to public administrations and the administration of justice.

In the event of other transfers or communications of data, they will always be made on a legal basis that legitimises such processing, and we will inform you of this in advance. 

8. Exercising your rights

We inform you that you can exercise the following rights:

  1. Right of access to your personal data in order to know which ones are being processed and the processing operations carried out on them.
  2. Right to rectify any inaccurate personal data. 
  3. Right to have your personal data deleted, where this is possible.
  4. Right to request limitation of the processing of your personal data when the accuracy, legality or necessity of the processing is in doubt, in which case we may keep the data for the exercise or defence of claims.
  5. Right to object to automated decision making, including profiling.
  6. Right to oppose the processing of your personal data when the legal basis for their processing, according to paragraph 4 above, is the legitimate interest.
  7. Right to the portability of your data, when the legal basis that enables us to process them as indicated in paragraph 4 above is the existence of a contractual relationship or your consent.
  8. Right to revoke consent given to PhotoPills.

You can exercise your rights at any time and free of charge in the following ways:

  1. By sending an email to the following address support[at]photopills[dot]com indicating the right you wish to exercise and your identification data.
  2. By sending a written request to the address Calle Ses Gerreries, 25, 07760, Ciutadella de Menorca, Spain, indicating the right you wish to exercise and your personal details.
  3. In addition, when you receive any communication from us, by clicking on the unsubscribe section that will contain that communication, you will be able to unsubscribe from all previously accepted commercial communications. 

We also inform you that you have the right to file a complaint with the Spanish Data Protection Agency if you consider that we have committed a breach of data protection legislation with regard to the processing of your personal data.

9. Withholding periods

We will only keep your data for as long as it is necessary to offer you these services. Any of the data that you provide us with through the channels will be blocked as long as they are no longer necessary to manage the service and will only be available in the event of a legal obligation (derived from a request from the Spanish State Security Forces or Spanish Courts) as well as when you exercise your rights through the following email address support[at]photopills[dot]com.

10. Security and confidentiality

We are committed to the security of your information. In order to prevent unauthorized access or disclosure of personal information, we have put in place appropriate technical and physical measures and management processes to safeguard and secure the information we collect from you.

11. Minors

Minors under 14 years of age may not use the services available through the App without the prior authorization of their parents, guardians or legal representatives, who shall be solely responsible for all acts performed through the App by the minors in their care, including the completion of the personal data of said minors and the ticking, if applicable, of the boxes accompanying them. In this sense, and to the extent that PhotoPills has no capacity to control whether users are minors or not, parents and guardians must be the ones who enable the necessary mechanisms to prevent minors from accessing the App and/or providing personal data without their supervision, and PhotoPills does not accept any responsibility in this regard. 

12. Privacy Policy update 

We make our best efforts to keep our Privacy Policy fully updated on a regular basis. If we make changes, they will be clearly and specifically identifiable, as permitted in the relationship we have established with you (e.g., we may communicate changes to you by email).

 

This privacy policy has been revised and published as of March 26, 2020.