Privacy Policy

1. IDENTIFICATION AND CONTACT INFORMATION

  • Data Controller: CLIQPOD S.L. (hereinafter, “CLIQPOD”)
  • Registered office: Carrer Aragó 383. Barcelona 08013. Spain
  • VAT Number: B67255703
  • DPO: @ com

2. INFORMATION

By accepting this Privacy Policy, the user (hereinafter, the "User") is informed that the personal data provided through any of CLIQPODS´s mobile applications (hereinafter, the "App"), as well as the data derived from his/her browsing in relation to his/her use of the present CLIQPOD website (hereinafter, the “Website”) and any other data that the User may provide in the future on the App or the Website, will be processed by CLIQPOD as the data controller for the purposes indicated in this Privacy Policy.

Users should carefully read this Privacy Policy, which has been drafted in a clear and simple manner.

3. OBLIGATION TO PROVIDE DATA

The data requested both in the App and the Website forms are, in general, mandatory in order to comply with the purposes for which they are being collected, unless otherwise specified in the required field.

Therefore, if the User does not provide them or does not provide them correctly, the User’s requests may not be attended.

4. ORIGIN OF THE DATA

The data processed by CLIQPOD for the purposes listed in the following section are obtained from the User, either directly or from his/her use of the App and the Website.

5. FOR WHAT PURPOSES WILL CLIQPOD PROCESS PERSONAL DATA?

CLIQPOD will process the User's personal data for the following specific purposes:

  • Management of the contractual relationship with the User: The provision of the services and functionalities offered by the relevant App to the User when playing a game or interacting with the App.
  • To answer the queries raised by the User through the contact or feedback channels provided: to manage, process and provide support for the requests, applications, incidents, complaints, or queries made by the User through the different communication channels made available in the App or the Website.
  • Preparation of reports, statistics, and internal analysis to improve the App and the Website: to analyze, manage and prepare internal reports and statistics on User behavior in order to implement improvements to both the App and the Website, using aggregated information.
  • Fraud prevention: Prevention and control of the use of both the Website and App for illegal or unauthorized purposes, with or without economic purpose.
  • Optimization of services and detection of errors and problems: to improve and optimize our services, as well as to detect Website or App errors and technical problems.
  • Personalization of advertisements shown in the App: This will be done based on your Google Advertising ID or Apple ID, according to our Cookies Policy.
  • To comply with legally established obligations: when the processing is necessary to comply with a legal obligation derived from regulations which may be applicable to CLIQPOD.

6. WHAT USER DATA WILL CLIQPOD PROCESS?

During the use of the App and the Website, the following personal data may be processed:

a) Management of the contractual relationship with the User:

  • Identifying data: name, surname.
  • Contact details: e-mail address.
  • Data obtained through User-generated content
  • Other data: cookies and similar identifiers.

b) To answer the queries raised by the User through the contact and feedback channels available:

  • Identification data: name, surname.
  • Contact details: e-mail address.
  • Other data: any data that may be provided by the User in relation to the relevant query, request or feedback.

c) Production of internal reports, statistics, and analysis to improve the Website and App:

  • Aggregated User Information.
  • Navigation data on the App: IP, behavior on the App and the Website and technical device information.
  • Other data: The Google Advertising ID is a unique, non-personalized, and non-permanent ID for advertising for a device using Android. Also, Apple ID information may be process for the referred purposes.

d) Fraud prevention:

  • Identification data: name, surname, selfie.
  • Contact details: e-mail.
  • Navigation data on the App and the Website: IP, behavior on the App and the Web.

e) Optimization of services and detection of errors and problems of the App and the Website:

  • Identification data: name, surname, first name.
  • Contact details: e-mail.
  • Navigation data on the App: IP, your behavior on the App and the Website.
  • Data obtained through User-generated content: comments and ratings.

f) Personalization of advertisements shown in the App and the Website:

  • Navigation data on the App and the Website: IP, your behavior on the App and the Website.
  • Other data: Google Advertising ID and the data collected through this ID, including the advertising content you have viewed and your interactions with this content.

g) To comply with legal obligations: any data processed by CLIQPOD that may be required for this purpose.

If the User provides data of third parties, he/she declares that he/she has their consent and/or sufficient legitimacy and undertakes to provide them with the information contained in the Privacy Policy, exempting CLIQPOD from any liability in this regard. However, CLIQPOD may carry out the appropriate verifications to check this, adopting the corresponding due diligence measures, in accordance with data protection regulations.

7. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF USER DATA BY CLIQPOD?

CLIQPOD processes the User's data in accordance with the following legal bases:

  • Management of the contractual relationship with the User: the processing of data derived from this purpose will be based on the fulfillment of the contractual relationship.
  • To provide answers to the issues raised by the User through the contact and feedback channels provided: the processing of data derived from this purpose is the legitimate interest of CLIQPOD of providing an adequate service to the User and answering any queries he or she may have.
  • Preparation of reports, statistics, and internal analyses to improve the App and the Website: all processing derived from this purpose will be based on the legitimate interest of analyzing the App and the Website and determining potential upgrades.
  • Fraud prevention: all processing derived from this purpose will be based on the legitimate interest of the data controller. This legitimate interest is based on ensuring that the services are not used for unlawful purposes and, in the event of unlawful use, to manage, process, and remedy the unlawful conduct carried out by the User.
  • Optimization of services and detection of errors and problems of the App and the Website: all processing derived from this purpose will be based on the legitimate interest of analyzing the App and the Website and determining potential upgrades.
  • Personalization of advertisements shown in the App and the Website: based on the User’s consent, gathered through the consent management platform implemented in the App and the Website, according to our Cookie Policy.
  • To comply with legally established obligations: All processing derived from this purpose will be based on compliance with a legal obligation.

8. RETENTION OF PERSONAL DATA

The User's personal data will be kept by CLIQPOD for the following periods:

  • Data provided for the management of the contractual relationship with the User: the data provided to manage, process, formalize and fulfill the contractual relationship will be kept while the User has the App installed or until he/she requests the erasure of his/her data, and, once the User deletes the App, for the period of limitation of the legal actions that may arise from it.
  • To provide answers to the queries raised by the User through the contact channels provided: the data will be kept for the period necessary to process and respond to your request and, once this period is over, for the period of limitation of the legal actions derived.
  • Preparation of reports, statistics, and internal analyses to improve the App's and the Website´s services: the information will be used in aggregated form for the preparation of reports, statistics, and analyses, during the period necessary to process and prepare the aforementioned reports, statistics and/or analyses, and, once this period has expired, during the period of limitation of the legal actions derived from the aforementioned request.
  • Fraud prevention: the data used for this purpose will be kept for the period necessary to detect any irregular activity and, in the event some illicit behavior is detected, for the period of limitation of the legal actions that may derive from them.
  • Data used for the optimization of the services and detection of errors and problems of the App and the Website: the data used for this purpose will be kept for the period necessary to process and develop the optimization and error detection work and, once this work has been carried out, for the period of limitation of any legal actions that may arise.
  • Personalization of advertisements shown in the App and the Website: personal data will be kept while the User has the App installed. The other data will be kept for the period necessary to provide personalized advertisements or as long as informed by the Cookie Policy.
  • To comply with the legally established obligations: the data provided to comply with the obligations arising from the services offered by CLIQPOD will be kept for the legally established periods.

9. RECIPIENTS OF PERSONAL DATA

Personal data provided by the User through the App may be communicated to:

  • Third parties to manage purchases made within the App, such as PayPal, Google Pay, Apple Pay or Freestar, based on the contractual relationship with the User.
  • Public Administrations, in the cases provided by law, based on compliance with a legal obligation.
  • Courts and tribunals, in the cases provided for by law, based on compliance with a legal obligation.

In addition, CLIQPOD will collaborate with third-party service providers who may have access to your personal data and will process User data on behalf of CLIQPOD in order to provide services.

Specifically, CLIQPOD will rely on the provision of services by third-party providers who carry out their activity, by way of example and without limitation, in the following sectors of activity: legal advice and technological and IT services.

When CLIQPOD carries out international data transfers, CLIQPOD will ensure that the importer of the data is located in a country that the European Commission considers as providing an adequate level of protection, or where that is not the case, CLIQPOD will adopt sufficient safeguards to make sure the personal data is protected (for example, by the signing of standard contractual clauses).

10. USER RESPONSIBILITY

The User guarantees that the data provided to CLIQPOD is true, accurate, complete, and up to date. To this effect, the User is responsible for the veracity of all the data provided and will keep the information provided suitably updated, so that it corresponds to their real situation, especially the information included by the data subject on the forms fulfilled.

Likewise, he/she guarantees that he/she has informed the third parties of whom he/she provides his/her data, if he/she does so, of the aspects contained in this document. Likewise, the user guarantees to have obtained their authorization to provide their data to CLIQPOD for the aforementioned purposes.

In any case, CLIQPOD is an intermediary, so the User shall be liable for any false or inaccurate information provided through the App and for any damages, direct or indirect, that this may cause to CLIQPOD or third parties, as well as for any possible civil or criminal liability that may arise from the activity of users on the App and the Website.

11. EXERCISE OF RIGHTS

The User may submit a request to CLIQPOD, to the e-mail or postal address indicated in the heading of this Privacy Policy at any time and free of charge, in order to exercise the following rights:

a) Right of access:

You have the right to be informed by CLIQPOD of whether it is processing your personal data and, if so, to have access to such data and to receive information on the purposes for which they are processed, the categories of data affected by the processing, the recipients to whom your personal data were communicated and the foreseen period for which the data will be kept, among other information.

b) Right of rectification and deletion:

You have the right to request the deletion of personal data provided that the legal requirements are met, and the rectification of inaccurate data concerning you when, among other reasons, such data are no longer necessary for the purposes for which they were collected.

c) Limitation of processing:

In certain circumstances (e.g., where the user disputes the accuracy of his or her data, while the accuracy of the data is being verified), he or she may request that the processing of his or her personal data be restricted and processed only for the purpose of pursuing or defending claims.

d) Consent withdrawal:

You also have the right to withdraw the consent at any time and free of charge, which will not impact the processing of your personal data carried out on the basis of your consent prior to the withdrawal.

e) Objection:

You have the right to object to the processing at any time, on grounds relating to your personal situation, where the processing is based on our legitimate interest or on the legitimate interest of a third party (including processing for the purpose of direct marketing and profiling). In this case, CLIQPOD will cease processing, unless legitimate reasons can be demonstrated.

f) Portability of your data:

You will have the right to receive the personal data that you have provided to CLIQPOD in a structured, common, and machine-readable format, and to be able to transmit it to another data controller without, in the cases legally provided.

g) Automated individual decisions:

Furthermore, in addition to the above-mentioned rights, in case of automated decisions, including profiling, you have the right to obtain human intervention by CLIQPOD and to express your point of view and challenge the decision.

h) Others:

Similarly, where personal data are transferred to a third country or to an international organization, you have the right to be informed about how you can access or obtain a copy of the appropriate safeguards relating to the transfer.

In addition, you may ask questions or raise concerns about the organization's privacy policy or information processing practices. Likewise, you may lodge a complaint regarding the protection of your personal data with the competent supervisory authority, if you consider that CLIQPOD has infringed the rights that are recognized by the applicable data protection regulations.

The competent data protection authority in Spain (AEPD) may be contact through the following link: https://www.aepd.es/ or in C/ Jorge Juan, n.º 6, CP: 28001, Madrid.

12. SECURITY MEASURES

CLIQPOD will process the User's data in a confidential manner and will, in accordance with the provisions of the applicable regulations, adopt appropriate technical and organizational measures to ensure the security of the data and prevent its alteration, loss, unauthorized access. The measures will be defined taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk for the rights and freedoms of natural persons.

13. ACCESS TO YOUR INFORMATION AND YOUR CHOICES

You may access your information to update or correct it by sending an email to @ com. We may send you important communications regarding the Services, and you will not be able to opt out of those communications.

14. CHANGES

CLIQPOD reserves the right to revise its Privacy Policy from time to time. For this reason, we ask the User to regularly check this privacy statement for the most recent version of CLIQPOD´s Privacy Policy. If we make any material changes to this Privacy Policy, we’ll notify you of these changes, for example by posting them on the App or providing email or other notice, and we’ll update the “Last Updated” date at the bottom of the Privacy Policy to indicate when those changes will become effective.

15. ACCEPTANCE AND CONSENT

The User declares to have been informed of the conditions on personal data protection, accepting the content of this Privacy Policy.

Last updated: May 2024