Privacy Policy

 

Privacy Policy

Last update: May 17, 2024

 

This privacy policy describes our policies and procedures regarding the collection, use and disclosure of your information when you use the Service and informs you of your privacy rights and how the law protects you.

We use your personal information to provide and improve the Service. By using the Service, you consent to the collection and use of information in accordance with this privacy policy.

We handle your personal information only when it is essential to provide you with our online services and content effectively. We only use your personal data if you have given us permission in advance. However, there are situations in which we cannot ask for your consent first due to special circumstances, but we are still permitted by law to process your data.

Interpretation and definitions

Interpretación

Words whose initial letter is capitalized have defined meanings under the following conditions. The following definitions will have the same meaning regardless of whether they appear in the singular or plural.

For the purposes of this privacy policy:

Definiciones

Account means a unique account created for you to access our Service or portions of our Service.

Affiliate means an entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for the election of directors or other management authority.

Application refers to Zyrcled, the software program provided by the Company.

Business, for the purpose of the GDPR, refers to the Company as the legal entity that collects personal information from Consumers and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and which alone, or jointly with others, determines the purposes and means of the processing of Consumers’ personal information, which does business in Europe.

Company (referred to as “the Company”, “We”, “Us”, “We” or “Our” in this Agreement) refers to: Zyrcled Social Group SL

1. Name and contact details of the data controller, as well as the company’s data protection officer

1.1 Responsable

Zyrcled Social Group S.L.

VAT NUMBER: B10751543

Tax Address: Calle Ameria 19-B, 08620, Sant Vicenç dels Horts, Barcelona

E-mail: contacto@zyrcled.com

For the purpose of the GDPR, the Company is the Data Controller.

Country refers to: Spain

Data controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

Device means any device that can access the Service, such as a computer, cell phone or digital tablet.

GDPR refers to the EU General Data Protection Regulation.

Personal data is any information that relates to an identified or identifiable person.

For the purposes of the GDPR, Personal Data means any information relating to you, such as a name, an identification number, location data, online identifier or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. location, online identifier or one or more factors specific to physical, physiological, genetic, mental, economic, cultural or social identity.

Services refers to the application, the Web and other services that we may offer under the Zyrcled brand.

Service Provider means any natural or legal person who processes data on behalf of the Company. It refers to third party companies or individuals engaged by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered data processors.

Usage data refers to data collected automatically, generated by the use of the Service or from the infrastructure of the Service itself (for example, the duration of a page visit).

You refer to the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual accesses or uses the Service, as applicable. Under the GDPR, you may be referred to as the Data Subject or as the User, as you are the individual using the Service.

Collection and use of your personal data

Types of data collected

Datos personales

We focus on improving your user experience and related technical and content development, ensuring that our features and algorithms meet the core principles of our community and what you expect from us. We also take IT security very seriously to protect you.

We will delete any personal data that is no longer necessary for the purposes for which it was collected, provided that we do not have a legal obligation to retain it. For tools provided by third parties, if a data deletion deadline is not specified, you should consult the privacy policy of that tool on the third party’s website for more information.

While using Our Service, We may ask you to provide Us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

  • Dirección de correo electrónico
  • First and last name
  • Telephone number
  • Address, State/Province, Postal Code, City, Country
  • Date of birth
  • Gender Identity
  • Sexual preference
  • Photos
  • Location
  • Gmail or Apple ID login information
  • Usage Data

    • Usage data

    Usage Data is automatically collected when you use the Service.

    Usage Data may include information such as your Device’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

    When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, the unique ID of your mobile device, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

    We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

    Information collected while using the application

    While using our application, to provide features of our application, we may collect, with your prior permission:

    • Location information

    • Information from your Device’s address book

    • Images and information from your Device’s camera and photo library

    • We use this information to provide features of our service, to improve and personalize our service. The information may be uploaded to company servers and/or a service provider’s server or may simply be stored on your device.

    • In our app, we use several methods to identify devices. This allows us to offer you certain functionalities, evaluate and fix bugs, and provide you with personalized content and information. Device IDs help us associate payment services with the correct devices and send you push notifications as part of what our app has to offer you.

    • To identify devices, we use the “Ad-ID” on iOS devices and the “Google Advertising ID” on Android devices. We want to assure you that we do not use these IDs for advertising purposes.

    You can enable or disable access to this information at any time through your device settings.

    Use of your personal data

    The Company may use personal data for the following purposes:

    • To provide and maintain our Service, including to monitor the use of our Service.

    • To manage your account: to manage your registration as a user of the Service. The personal data you provide may give you access to different functionalities of the Service that are available to you as a registered user.

    • For the performance of a contract: the development, fulfillment and performance of the contract for the purchase of the products, goods or services you have purchased or any other contract with Us through the Service.

    • To contact you: To contact you by email, phone calls, SMS or other equivalent forms of electronic communication, such as push notifications from a mobile application regarding updates or informational communications related to contracted features, products or services, including security updates, when necessary or reasonable for implementation.

    • To provide you with news, special offers and general information about other goods, services and events we offer that are similar to those you have already purchased or inquired about, unless you have opted out of receiving such information.

    • To manage your requests: To attend and manage your requests to Us.

    • For Business Transfers: We may use your information to evaluate or effect a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, in which personal data we hold about our Service users is among the assets transferred.

    • For Other Purposes: We may use your information for other purposes, such as analyzing data, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Service, products, services, marketing and your experience.

    We may share your personal information in the following situations:

    • With Service Providers: We may share your personal information with service providers to monitor and analyze the use of our Service, to show you advertisements to help maintain and support Our Service, for payment processing, to contact you.

    • For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing or acquisition of all or a portion of Our business to another company.

    • With Affiliates: We may share your information with Our affiliates, in which case We will require those affiliates to comply with this privacy policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

    • With business partners: We may share your information with Our business partners to offer you certain products, services or promotions.

    • With other users: when you share personal information or interact in groups with other users of the app, such information can be seen by all users in the same group and especially by those who are similar to your preferences.

    • With your consent: We may disclose your personal information for any other purpose, provided that your consent will be required.

    Protection and no sale of personal data

    With all of the above regarding the use of your data, we want to make it clear that,

    At Zyrcled Social Group S.L., we are committed to protecting your privacy and maintaining the security of your personal data. In accordance with the General Data Protection Regulation (GDPR) of the European Union, we want to make it clear that we do not sell, rent, trade or otherwise transfer your personal data directly to third parties for marketing or advertising purposes.

    However, as part of our business model to provide you with a free service, we display advertisements on our application. Some of these ads may be customized based on information you have provided to us, such as your likes, preferences and activity within the app. This customization is done through the use of advertising technologies provided by third parties, such as ad management platforms.

    It is important to note that, in this process, we do not directly share your personal information with these third parties. Instead, we use non-personal unique identifiers that allow these systems to display relevant advertisements without accessing your personally identifiable information. These third parties are contractually obligated to use the information provided only for the purposes specified and in accordance with our instructions.

    We reserve the right to disclose your personal information when required by law or when we believe it is necessary to protect our rights, property or safety, or those of our users or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction purposes.

    By using our application, you consent to the processing of your information as described in this privacy policy. If you have any questions about our data protection practices or wish to exercise your rights under the GDPR, please contact us using the information provided in the “Contact” section.

    Links to other sites

    Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly encourage you to review the privacy policy of each site you visit.

    We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party sites or services.

    Children’s privacy

    Our Service is not directed to anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from minors, we take steps to delete that information from our servers.

    Retention of your personal data

    The Company will retain your personal data only for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

    The Company will also retain Usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen security or to improve the functionality of Our Service, or We are legally required to retain this data for longer periods of time.

    Transfer of your personal data

    Your information, including personal data, is processed at the Company’s operational offices and at any other place where the parties involved in the processing are located. This means that this information may be transferred to – and maintained on – servers located outside of your state, province, country or other governmental jurisdiction but within the territorial scope of the European Union and in compliance with the GDPR.

    Your consent to this privacy policy followed by your submission of such information represents your agreement to that transfer.

    The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with thisprivacy policy. No transfer of your personal data to an organization or country will be made unless there is a compelling or legal justification for overriding reasons, including the security of your data and other personal information.

    Rights over your data.

    Delete your personal data

    You have the right to delete or request that we assist in deleting personal data we have collected about you.

    Our Service may give you the ability to delete certain information about you from within the Service.

    You may update, amend or delete your information at any time by logging into your Account, if you have one, and visiting the account settings section that allows you to manage your personal information. You may also contact us to request access, correction or deletion of any personal information you have provided to us.

    Profile information

    We recommend caution when disclosing personal information. We discourage the publication of email accounts, URLs, chat data, phone numbers, full names with addresses, bank card details, national identity cards, driving licenses and any personal information in the profile, as this could be open to possible abuse or misuse.

    By sharing information in your profile or while using the chat, you are responsible for the information you share.

    Geolocation information

    If you give us your consent, we may collect your exact geolocation (latitude and longitude) from your device. The collection of your geolocation may occur in the background when you are not using the services, as long as the permission you expressly granted us allows it. The use of the exact location in the foreground (only if the app is used) is solely for the purpose of being able to find profiles and/or be found by other people nearby. It is important to note that if you choose not to allow us to collect your precise geolocation, we will not do so, and some of our services that rely on precise geolocation may not be available to you.

    Zyrculos” Groups

    Similarly, we are in a position to document your interaction with the groups accessible on Zyrcled by collecting relevant information and other data associated with these groups. As an integral part of our data management practices, we reserve the right to disclose statistics derived from such data. This action provides us with a global perspective of how users interact with the various groups available on Zyrcled.

    Special group orgies

    In this group, due to its complexity and particularities when organizing a meeting between users of the application, it is possible that an exceptional level of information about the organizer of the event may be required, beyond the data already registered. This may include a request for verification of the DNI (National Identity Document) of the individual initiating the meeting, as well as any other data that may be necessary, always with the objective of guaranteeing the security, integrity and reliability of the event for all its attendees.

    Age of majority to be a user of the app and of the zyrculos

    Zyrcled is strongly committed to protecting legitimate users and minors through a robust identity verification and age of majority validation process. We urge all of our users to easily and freely authenticate their accounts to affirm their identity and age.

    During the identity validation process, we will evaluate the accuracy of the user information provided in your profile via video, focusing on your gender and age specifically. We reserve the right to request an official identification document if there are suspicions about the veracity of your information. The data is retained only as long as necessary for the purpose of this regulation.

    For verification, we require a video of you alone, speaking your full name, using the verify profile option. You must follow the prompts. Once the verification process is complete, all videos provided will be permanently deleted. Only Zyrcled staff in charge of validation will have access to them during this process. We do not share your information with third parties.

    The verification of identity and age is voluntary. Therefore, the processing of this data is based on your explicit consent to the process of confirmation of the age of majority.

    But remember that in case of doubt about the age of majority of a user and his refusal to verify, it may result in temporary blocking or deletion of the profile.

    Surveys and other contributions

    From time to time, we may conduct surveys for research purposes and we may contact you to determine whether you wish to participate. It is important to note that participation in these marketing surveys is completely optional.

    Please note, however, that we may need to withhold certain information when we have a legal obligation or a legal basis to do so.

    Disclosure of your personal data

    Commercial transactions

    If the Company is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different privacy policy.

    Compliance with the law

    Under certain circumstances, the Company may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

    Other legal requirements

    The Company may disclose your personal data in the good faith belief that such action is necessary to:

    • Fulfilling a legal obligation

    • Protect and defend the rights or property of the Company.

    • Prevent or investigate possible irregularities in connection with the Service.

    • Protect the personal safety of users of the Service or the public

    • Protect users against negligence, misuse or criminal activity by other users.

    • Protecting against legal liability

    Security of your personal data

    The security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

    Detailed information on the processing of your personal data

    The service providers we use may have access to your personal data. These third party service providers collect, store, use, process and transfer information about your activity only for our Service and in accordance with their privacy policies.

    Analytics

    We may use third party service providers to monitor and analyze the use of our Service.

    Google Analytics

    Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

    You can opt out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in its Privacy Policy: https://policies.google.com/privacy.

    For more information about Google’s privacy practices, please visit Google’s Privacy and Terms webpage: https://policies.google.com/privacy.

    Firebase

    Firebase is an analytics service provided by Google Inc.

    You may opt out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in its Privacy Policy: https://policies.google.com/privacy.

    We also encourage you to review Google’s policy for the protection of your data: https://support.google.com/analytics/answer/6004245.

    For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners’ sites or applications web page: https://policies.google.com/technologies/partner-sites.

    Advertising

    We may use Service Providers to display advertisements to you to help maintain and support Our Service.

    Google AdSense and DoubleClick Cookie

    Google, as a third party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other sites on the Internet.

    You can opt out of the DoubleClick cookie for interest-based advertising by visiting the Google ad settings page: http://www.google.com/ads/preferences/.

    E-mail marketing

    We may use your personal data to contact you with newsletters, marketing or promotional material and other information that may be of interest to you. You may opt out of receiving any, or all, of these messages from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

    We may use email marketing service providers to manage and send emails to you.

    Mailchimp

    Mailchimp is an email marketing delivery service provided by The Rocket Science Group LLC.

    For more information about Mailchimp’s privacy practices, please visit their privacy policy: https://mailchimp.com/legal/privacy/.

    Payments

    We may provide paid products and/or services within the Service. In that case, we may use third party services for payment processing (e.g., payment processors).

    We will not store or collect your payment card details. That information is provided directly to our third party payment processors whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS managed by the PCI Security Standards Council, which is a joint effort of brands such as Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

    To facilitate a variety of payment options and ensure secure transactions, we share certain payment information with our payment provider, (RevenueCat). When you choose a payment method during the checkout process, the necessary data is automatically sent to our payment provider. By selecting a payment option, you agree to the transfer of your personal data necessary to process the payment.

    Personal data that may be shared with the supplier includes your first name, last name, address, date of birth, gender, email address, IP address, phone number and other data relevant to the payment. Purchase-specific details such as bank information, card numbers, validity dates, CVC codes, and details about the goods or services purchased may also be shared.

    The main purposes of this exchange of information are to verify your identity, administer payments and prevent fraud, based on the fulfillment of contractual commitments according to art. 6, paragraph 1, section 1, letter b) of the GDPR. In addition, if deemed necessary and if there is a legitimate interest, your personal data may be shared by the controller with the payment provider, who in turn may share it with credit bureaus to verify your creditworthiness and identity according to art. 6, paragraph 1, section 1, letter f) of the GDPR.

    The payment provider may also share your data with services or subcontractors necessary to fulfill contractual obligations. Remember that you have the right to revoke your consent to the processing of your personal data at any time to the payment provider, although this will not affect the information necessary for the management of payments related to contracts.

    Apple Store In-App Payments

    Its Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/.

    Google Play In-App Payments

    Its privacy policy can be viewed at https://www.google.com/policies/privacy/.

    Stripe

    Its privacy policy can be viewed at https://stripe.com/us/privacy.

    PayPal

    Its privacy policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full.

    Usage, performance and miscellaneous

    We may use third party Service providers to maintain and improve our Service.

    reCAPTCHA Invisible

    We use an invisible captcha service called reCAPTCHA. reCAPTCHA is operated by Google.

    The reCAPTCHA service may collect information from you and your device for security purposes.

    The information collected by reCAPTCHA is maintained in accordance with Google’s Privacy Policy: https://www.google.com/intl/en/policies/privacy/.

    GDPR Privacy

    Legal basis for processing personal data under the GDPR

    We may process personal data under the following conditions:

    • Consent: You have given your consent to the processing of personal data for one or more specific purposes.

    • Execution of a contract: The provision of personal data is necessary for the execution of an agreement with you and/or for any pre-contractual obligation thereof.

    • Legal obligations: The processing of personal data is necessary for compliance with a legal obligation to which the Company is subject.

    • Vital interests: The processing of personal data is necessary to protect your vital interests or those of another natural person.

    • Public interests: The processing of personal data is related to a task that is carried out in the public interest or in the exercise of official authority granted to the Company.

    Legitimate interests: The processing of personal data is necessary for the purposes of the legitimate interests pursued by the Company.

    In any case, the Company will be happy to assist in clarifying the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a necessary requirement to enter into a contract.

    Your rights under the GDPR

    The Company undertakes to respect the confidentiality of your personal data and to ensure that you can exercise your rights.

    You have the right under this Privacy Policy, and by law if you are within the EU, to:

    • Request access to your personal data. The right to access, update or delete information we have about you. Where possible, you can access, update or request deletion of your personal data directly within the settings section of your account. If you are unable to perform these actions yourself, please contact us for assistance. This also allows you to receive a copy of the personal data we hold about you.

    • Request correction of personal information we have about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.

    • Object to the processing of your personal data. This right exists where we are relying on a legitimate interest as the lawful basis for our processing and there is something in your particular situation which makes you want to object to our processing of your personal data on this basis. You also have the right to object where we are processing your personal data for direct marketing purposes.

    • Request deletion of your personal data. You have the right to ask us to erase or delete personal data when there is no good reason for us to continue to process it.

    • Request the transfer of your personal data. We will provide you, or a third party you have chosen, with your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially gave your consent for us to use or where we use the information to perform a contract with you.

    • Withdraw your consent. You have the right to withdraw your consent to the use of your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific features of the Service.

    Exercising your GDPR data protection rights

    You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will do our best to respond to you as soon as possible.

    You have the right to complain to a data protection authority, such as the Spanish Data Protection Agency (AEPD) about our collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

    Modifications to the privacy policy

    We reserve the right to update or modify this privacy policy at any time. Any significant changes to this policy will be notified through appropriate means of communication, such as a notice on our website or an email notification, prior to the changes taking effect.

    The date of the last modification will be indicated at the top of this privacy policy. We encourage you to check this page periodically for updates.

    Your continued use of our services following the posting of the modifications constitutes your acceptance of the changes made. If you do not agree to the modified terms of the privacy policy, we ask that you discontinue using our services and, if necessary, contact us to resolve any concerns.

    How to contact us:

    E-mail: contacto@zyrcled.com

    Web Contact: https://zyrcled.com/contacto

    Postal: Calle Almeria 19-B, 08620, Sant Vicenç dels Horts, Barcelona