Privacy Policy

1. Introduction

This Privacy Policy describes how RECICLAN APP, S.L. processes the personal data collected through the ReciClan mobile application. Hereinafter, the APP may be referred to as the "Platform".

Use of the ReciClan application's services is subject to the Terms and Conditions of Use. By using these services, the User understands, acknowledges and accepts this Privacy Policy and the Terms and Conditions of Use.

We recommend reading the Privacy Policy and the Terms and Conditions of Use carefully; for any query or clarification you may contact RECICLAN APP, S.L. by email at info@reciclan.org or by post at Avinguda d'en Piera 132, 08107 Martorelles (Barcelona), Spain.

This Privacy Policy applies to access to and use of ReciClan and/or any function, content, tools and services accessible in connection with the application.

2. Data controller and developer information

In accordance with Article 10 of Spanish Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI-CE), RECICLAN APP, S.L. provides the following details:

Company name	RECICLAN APP, S.L.
Tax ID (NIF)	B75469858
Address	Avinguda d'en Piera 132, 08107 Martorelles (Barcelona), Spain
Email	info@reciclan.org
Website	https://www.reciclan.org, directly linked to the App
Business activity	Reciclan is a platform focused on environmental education and awareness in the field of recycling and waste management. Its activity centres on promoting sustainable habits and improving citizen participation in the correct separation of waste. It also promotes the circular economy and the improvement of the urban environment through innovative solutions.
Geographical area of operation	RECICLAN APP, S.L. operates within the European territory.

Name of the App

ReciClan (hereinafter, the App).

Category of ReciClan

The ReciClan App may be considered a digital platform of an educational and environmental awareness nature, aimed at promoting sustainable habits in recycling and waste management through the interaction and active participation of users.

Target audience

ReciClan is aimed at the following audiences: the general public, public administrations, local entities and organisations interested in promoting sustainability and correct waste management.

Languages of ReciClan

ReciClan is available in the following languages:

Spanish
Catalan

3. Data collected by the application

RECICLAN APP, S.L. informs users of the profiles enabled in the APP, the information required for each profile and any special category information, should it be required.

User profile	General information	Special category information
Councils, public entities	Company name, tax ID, address, telephone, geolocation, email	Not collected
Users, family clan	Name and surname, national ID (DNI/NIE), address, geolocation, age, email	Not collected

In addition to the data provided at registration, the application may access certain technical information about the device and features such as geolocation, the camera or the photo gallery, always with the User's consent, as detailed in section 8. Security and device features. The application does not include payment features, so no data relating to means of payment is requested or processed.

4. Data protection policy

Under the ePrivacy Directive (Directive 2002/58/EC, as amended by Directive 2009/136/EC), "the terminal equipment of users of electronic communications networks and any information stored on such equipment are part of the private sphere of the users requiring protection under the European Convention for the Protection of Human Rights and Fundamental Freedoms".

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and Spanish Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights, ReciClan informs the User that the information collected through the application and the websites will be incorporated into the processing systems for which RECICLAN APP, S.L. is responsible, for the purposes of managing and maintaining the relationship with the User, as well as for information, statistical and marketing tasks relating to the services and related activities.

Legal bases for processing

RECICLAN APP, S.L. informs that the legal bases legitimising the processing of personal data are, in general, the performance of the legal and/or contractual relationship established with the user, as well as the free, specific, informed and unambiguous consent given by the user, in accordance with Article 6.1 of Regulation (EU) 2016/679.

Retention period

RECICLAN APP, S.L. informs that personal data will be kept for as long as necessary to fulfil the purpose for which it was collected, while the legal and/or contractual relationship is maintained and/or the consent given is not withdrawn. Thereafter, the data may be kept duly blocked for the periods established by law in view of any liabilities arising from the processing.

5. Rights of data subjects

RECICLAN APP, S.L. informs Users that they may exercise their rights of access, rectification, restriction, erasure, portability and objection to the processing of their personal data before the Data Controller, as well as withdraw the consent given.

Right of access: the user's right to obtain information about their specific personal data and the processing carried out or being carried out, as well as the available information on the origin of that data and the disclosures made or planned.
Right to rectification: the data subject's right to have inaccurate or incomplete data corrected. This can only be satisfied in relation to information under the control of the APP, for example, deleting comments posted on the page itself, images or web content containing the user's personal data.
Right to restriction of processing: the right to have the purposes of processing originally envisaged by the controller restricted.
Right to erasure: the right to have the user's personal data deleted, except as provided in the GDPR itself or in other applicable regulations that require the data to be retained, in due time and form.
Right to data portability: the right to receive the personal data the user has provided in a structured, commonly used and machine-readable format, and to transmit it to another controller.
Right to object: the user's right to have the processing of their personal data not carried out or to have the APP cease processing it.

How to exercise your rights

To exercise any of the rights described above, the following requirements must be met:

Submission of a written request to Avinguda d'en Piera 132, 08107 Martorelles (Barcelona), Spain (for the attention of RECICLAN APP, S.L.) or by email to info@reciclan.org.
The request sent by the data subject must meet the following legal requirements: the applicant must reliably prove their identity and, where there is doubt about the applicant's identity, they will be asked to complete the request (e.g. by providing further information such as their ID number, a copy of their ID document, the email address they provided, etc.).
The request may be made by a legal or voluntary representative, provided they are duly identified and authorised by the data subject (by means of an express authorisation from the data subject to exercise the personal rights regulated by data protection legislation).
A request specifying what is being asked for (the right being exercised or the information to be accessed). If no specific file is referred to, all information held with the applicant's personal data will be provided. If information about a specific file is requested, only the information in that file will be provided. Information relating to a third party can never be provided. If the request is made by telephone, the applicant will be asked to submit it in writing and informed of how to do so and the address to which it must be sent. Information will never be given by telephone.
Address for notification purposes.
Date and signature of the applicant.
Documents supporting the request.
The data subject must use any means that provides proof of sending and receipt of the request.

Finally, please note that you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) if you become aware of or consider that an event may constitute a breach of the applicable data protection regulations.

Security measures and Data Protection Officer

RECICLAN APP, S.L. undertakes to adopt the necessary technical and organisational measures, in line with the level of risk involved in the processing carried out, so as to guarantee its integrity, confidentiality and availability.

If you would like further information about the procedures and protocols adopted by RECICLAN APP, S.L., you may contact the Data Protection Officer in writing at info@reciclan.org.

6. Accuracy and currency of data

ReciClan informs users that the Platform may contain links to other websites not belonging to ReciClan, and that it is therefore not responsible for the processing of personal data that the User provides on those websites. We therefore recommend that you review the privacy policies of those sites.

ReciClan also informs that if the User enters data in forms on third-party websites, those third parties will be responsible for the personal data and must adopt the corresponding technical measures.

7. Processing we carry out

Processing of personal data carried out by ReciClan:

Management of APP users: users

Purpose: Managing registration, access to and use of the mobile application, including user registration and the administration of the available features.
Retention period: Data will be kept for as long as the relationship with the user is maintained and its erasure is not requested. Thereafter, it will be kept duly blocked for the periods established by law to deal with any liabilities.
Legal basis: Art. 6.1(b) GDPR: processing is necessary for the performance of the contractual relationship to which the data subject is party. Subsidiarily, Art. 6.1(f) GDPR: the controller's legitimate interest in ensuring the correct operation and security of the application.
Disclosures: No disclosure of data to third parties is planned, except where required by law or where necessary to provide the service (data processors duly engaged in accordance with Article 28 GDPR).
International transfers: No international data transfers are planned. Should any take place, compliance with Articles 44 et seq. of the GDPR will be guaranteed.
Type of data: Identification data only

Management of APP users: Public Administration clients

Purpose: Managing access to, use and administration of the platform by users linked to the Public Administration client, including credential management, support and maintenance of the service.
Retention period: Data will be kept for as long as the contractual relationship with the client entity is maintained and the user remains authorised. Once the relationship ends, the data will be kept duly blocked for the periods established by law to deal with any liabilities.
Legal basis: Article 6.1(b) GDPR: processing is necessary for the performance of the contract signed with the client entity or for the application of pre-contractual measures.
Disclosures: No disclosure of data to third parties is planned, except where required by law or where necessary to provide the service (data processors duly engaged in accordance with Article 28 GDPR).
International transfers: No international data transfers are planned. Should any take place, compliance with Articles 44 et seq. of the GDPR will be guaranteed.
Type of data: Identification data only

Regulatory compliance management

Purpose: Managing, controlling and processing the legal and regulatory obligations to which the entity is subject, including responding to requests from competent authorities and keeping mandatory records.
Retention period: Data will be kept for as long as necessary to comply with the applicable legal obligations. Thereafter, it will be kept duly blocked until any liabilities arising from the processing are time-barred.
Legal basis: Article 6.1(c) GDPR: processing is necessary for compliance with a legal obligation to which the controller is subject.
Disclosures: Data may be disclosed to Public Administrations, regulatory bodies and competent authorities where necessary to comply with the applicable legal obligations. The legal basis for such disclosures is compliance with a legal obligation under Article 6.1(c) GDPR.
International transfers: No international data transfers are planned. Should any take place, compliance with Articles 44 et seq. of the GDPR will be guaranteed.
Type of data: Identification data only

Marketing actions

Purpose: Collecting, recording and processing personal data for the purpose of sending commercial, promotional or advertising communications, by electronic and/or traditional means, relating to the entity's products, services or activities.
Retention period: Data will be kept for as long as the data subject's consent is maintained and its erasure or objection is not requested.
Legal basis: Article 6.1(a) GDPR: the data subject has given consent to the processing of their personal data for one or more specific purposes.
Disclosures: Personal data may be disclosed to third parties where necessary to comply with legal obligations or to provide the service correctly, including, where applicable, suppliers acting as data processors with whom the corresponding contracts have been signed in accordance with Article 28 GDPR. It may also be disclosed to Public Administrations, Courts and Tribunals or other competent bodies where required by applicable regulations.
International transfers: No international data transfers are planned. Should any take place, compliance with Articles 44 et seq. of the GDPR will be guaranteed.
Type of data: Identification data only

Management of contests and promotions

Purpose: Collecting, recording and processing personal data for the purpose of managing participation in contests, prize draws, prizes and/or promotional actions organised by the entity.
Retention period: Data will be kept for as long as necessary to manage the activity and comply with the legal obligations arising from it. Thereafter, it will be kept duly blocked for the limitation periods of any liabilities.
Legal basis: Article 6.1(a) GDPR: the data subject has given consent to the processing of their personal data for one or more specific purposes.
Disclosures: Data may be disclosed, where necessary, to partner or sponsoring entities of the contests, prize draws or promotions, exclusively for their management. The legal basis for such disclosures will be the data subject's consent or compliance with legal obligations, as applicable.
International transfers: No international data transfers are planned. Should any take place, compliance with Articles 44 et seq. of the GDPR will be guaranteed.
Type of data: Identification data only

8. Security and device features

RECICLAN APP, S.L. undertakes to comply with the Terms and Conditions of Use and the Privacy Policy in relation to the APP and the Services, in accordance with the following sections:

a) Geolocation

RECICLAN APP, S.L. informs that the application may require access to the geolocation of the User's device, using the operating system's own location services. Accessing and processing such data is considered processing of personal data insofar as it allows the User to be identified or made identifiable.

Prior to installation, as well as during use of the application, the User will be informed of the use of this feature and must expressly, specifically and knowingly give or refuse their consent.

The User may withdraw, at any time and in a simple and effective way, the consent given for the processing of their location data through the device's permission settings, which will prevent the application from accessing that information.

Likewise, uninstalling the application will end RECICLAN APP, S.L.'s access to and processing of geolocation data.

The application will only access geolocation data while the User is using it, and no continuous processing of such data will take place. Should continuous or background processing be necessary, the User will be informed beforehand and their express consent will be obtained separately.

For more information on how to enable or disable this feature, the User can consult the settings options of their device on the iOS and Android operating systems. Disabling this feature may limit certain features of the application.

b) Device permissions

Most mobile platforms (iOS, Android, among others) establish control mechanisms that limit applications' access to certain device features and data without the user's prior consent. These authorisation systems allow the user to manage in a granular way the permissions granted to each application.

In this regard, the iOS operating system will request authorisation the first time the application needs to access certain data or features, allowing the user to accept or refuse such access. Android devices, for their part, will inform of the permissions required by the application before use, requesting the user's authorisation to activate them.

RECICLAN APP, S.L. may use certain device features (such as storage, camera, location or others), which may involve access to personal data. In any event, the application will inform the user beforehand, clearly and fully, about the use of such features, requesting the user's express consent where necessary, in accordance with Article 6.1(a) of Regulation (EU) 2016/679.

The user may, at any time, configure, limit or revoke the permissions granted through their device's settings, without affecting the lawfulness of processing based on prior consent. However, refusing or withdrawing certain permissions may affect the correct provision or functionality of the application.

For the correct installation and use of ReciClan by user-type and public administration users, as well as by family-type users (including administrators and members of family clans), access to and use of the following features and applications available on the User's device may be necessary:

Device permission	Users and public administrations	Family users (family clans)
Contacts	No	Yes
Photo gallery	Yes	Yes
Documents	Yes	No
Email	No	No
Calendar	Yes	No
Geolocation	Yes	Yes
Microphone	No	No
Camera	Yes	Yes
Other	No	No

Such access will take place in accordance with the operating system's authorisation mechanisms, informing the User beforehand and requesting, where appropriate, their express consent when necessary, in accordance with current data protection regulations.

Refusal or limitation of these permissions by the User may affect the correct operation or availability of certain features of the application.

RECICLAN APP, S.L. informs the user that if the APP is not granted access to the various applications on their mobile device, the APP may not work fully and some sections may not be enabled for the User.

c) Permitted uses and restrictions

Users who reside or are domiciled in countries other than Spain, whether inside or outside the European Union, must ensure that their access to and use of the Application and/or its content complies with the regulations applicable to them in their jurisdiction.

In any event, access to and use of the Application by users who do not meet the requirement of residence in Spain is deemed to be at their sole responsibility, releasing RECICLAN APP, S.L. from any liability arising from non-compliance with the regulations applicable in those territories.

d) Minors

In accordance with current data protection regulations and, in particular, the principle of the best interests of the child, RECICLAN APP, S.L. guarantees special protection of the privacy of minors.

The application allows an administrator user to create "family clans" and invite other members of the family unit, including minors, to join. In these cases, where the processing of personal data concerns minors, the prior consent of the holders of parental authority or guardianship is required, in accordance with Article 8 of Regulation (EU) 2016/679 and Article 7 of Spanish Organic Law 3/2018.

The administrator user of the "family clan" declares and warrants that they have the necessary authorisation to add minors, assuming responsibility for the truthfulness of that statement and for supervising the minors' use of the application.

RECICLAN APP, S.L. will adopt appropriate technical and organisational measures to guarantee a level of security appropriate to the risk in the processing of minors' data, limiting its use to the intended purposes and applying the principles of data minimisation and data protection by design and by default.

e) Push notifications

RECICLAN APP, S.L. informs that the application may send push notifications to the User's device for the purpose of facilitating the correct operation of the application, improving the user experience and communicating relevant information relating to the services offered, in accordance with this Privacy Policy and the Terms and Conditions of Use.

The sending of push notifications may be based on the User's consent, which may be given or refused through the mechanisms provided by the device's operating system (iOS, Android or others) at the time of installation or use of the application.

In any event, the User may configure, limit or revoke the receipt of push notifications at any time through their device's settings, without affecting the lawfulness of prior processing based on their consent.

The User is informed that disabling push notifications may affect the correct operation of certain features of the application or limit its functionality.

f) Device information

For the correct operation of ReciClan, the application may access and process, where applicable, the following information from the User's device, always in accordance with the principles of data minimisation and purpose limitation (Art. 5 GDPR) and, where necessary, after obtaining consent in accordance with Article 6.1(a) GDPR:

Device attributes: technical information about the device, such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, and information about installed applications, files and plug-ins, where necessary to guarantee compatibility and the correct operation of the application.
Identifiers: unique identifiers of the device and the application (for example, device ID, application or account identifiers), used for service management, user authentication and application security.
Device signals: information relating to Bluetooth signals, Wi-Fi networks, beacons or nearby mobile phone masts, insofar as necessary for specific features of the application (for example, approximate location or interaction with the surroundings).
Device settings data: information derived from the permissions granted by the User on their device, such as access to geolocation (GPS), camera, photo gallery or other features necessary to provide the service.
Network and connections: information about the device's connectivity, such as the telecommunications operator, Internet service provider, language, time zone, IP address, connection speed and, where applicable, information about nearby devices or devices connected to the same network, where necessary to enable certain features of the application.

Access to and processing of this data will be strictly limited to the purposes necessary to provide the service, guaranteeing its confidentiality, integrity and availability at all times, as well as respect for the User's rights.

9. Changes to this policy

ReciClan reserves the right to change or amend the Privacy Policy and/or the Terms and Conditions of Use or any service policy. ReciClan Users will be informed in advance of changes affecting them, with regard to this Privacy Policy and/or the Terms and Conditions of Use and/or the functionality of ReciClan itself. Any change or amendment will take effect once published on the website www.reciclan.org and/or in the ReciClan application.

Amendments that are notified will be deemed accepted if the User uses the service. It is therefore the User's obligation to review these conditions and other applicable policies frequently in order to be aware of the Privacy Policy and the Terms and Conditions of Use that apply to the service provided. Non-acceptance of the amendments entails the loss of the right to use the ReciClan application, and the User must therefore stop using the Service.

10. Contact

If you have any questions about the Privacy Policy, you can contact us by email at info@reciclan.org or in writing at Avinguda d'en Piera 132, 08107 Martorelles (Barcelona), Spain, for the attention of RECICLAN APP, S.L.