To demonstrate that we care about the privacy of our users, and manage their relationships with us, in TURISPORT, SL treat your personal data to fulfill different purposes, always in accordance with the provisions of current regulations, respecting their rights and with full transparency.

For this purpose, we have adopted and inform you of this Privacy Policy for Personal Data, which you will access when registering your data in the first access to the app and which explains, in an understandable and simple to understand language, how we collect, store, use and disclose the information, with regard to the processing of personal data that Users have voluntarily provided during the registration process, access and use of the service.

The main regulations governing the processing that we will do with your personal data are:

(i) 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 and repealing Directive 95/46/EC (hereinafter the GDPR).

(ii) Organic Law 3/2018 of December 5, 2018, on the Protection of Personal Data and Guarantee of Digital Rights (hereinafter LOPD).

The controller is the legal entity that determines the purposes and means of the processing of personal data. In other words, the controller decides how and for what purposes personal data are processed.

For the purposes of this Data Protection Policy, the person responsible for the processing of personal data is:

• Identity of the company: TURISPORT, S.L., NIF number B0888215, registered in the Mercantile Registry of Barcelona, Volume 36346, Folio 211, Page B 37976, Inscription 13.
• Registered office: Calle Isaac Newton, 8, 08430, La Roca del Vallès, Barcelona
• Contact telephone number: 902 365 112
• Contact e-mail: [email protected]

Personal data is any information about an identified or identifiable natural person.

For the treatments and purposes that we explain in this Privacy Policy, the responsible collects and processes personal data indicated in each type of treatment, and that will depend on the different services you request or the contractual relationship with TURISPORT, SL

Not all of the data we inform you about is used for all data processing. We detail the type of data processed for each treatment.

In the case of processing based on your consent, we will additionally inform you of the details of the specific data used.

The User guarantees and is responsible, in any case, for the truthfulness, accuracy, validity and authenticity of the personal data provided and undertakes to keep them duly updated.

Processing of SOS Alert mobile application data

We process the following categories of personal data:

a) Personal data provided by the User:

• The above personal data, when requested, are necessary for the proper performance of the contract between TURISPORT, S.L. and the User, and to enable us to comply with the legal obligations of TURISPORT, S.L., except when we rely on the consent of the User as a legal basis for processing, and for our legitimate interest. Without them, we may not be able to provide all the services requested.

  It is important that all personal information provided to us is correct and accurate. This includes, among other things, ensuring that the contact details we hold (including email address) are always correct. the User shall be solely responsible for the veracity and correctness of the data he/she provides.

  When installing the SOS Alert Application, the data provided by the User is stored in the device itself and may be sent and stored in the servers of the service, as well as being sent and stored by the insurance company and/or the emergency/assistance services or third parties to provide related services, with which it establishes communication to offer the service.

  SOS Alert may use the telephone numbers and/or e-mail to locate the User, and provide the service for which it was developed, thus facilitating the task to the insurance company / emergency services and / or roadside assistance or third parties to provide related services. Such numbers will only be communicated to third parties for the exclusive and necessary provision of the Application Service and/or to make commercial proposals.

  The personal data provided by the User may be communicated to third parties, such as the Application servers, as well as to insurance company / service or emergency or roadside assistance centers or other third parties to provide related services, for the provision of the Application Service. Similarly, and in accordance with the provisions of the LOPD, the personal data obtained will also be communicated to other third parties in cases where a legal rule so provides.

  By submitting personal data, the User expressly agrees to the use and management thereof by TURISPORT, S.L., Owner of the Application, as well as by the insurer and / or emergency services / assistance or third parties to provide related services, to which it could have been sent.

  Our services may incorporate optional features that, if you use them, require us to collect additional information to provide those features. You will be notified of such collection, as appropriate. If you choose not to provide the information required to use a feature, you will not be able to use the feature.

b) Personal data automatically collected by the use of the V16 emergency beacon.

• Location / geolocation data – real-time geographic location of the device where the SOS Alert Application is installed – in the event of a breakdown or accident notification or other cause of vehicle parking, whereby the User accepts and consents to the collection, transmission, maintenance, processing and use of such location / geolocation data.
• The activation of the alert collected on the communications operator’s server and integrated in SOS alert implies the authorization to the insurance company / emergency or roadside assistance service or centers or other third parties to provide related services, for the use, in case of need, of all the locations obtained. The User agrees that the insurer / emergency or roadside assistance services or centers or other third parties to provide related services, may collect, maintain, process, store and/or use diagnostic, technical, usage and other related information.

  If you do not expressly consent to the collection, maintenance, processing, storage and/or use of your location/geolocation data, do not download or use the SOS Alert Application.

• We collect information relating to visits to the Application and the use of the Application by the User, such as the device and browser used, the IP address or domain names of the computers connected to the website, the URI addresses of the requests made, the time of the request, the method used to send the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters related to the operating system and computer environment used, the date and time of the visit, the duration of the visit, the referring site and the navigation path on the website related to the visit and the interactions on the website, including the services and offers in which the User is interested. Please note that we may associate this information with the User’s account.
• To the extent permitted by applicable law, we may receive additional information about the User, such as fraud detection information and notices from third party service providers or partners for our fraud prevention activities.

Since personal data (including sensitive data) may be collected through permissions – we inform Users of the use of any of the following groups of permissions that the application requests and needs to function properly:

The User can manage these permissions through the application settings of the mobile device’s operating system, being able to grant or deny such permissions at any time. Notwithstanding the foregoing, we inform you that all permissions required by the mobile App are necessary for its proper functioning.

The Data Controller adopts the physical, technical and organizational measures necessary to ensure the security, integrity and confidentiality of the data in accordance with the provisions of the regulations on the protection of personal data.

It is important for the User to protect against unauthorized access by third parties to your password and to their computers, devices and applications. We recommend that you use a unique password for your SOS Alert account that you do not use for other online accounts.

Notwithstanding the foregoing, the security of information transmitted over the Internet cannot be guaranteed. In this sense, TURISPORT, SL can not be held responsible for any interception or interruption of communications over the Internet or changes in or loss of information. Users of the Application are responsible for maintaining the security of any password, User name or other form of identification to gain access to password-protected areas of any of our services. In order to protect both the user and your information, we may suspend the use of any of the services TURISPORT, SL without notice, pending investigation, if it is suspected that there is a breach of security.

Also, although the Responsible, TURISPORT, SL, makes backup copies of the content hosted on its servers, however not responsible for the loss or accidental deletion of data by users. Likewise, it does not guarantee the full replacement of data deleted by Users, since such data may have been deleted and/or modified during the period of time elapsed since the last backup.

The services provided or rendered through the Application, except for specific backup services, do not include the replacement of the contents kept in the backup copies made by the Data Controller, when this loss is attributable to the User; in this case, a fee will be determined according to the complexity and volume of the recovery, always with the prior acceptance of the User. The replacement of deleted data is only included in the price of the service when the loss of the content is due to causes attributable to the Responsible Party.

All personal data provided by the User when registering (which are requested to the Users through the Application) and the location / geolocation data reported to the operator’s servers, are going to be used for the following purposes:

• They are necessary to provide the service object of the service by virtue of which the Application has been downloaded and installed on the corresponding devices.
• Inform the User’s insurance company, if provided by the User, and/or the emergency service / roadside assistance or other third parties to provide related services, for the activation, management or contracting of services related to the incident.
• Communication with the User: TURISPORT S.L. uses the User’s data when it needs to send notifications of the Service and respond when the User contacts.
• The user’s personal data may also be processed to send communications related to the activity of TURISPORT SL, focused at all times to keep your app updated or because from TURISPORT SL is considered interesting that the user would know other services provided from TURISPORT SL and, in any case, always related to the services of TURISPORT SL, TURISPORT SL partner companies or application SOS alert.
• Improve and develop the Services: we use the information we collect to improve and customize the Services, troubleshoot problems and protect against potential errors. Statistical analysis of errors is performed for the sole purpose of improving the Services.

By providing us with your data, the User declares to have read and understood this Privacy Policy, giving their unequivocal and express consent to the processing of their personal data in accordance with the purposes and terms expressed herein.

Our organization undertakes to treat your personal data with complete confidentiality and to implement appropriate physical, technical and organizational security measures for the protection of your personal data. In particular, your data is encrypted both in storage and in communication to preserve confidentiality.

Personal data will be kept as long as the interested party does not request cancellation. If you decide to cancel your personal data, they will be deleted from our database and you will not be able to use our application, without prejudice to the provisions of the section “Terms of retention of your data” of this Privacy Policy.

The necessary communications made by TURISPORT SL for the proper provision of services that involve the processing of user data by a third party, will be supported by the corresponding contract processing manager TURISPORT SL will sign with such companies.

The processing of the User’s data is carried out with the following legal bases that legitimize it:

• The request for information and/or the contracting of the services of the Application, whose terms and conditions will be made available to the User in any case, in advance, for their express acceptance.
• The legal basis for the processing of data is the free, specific, informed and unequivocal consent of the User, making available to him/her the present Privacy Policy, which he/she must accept, by accepting and checking a box provided for this purpose, when installing the app on his/her mobile device (Android or iOS), as well as the authorization for the location / geolocation reported to the operator’s servers.

  If the user does not provide TURISPORT SL their data, or do so erroneously or incompletely, it will not be possible to proceed with the use of the application.

• In addition, the execution of your automobile insurance contract with your insurance company also legitimizes the communication of your personal data including location / geolocation data to the same or to third party partners of the same to provide related services, in case of breakdown, accident or other cause of parking of the vehicle in order to provide you with roadside assistance.

• Your personal data will not be disclosed to third parties unless you inform us through the mobile application of the occurrence of your breakdown or accident on the road, or other cause of parking the vehicle.
• Likewise, the above data may be communicated to a specialized company for the request of the corresponding emergency service through the emergency number 112 throughout the national territory.
• Processors: we inform that TURISPORT SL hires third-party suppliers for the provision of some services (technology service providers for the purposes of maintenance and development of the app, etc.). Suppliers may have access to your personal data in their capacity as data processors. With regard to the App users, the following providers have access to their data: Telefónica España, S.A.
• Your personal data will not be transferred to other entities, unless legally required. We inform you that international data transfers will not be carried out either.
• Your data will be communicated to the Dirección General de Tráfico (DGT), in an anonymized form, through the beacon, not through SOS alert. Only data related to the incident will be communicated, in compliance with current road safety regulations.
• Transfers of companies: as we develop our business, we may buy or sell other companies or services. In such transactions, one of the assets of the transferred companies is usually the personal information of the customers; such information will in any case be subject to the commitments made in the pre-existing Privacy Notices (unless, of course, otherwise authorized by the customer). Of course, in the unlikely event that TURISPORT S.L., or substantially all of its assets, is acquired by a third party, personal customer information would be one of the transferred assets.

Retention for the maintenance of the Contractual Relationships
We will process the User’s data for as long as the Contractual Relationships that we have established remain in force.

Retention of consent-based processing authorizations

We will process data based on the User’s consent, until the User revokes it.

If the user cancels your service contract with TURISPORT, SL, but does not revoke the consents that we would have given us automatically leave them without effect since it ceases to be a customer.

Retention for compliance with legal obligations and formulation, exercise and defense of claims.
Once revoked the authorizations to use your data by withdrawing your consent, or terminated the contractual or business relationships you have established with TURISPORT, SL, we will retain your data only to comply with legal obligations and to allow the formulation, exercise or defense of claims during the limitation period of the actions arising from contractual relations.

We will treat these data by applying the necessary technical and organizational measures to ensure that they are only used for these purposes.

Destruction of data

We will destroy your data when they have passed the retention periods imposed by the rules governing the activity of TURISPORT, SL and the statute of limitations for administrative or judicial actions arising from the relationship established between the user and TURISPORT, SL.

Cookies are small text files placed on your device to store data that can be read by a web server in the domain that placed the cookie. We use cookies and similar technologies to store and track your preferences and settings, enable you to sign in, provide interest-based advertising, fight fraud, analyze how our products work, and serve other legitimate purposes.

In the case of the SOS alert app, only session TOKEN cookies are used for user validation and navigation. This is done by using authorization data in the HTTPS header of the app calls.

The User has the possibility to accept or reject cookies, depending on the configuration of his device through the configuration options. If you refuse to receive or delete cookies, access to some services may not function properly.

In accordance with applicable data protection regulations, personal data subjects (Users) have a number of rights in relation to the processing of their personal data. In addition to the right to information, they can exercise their rights of access, rectification, deletion, limitation, portability of their personal data, opposition, not to be subjected to automated decisions, including profiling, to withdraw their consent, and to file a complaint with a supervisory authority.

The exercise of these rights shall be free of charge for the User, except in cases where manifestly unfounded or excessive requests are made, especially for repetitive reasons.

TURISPORT, S.L. will attend as soon as possible the exercise of the rights of the user and provide the requested information within a maximum period of one month from receipt of the request. This period may be extended for a further two months if necessary, taking into account the complexity and number of applications.

You may exercise the aforementioned rights by sending an e-mail to [email protected], attaching a document proving your identity and providing the necessary details to process your request.

Data subjects may obtain additional information about their rights on the website of the Spanish Data Protection Agency.

The detail of these rights is as follows:

Right to information:

The User has the right to be informed in a concise, transparent, intelligible and easily accessible manner, in clear and simple language, about the use and processing of his personal data.

Right of access:

The User has the right to ask us at any time to confirm whether we are processing his or her personal data, to provide him or her with access to information about the processing of such data and to obtain a copy of such data. The copy of the User’s personal data provided by us will be free of charge, although requests for additional copies may be subject to a reasonable charge based on administrative costs. For our part, we may ask the User to prove his identity or require further information necessary to process his request.

Right of rectification:

The User has the right to request the rectification of inaccurate, outdated or incomplete personal data concerning him/her. You may also request that incomplete personal data be completed, including by means of an additional declaration.

Right of suppression:

The User has the right to request the deletion of his/her personal data when, among other reasons, the data are no longer necessary for the purposes for which they were collected. However, this right is not absolute, so that TURISPORT SL may continue to keep them properly blocked in the cases provided by applicable law.

Right to limit processing:

The User has the right to request that we limit the processing of his or her personal data, which means that we may continue to store it, but not continue to process it if any of the following conditions are met:

• That the User contests the accuracy of the data, during a period of time that allows the Responsible to verify the accuracy of the data.
• The processing is unlawful and the User opposes the deletion of the data and requests instead the limitation of its use.
• TURISPORT SL no longer need the data for the purposes of treatment, but the user needs them for the formulation, exercise or defense of claims.
• The user has opposed the processing, while verifying whether the legitimate reasons TURISPORT SL prevail over those of the user.

Right to data portability:

The User has the right to have his/her data transmitted to another Data Controller in a structured, commonly used and machine-readable format. This right applies when the processing of your personal data is based on consent or the performance of a contract and such processing is carried out by automated means.

Right of opposition:

This right allows the User to object to the processing of his/her personal data, including profiling. We will not be able to comply with your right only when we process your data if we can prove legitimate reasons for the processing or for the formulation, exercise or defense of claims.

Right to opt out of automated decisions, including profiling:

This right allows the User not to be subject to a decision based solely on automated processing, including profiling, that produces – such decisions – legal effects or affects him/her in a similar way. Unless such a decision is necessary for the conclusion or performance of a contract, is authorized by law or is based on consent.

Right to withdraw consent:

In cases where we have obtained your consent to the processing of your personal data in connection with certain activities (e.g. for the purpose of sending you commercial communications), you may withdraw your consent at any time. In this way, we will stop performing that specific activity for which you had previously consented, unless there is another reason that justifies the continuity of the processing of your data for these purposes, in which case, we will notify the User of this situation.

Right to file a complaint with a supervisory authority:

It must be informed, in turn, in compliance with the provisions of the current regulations on the protection of personal data, based on Articles 63 and following of the Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, of the right of the User / interested party to seek the protection of the Spanish Data Protection Agency or, where appropriate, of the supervisory authorities of the Autonomous Communities.

Consequently, if you have any claims arising from the processing of your data, you can address them to the Spanish Data Protection Agency www.agpd.es (c/ Jorge Juan, 6, 28001 Madrid, Tel. 900 293 183) or the supervisory authorities of the Autonomous Communities.

In TURISPORT S.L. process your data within the European Economic Area and, in general, we hire service providers also located within the European Economic Area or in countries that have been declared with an adequate level of protection.

TURISPORT S.L. does not provide for international transfers in the course of processing your personal data.

However, if for the processing of your data for the purposes indicated above, your data should be transferred outside the European Economic Area (“EEA”), such transfers will be made on the basis of the signature with such companies located outside the EEA of standard data protection clauses adopted by the European Commission on international transfers.

If we need to use service providers who carry out processing outside the European Economic Area or in countries that have not been declared with an adequate level of protection, we would ensure that we guarantee the security and legitimacy of the processing of your data.

To this end, we require adequate guarantees from these service providers in accordance with the provisions of the GDPR so that they have, for example, binding corporate rules that guarantee the protection of information in a similar way to that established by European standards or that they subscribe to the standard clauses of the European Union.

TURISPORT S.L. may amend this Privacy Policy to adapt to new legislation, case law or interpretation of the Spanish Data Protection Agency. These privacy conditions may be supplemented by the General Conditions of Use, the Legal Notice and Cookies Policy and Special Conditions that, where appropriate, are collected for certain products or services, if such access involves some specialty in terms of protection of personal data.

We will also review this Privacy Policy from time to time as necessary to keep you informed of new processing.

• I have read and accept the General Conditions of Use and the Privacy Policy.
• I authorize the sending of information for the communication of improvements in the application, new products and services developed by TURISPORT SL.