Basic Information Treatment of Personal Data.

BASIC DATA PROCESSING INFORMATION
Responsible for the treatment	NBN23 S.L. CIF. B40634206 Calle Juan de la Cierva y Codorniu nº 27; Edificio Wellness 13ª Planta. 46980 Paterna (Valencia, Spain). E-mail of the Data Protection Delegate DPO@nbn23.com / DPO@nbn23.tech
Purposes of Processing	User registration. Access to private area. Purchase of applications, subscription, payment, download of applications. Management of returns, claims and withdrawal in the purchase of applications. Management of user profile claims and / or user player. Respond to requests for information and contact. Send own or third party commercial communications. Offer commercial communications based on profiling and segmentation tasks. Fraud prevention, age verification of minors accessing the page. Personalization and monitoring of activities carried out on the page through cookies, based on the authorizations granted. Analysis of usability and quality of the site and computer applications to improve it.
Source	Provided by the user himself. Obtained by browsing the website. Also obtained through the user’s social network login.
Legal basis	The execution of the license agreement for the use of the applications with the user. To comply with the legal obligations of NBN23. Consent of the data subject, for the sending of commercial communication and transfer of data to third parties, as well as the evaluation of their habits to provide personalized content and outreach of challenges through the Swishverse application. Legitimate interest of NBN23, in relation to the processing activities necessary for the prevention of fraud, age verification of minors, informative and commercial communications related to the products and services contracted.
Data Transfers	All those that are necessary for the fulfillment of the aforementioned purposes or are carried out in compliance with a legal obligation established for NBN23. Public Administrations, suppliers for the provision of services, companies and collaborating entities, Banking Entities for the management of collections/payments.
	They may be exercised by e-mail DPO@nbn23.com, or at the registered office of NBN23: Calle Juan de la Cierva y Codorniu nº27, Edificio Wellness, 13th Floor. 46980 Paterna (Valencia, Spain).
Rights of interested parties	We inform you that you may exercise, where appropriate, the rights of access, rectification or deletion, limitation of processing, opposition, to data portability or not to be subject to a decision based solely on automated processing, as well as to withdraw consent.
	More information

1. Introduction

This Privacy Policy describes how NBN23 S.L. (“we” or “us”) collects, uses, discloses and safeguards the personal information of users (“you” or “user”) of our application subscription selling website (“the Site”).

Identification of the Controller and Scope of the Privacy Policy. / Who is the Controller of Personal Data?

NBN23 S.L. (hereinafter “NBN23”) is the Data Controller of your personal data in order to provide you with the services identified in our App Store/Sale of App Subscriptions.

NBN23 is a company with registered office at C/ Juan de la Cierva y Codorniu nº 27; Edificio Wellness 13ª Planta. 46980 Paterna (Valencia, Spain) and its VAT number is B40634206.

At NBN23 we are committed to the fundamental right to the protection of your personal data and this Privacy Policy is intended to inform you about the processing of personal data that we carry out and about your data protection rights in accordance with current legislation on Personal Data Protection.

Please note that NBN23 has a Data Protection Officer in accordance with the aforementioned regulations, who is at your disposal for any questions or concerns regarding the processing of your personal data, and who can be contacted through dpo@nbn23.com /dpo@nbn23.tech.

3. Information We Collect; What Information Do We Process?

3.1. Personal Information that you provide us directly:

• We collect information about you when you contact us through the channels provided for this purpose, as in the contact form, application download form and payment, return forms, withdrawal and / or cancellation of the service. All fields marked with an asterisk (*) that are provided to you in the different services must be completed, so that the omission of any of them could make it impossible to provide you with the requested services. You must provide truthful information, being forbidden the impersonation of identity.
• To ensure that the information provided is always up to date, you must inform NBN23 as soon as possible of any changes to your personal data.

Likewise, by clicking on the “I accept”/ “process order” button (or similar) incorporated in the forms and services available, you declare that the information and data you have provided in them are accurate and truthful.

Application and contact forms	Identification data: name and surname, e-mail address. Request and/or information data.
User registration	Identification data: Name and surname, e-mail address, contact telephone number, user login. Personal characteristics data: age, sex, date of birth.
Application subscription / application store	Identification data: Name and surname, complete postal address, e-mail address, ID card, telephone number. Economic data: price, payment method, invoicing, tax deductions/taxes. Transaction data of goods and services: application license, product renewal dates.
Management of returns, complaints and withdrawal rights	Identification data: name and surname, postal address, e-mail address. Transaction data: order data, return, complaint management and withdrawal.

3.2. Information obtained indirectly / Usage Information:

When you browse our Site and/or when you use the applications, according to the authorizations you grant us, other tracking technologies may be installed on your device, as explained in our Cookie Policy. Cookies.

Cookies

IP address, browser type, page views, time and date of access, referrer URL.

4. What is the origin of the data?

We consider that all data processed by NBN23 has been provided freely and by the owner.

In the event that the data you provide us is of a third party, either within the order data or in our “Gift Card” services, you warrant that you have informed them of this Privacy Policy and have obtained their authorization to provide us with their data for the purposes outlined in this Privacy Policy; also, you warrant that the data provided is accurate and up to date, and you become liable to us for any damages, direct or indirect, that may be caused as a result of a breach of this obligation.

5. Purpose of Data Processing / For what purpose and on what legitimate basis do we process the data?

We use the information collected for the following purposes:

3.1.- Manage User registration and access to the applications.

We will process your personal data for the registration as a registered user on our website and for the download of our applications. The basis that legitimizes the treatment is your consent; we will send you communications in connection with this registration and activation, which have their legitimacy in your status as a user.

3.2.- To manage the Services of our computer applications.

We will treat your personal data to give you access to our computer applications according to the plans and services you have contracted, as well as to inform you through notifications, notices and alerts regarding subscription deadlines, subscription changes, changes in service, respond to your requests for information. The basis that legitimizes the treatment is in the hiring of our services, whether free and/or paid services.

3.3.- Manage the purchase of applications.

We will treat your personal and payment data for the contracting process of our applications, including your payment data. We inform you that we do not store card data and / or payment methods, since we use payment service providers that offer a total guarantee of security in such transactions. The basis that legitimizes this treatment is the hiring of our applications.

3.4.- Returns, claims, cancellations and exchanges.

We use your user data to respond to your complaints, requests for refunds, plan changes, and to respond to the queries you send us in this regard. The legal basis that allows this treatment is the fulfillment of our legal and contractual obligations.

3.5.- Profile claims.

We will use your personal data and the data you provide to us in profile or impersonation claims that you request from us. This is done on the basis of our legal obligations.

3.6.- Notifications and notices.

We will use your personal data to send you any communication related to our products and services available to you, either via email, sms and / or through notices and balloons within the application. You can configure them to select the channel in which you want to receive them. The basis that legitimizes these communication actions is the existence of a relationship between the parties.

3.7.- Notifications/notices/communications of products and services of third parties.

If you have given your consent, we may send you information, communications, notices and balloons, both within your area of the application and to the contact addresses you provide, about products and services of third parties with whom we collaborate. At any time you can disable these communications and/or object to them completely free of charge if you revoke your consent.

3.8.- To provide, personalize and improve your experience with our applications.

In order to offer our users improvements in our services and applications, we may use the application usage data. The basis that legitimizes this processing is the legitimate interest of NBN23 to offer services tailored to the needs of its users, the security of the applications and improvements in their performance.

To ensure the technical operation of the service, develop new applications and analyze the use of the service, including your interaction with applications and services made available to you on NBN23 applications.

We use the user’s data and their use of NBN23’s computer applications for the purposes of study and statistical analysis, in relation to behavior and preferences, to adapt our applications over time and to introduce new developments and functionalities. The basis for this processing is the legitimate interest of NBN23.

3.10.- To comply with our legal obligations.

We will treat your personal data to comply with the legal obligations that correspond to us, both fiscal, corporate, data protection, services of the information society, consumers and users, among others. The basis that legitimizes these treatments are such legal obligations.

6. Information Sharing

We may share your personal information with third parties under the following circumstances:

6.1. Proveedores de Servicios

We share information with third parties who perform services on our behalf, such as payment processing, data analysis, marketing services and customer support.

6.2. Socios Comerciales

We may share your information with business partners to offer you products and services that may be of interest to you.

6.3. Transacciones Comerciales

In the event of a merger, acquisition or sale of assets, your information may be transferred as part of the transaction.

6.4. Con su Consentimiento

We may share your information with third parties when we have your express consent to do so.

6.5. Cumplimiento Legal

We may disclose personal information to comply with applicable laws, regulations, legal process or governmental requests.

7. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, outreach, alteration or destruction. However, no method of transmission over the Internet or electronic storage is completely secure, so we cannot guarantee the absolute security of your information.

8. Data Retention

We will retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Once these periods have expired, your personal information will be deleted.

9. User Rights

You have the following rights in relation to your personal information:

9.1. Access and Rectification:

You have the right to access the personal information we hold about you and to request correction of any inaccurate data.

9.2. Cancellation and Opposition:

You may request deletion of your personal information and object to its processing under certain circumstances.

9.3. Portability:

You have the right to request the transfer of your personal information to another data controller.

9.4. Treatment Limitation:

You may request the limitation of the processing of your personal data in certain situations.

9.5. Channels for the exercise of rights:

To exercise these rights, please contact us by e-mail to our Data Protection Delegate DPO@nbn23.com, or by post to the registered office of NBN23: Calle Juan de la Cierva y Codorniu nº27, Edificio Wellness, 13th Floor. 46980 Paterna (Valencia, Spain).

Likewise, you can always go to the Spanish Data Protection Agency to request its protection or file a complaint if you consider that your rights have not been met.

10. Changes in the Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We recommend that you review this Privacy Policy periodically to be informed of any changes.

11. Contact

If you have any questions or concerns about this Privacy Policy, please contact us at:

E-mail: dpo@nbn23.com

Address: Avda. Juan de la Cierva y Codorniu, 27 Wellness Building 1 Floor 3 Paterna Technological Park (Valencia)

Effective date: 09/1/2024