1. Controller
The data controller for personal data collected on this website is Databilidad, S.L., NIF B26894907, represented by Úrsula Sánchez Macías.
- Address: Calle Doctor Pardo 13, 10940, Garrovillas de Alconétar (Cáceres), Spain.
- Email: [email protected].
- Website: www.databilidad.com.
2. Applicable rules
This policy follows current Spanish and European personal data protection rules.
- Regulation (EU) 2016/679, General Data Protection Regulation (GDPR).
- Spanish Organic Law 3/2018 on Data Protection and Digital Rights.
- Spanish Law 34/2002 on Information Society Services and Electronic Commerce.
3. Personal data processed
Databilidad mainly processes identifying and contact data voluntarily provided through forms, information requests, commercial communications or queries.
Ordinary public forms do not request special categories of personal data under Article 9 GDPR.
Beyond data you provide voluntarily, some technical data is collected automatically: QR-code scans on batch pages (the batch's public identifier, timestamp, and browser/device, plus whether the scanned code was valid or had been revoked), and, in the producer app, screen-view events and technical error reports for strictly operational purposes.
For visits to the public website, the IP address is currently used only transiently in memory to curb abusive requests; new web telemetry rows do not retain the IP, its hash or network prefix, though they may retain approximate location (country, region and city). Some historical web records created before this change may retain a pseudonymized IP hash and network prefix (/24 for IPv4, /64 for IPv6), together with that location, for up to 12 months; this change does not rewrite those records and they remain subject to their retention period. Producer-app telemetry and its security records may retain a pseudonymized IP hash and network prefix tied to the session. The full IP address is never kept as a permanent record.
Producers can view, for their own products, aggregated statistics about the visits they receive, including a breakdown by country, region and, when visit volume is high enough, approximate city or town of origin. They never see the record of an individual visit. That city- or region-level breakdown is only shown once a product has received a minimum number of visits, and visitor groups too small to distinguish safely are merged into one combined category or, if still too small, withheld entirely -- specifically to reduce the risk that a single visitor could be singled out within that data.
The producer app requests certain device permissions solely for its own functionality, never for tracking or advertising purposes: camera access, to capture photos and videos of products and batches that are uploaded directly to the producer's own catalog; microphone access, used only to record audio during that video capture; and access to files/storage, to import CSV/XLSX catalog files and to select existing photos or videos already on the device. The app's session credential is stored in the device's secure system storage (Android Keystore) and never leaves it except to authenticate requests with Databilidad's servers.
4. Processing principles
Processing follows the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality and accountability.
5. Purposes
Data is processed to answer requests, manage demos or proposals, maintain the relationship initiated by the user and comply with commitments derived from forms or communications.
Data may also be used proportionally for operational, statistical, commercial or quality-improvement purposes.
6. Legal basis
The main legal basis is consent when the data subject provides data for specific purposes.
Where a request relates to pre-contractual measures, proposals or requested services, processing may rely on pre-contractual measures. Security and abuse prevention may rely on Databilidad's legitimate interest.
7. Retention
Retention periods vary by data type, unless the user requests earlier deletion, a longer legal retention duty applies, or liability evidence must be kept:
- Contact, demo or query requests: for as long as the relationship is managed and, generally, up to 12 months.
- Website analytics, QR-code scans and producer-app telemetry: up to 12 months.
- Internal technical diagnostic logs (system logs): up to 6 months.
- Compliance audit trail (audit events): up to 24 months.
- Infrastructure backups: rotated every 90 days.
8. Recipients and transfers
Data may be processed by providers needed for hosting, security, analytics, communications or request management, under confidentiality and data protection conditions.
If international data transfers become necessary, prior information and GDPR safeguards will be applied when required.
9. Security and confidentiality
Databilidad applies technical and organizational measures appropriate to the risk to prevent destruction, loss, alteration, disclosure or unauthorized access to personal data.
Personal data is processed confidentially by Databilidad and by the people or providers that need access to provide the service.
10. Rights
Users may exercise rights of access, rectification, erasure, objection, restriction, portability and not being subject to solely automated decisions where applicable.
To exercise rights, write to databilidad.com/contacto with reference GDPR-www.databilidad.com and information needed to verify identity. A person on Databilidad's team always handles these requests: there is no self-service portal or automated process for exercising them.
11. Complaints
If a user considers that data protection rules have been infringed, they may lodge a complaint with the competent supervisory authority. In Spain, this is the Spanish Data Protection Agency.
