Informativa sulla privacy

1. Data controller

We have not appointed a data protection officer because we are not required to (art. 37 GDPR and art. 34 LOPDGDD). For any question about your data, write to the privacy email or use the contact form (reason «Data protection»).

2. Which data we process

Data you give us

• Account: name, email and password (stored hashed with bcrypt; we never see it). If you sign in with Google, Google gives us your name, email, profile photo and an identifier of your Google account.
• Profile: photo, username, bio, website and location, if you fill them in, and whether your profile is public.
• Your books: texts, photos, page designs, covers, places and coordinates, travel dates, voice narrations (your voice is personal data) and background music. Photos may carry metadata embedded by the camera (such as the date or the GPS location): check them before uploading photos you plan to make public.
• Social activity: comments, likes, who you follow and who follows you, collections, tags and collaborations on books.
• Payments: your plan, the status and dates of your subscription, Stripe customer and subscription identifiers and your invoices. You enter your card details directly with Stripe: they never go through our servers.
• Contact: name, email and message when you write to us through the form.
• Acceptance of the terms: date and version of the terms and of this policy you accepted, and your confirmation that you meet the minimum age.

Data generated when you use the service

• Technical and security data: IP address, browser and device type, approximate country, date and time of requests and sign-in attempts. We use them to run the service, limit abuse and detect attacks.
• App usage: change log of shared books, notifications, achievements and statistics of your account. The searches you make in Omoidetabi are not stored.
• Visit statistics: when someone opens a shared book or page, we count the visit for its author without cookies or identifiers stored on the device. We don't store the IP address: only an irreversible daily code (computed from the IP, the browser and the book with a secret key that changes every day), the referring domain, the approximate country and whether it is a phone or a computer. Visits by the author and their collaborators don't count.
• Support requests: the messages and screenshots you send us from the app or the contact form, and our replies.

Data about other people

If you upload photos or audio featuring other people, or write about them, you are responsible for having their permission, especially if you are going to share the book.

3. Why we use your data and on which legal basis

We don't sell your data, use it for advertising or build commercial profiles. We don't send marketing communications; if we ever do, we will ask for your consent first. Where the basis is our legitimate interest, you can object (see section 8).

4. How long we keep data

• Account and content: while you have the account. If you delete it, we immediately delete your data from the database and your files (photos, audio, covers, avatar) from storage. They may remain in encrypted backups for [COMPLETAR: plazo de las copias de seguridad, p. ej. 30 días / 30 days], after which they are overwritten.
• Photos you remove from a page: we keep them for 24 hours so you can undo the change, then they are deleted.
• Books you delete: they are deleted with their pages, photos, narrations, music and cover, except files another book still uses (for example, a photo a collaborator also uses in their own book).
• Invoices and billing data: 6 years (art. 30 of the Spanish Commercial Code) and, in any case, for the limitation periods of tax obligations (4 years, art. 66 of the General Tax Law). If you delete your account, invoices are kept unlinked from it and blocked: they would only be used if an authority requests them (art. 32 LOPDGDD).
• Technical and security data: rate limit counters last minutes or hours; technical logs, at most [COMPLETAR: plazo de los registros técnicos, p. ej. 30 días / 30 days].
• Contact messages: as long as needed to answer you and up to 12 months afterwards, unless we need to keep them longer to handle a claim.
• Notifications: read ones are deleted after 30 days; the rest, when you delete your account.
• Visit statistics: each single visit (with its daily code) is deleted after 7 days; after that only daily totals remain, deleted when the book or the account is deleted.
• Support requests: while you have the account; if you delete it, they are deleted with it. Requests sent without an account follow the period for contact messages.

5. Who we share data with

To provide the service we rely on providers that process data on our behalf (processors), under a contract that complies with article 28 GDPR. They only access the data they need for their task:

Google and Stripe also act as independent controllers for some purposes of their own (for example, the security of your Google account or fraud prevention in payments), under their own privacy policies.

We will also disclose data to courts, authorities or law enforcement when the law requires it.

6. International transfers

Some providers are outside the European Economic Area (mainly in the USA). In those cases the transfer relies on an adequacy decision of the European Commission (such as the EU-US Data Privacy Framework, for certified companies, or the one for the United Kingdom) or on the standard contractual clauses approved by the Commission (art. 46 GDPR), with additional measures where needed. You can ask us for a copy of these safeguards.

7. What other people see

• Your books are private by default. If you publish them or share their link, anyone with the link can view them (including photos, texts, places and audio).
• If you make your profile public, people will see your name, username, photo, bio, location, website and your public books.
• Collaborators you invite see the shared book and, if they are editors, change it.
• Comments you write on public books are visible to anyone who views the book.

8. Your rights and how to exercise them

At any time, free of charge, you can exercise your rights of:

• Access: knowing which data we hold about you and getting a copy.
• Rectification: correcting inaccurate or incomplete data.
• Erasure: asking us to delete your data.
• Objection: objecting to processing based on our legitimate interest.
• Restriction: asking us to suspend processing in certain cases.
• Portability: receiving your data in a structured, commonly used format.
• Withdrawing the consent you gave us, without affecting earlier processing.
• Not being subject to automated decisions with legal effects (we don't make any).

Do it yourself: in Settings → Data & account you can download all your data (a JSON file with links to your photos and audio) and delete your account; in Settings → Profile you can correct your details.

Or write to us at [COMPLETAR: email de privacidad, p. ej. privacidad@tudominio.com] or through the contact form (reason «Data protection»), saying which right you want to exercise. We will answer within one month (extendable by two more months for complex cases, in which case we will tell you). If we can't verify that you own the account, we will ask you to prove it.

If you believe we have not handled your data properly, you can lodge a complaint with the Spanish Data Protection Agency (AEPD, C/ Jorge Juan, 6, 28001 Madrid, www.aepd.es), although we would appreciate it if you told us first so we can try to fix it.

9. Minors

You must be at least 14 years old to create an account (art. 7 LOPDGDD). When you sign up you confirm that you meet this age. If we learn that an account belongs to someone younger without the consent of their parents or guardians, we will delete it. To buy paid plans or printed books you must be of legal age or have the permission of your parents or guardians.

10. Security

We apply technical and organizational measures appropriate to the risk: encrypted connections (HTTPS), hashed passwords, access to data restricted to those who need it, rate limits against attacks, share links with random identifiers and permission checks on every request. No system is infallible: if we detect a breach that puts you at risk, we will tell you and notify the AEPD where required.

11. Changes to this policy

If we change this policy significantly, we will let you know by email or in the app and, where the law requires it, ask you to accept it again. The date and version in force are always shown at the top. For cookies and storage in your browser, see the cookie policy.