Privacy Policy
Effectiveness date: November 2020
VINTERIA TRADE, S.L (hereinafter, “the Company”, “We”, “Us” and the like) is firmly committed to regulatory compliance and the privacy and protection of personal data. Accordingly, in the present Privacy and Cookie Policy (hereinafter, “this Policy”), the User (hereinafter “the User”, “you”, “your”) of Translator Bullet (hereinafter, “the/our app”) will find all the relevant information to better understand what We do with his/her personal data. If you do not agree with this Policy, please do not access and use our app.
We may update this Policy according to new legislative or jurisprudential requirements and/or business needs, among others. Any updates or modifications of this Privacy Policy will be considered applicable from the moment of their publication on the app. Therefore, the User is recommended to review this Policy regularly. This Policy will always be available on the app so that the data subjects can consult them at all times.
What does this Policy apply to?
This Policy applies to the personal data that We collect and process from you as a User of our app and the services offered in it.
Please bear in mind that in order to access and use our app you must be older than fourteen (14) years or above the required legal age according to the laws and regulations of your birth or residence country.
What does personal data mean and which data do We collect and process?
For the purposes of this Policy, "personal data" means all data that identifies you or that could be used to identify you, such as:
the personal data you provided to access and use our app;
the personal data provided, such as voice, wording and images, introduced in our app in order to translate the desired text;
information about the use that the User makes of our app (the sections you consult on our app, or the time that you remain on our app by using cookies);
information about the location of your device (that is, your IP address);
information about your Apple user ID when you have provided your consent to this platform to communicate this data to third party partners who develop apps offered through the platform.
In all cases, We only process personal data which is strictly necessary for the fulfillment of the purposes described above. In this sense, if you provide Us with more information than expressly required, you consent to the processing of it for the informed purpose/s for which you're sending it.
In order to properly provide the services offered in the app, the User must provide Us with accurate, truthful, updated and complete information, this being a reflection of the User’s real circumstances.
In this sense, please note that if you provide us with your images and/or voice, you are giving us your consent in order to process the above mentioned data with the exclusive purpose of carrying out the translation hired. Moreover, if you provide us with a third party’s voice or images, you understand and agree to have requested their consent in order for us to process said personal data.
Having said that, and in connection with the above mentioned, if you provide Us with personal data of third parties (adults), you confirm that you have informed them about the purposes for which their personal data will be processed and you guarantee to Us that you have obtained their prior and express consent to communicate their personal data to Us.
In light of the above, the Company will not be held responsible if:
The User and/or Customer is under fourteen (14) years of age or does not comply with the legal age requirements of his/her birth or residence country. In this sense, it is the sole responsibility of the parents and/or legal guardians to exercise adequate control over their minor children’s/wards’ online activity and to prevent their access to apps whose content is not suitable or recommended for minors. Therefore, the communication of a minor's personal data without the prior authorization of their parents/legal guardians is the exclusive responsibility of the latter. If We become aware that We have collected personal data about a User under the aforementioned age, We will delete that data as soon as it is technically possible.
The Company has received an adult’s personal data and/or private information to provide the services offered in the app by a third party who has not requested the adult’s consent to communicate his/her personal data to us. In such cases, the Company reserves the right to inform the interested person of how his/her personal data and/or private information has been collected and, where appropriate, We will ask the individual who provided the personal data to the Company to confirm that he/she requested the consent of the data subject and/or to amend this circumstance, as well as, if appropriate, to suspend the services and/or the User account.
For circumstances that are beyond our reasonable control, such as being provided with erroneous, incomplete, and/or fraudulent information from you as a User and/or Customer. You will be solely responsible for the inaccuracy or lack of veracity of the information provided. In this regard, the Company will not be held responsible for the impossibility of providing the Services or for the Services not being correct or complete because the User has not complied with this requirement.
Who is the personal data controller?
VINTERIA TRADE, S.L (hereinafter, “the Company”, “We”, “Us” and the like) is the controller of the User’s personal data above mentioned.
What do We use your personal data for?
Please be informed that you only are required to provide personal data and information strictly necessary to fulfill the purposes explained below. In this sense, if you provide Us with more information than that expressly required, you consent to the processing of it for the purpose/s for which you're sending it.
Having said that, We use your personal data for the following purposes:
To manage the translations requested;
To collect the fees of the premium subscription plan in regards to the services offered through the app;
To manage your information queries regarding our app and/or services offered through it;
To comply with our legal obligations, legal requirements, laws, and regulations and/or to respond to judicial, police or the corresponding authorities’ requirements;
To protect, investigate, and deter fraudulent, unauthorized, or illegal activity on/through our app;
To improve our app’s functionalities and services offered by analyzing disaggregated data not associated with a particular user’s personal information.
To show you advertisements related to our app while you are browsing your social media or third party websites.
What is the legal basis for processing your personal data?
We only process your personal data when there is a legal basis for doing so. The legal basis will depend on the reason(s) why We collect and process your personal data. In almost all cases the legal basis will be:
The consent that you provided Us with for the processing of your personal data in order to be able to provide you with the Services offered through the app and other purposes informed at the time of collection of your data (i.e. to install cookies). Also, the consent you have provided Apple to install cookies or similar technologies on your device(s) for the purpose of tracking your activity in these platforms, for example, what applications you have installed and shared with third party partners as well as the information about your browser or device for advertising purposes.
To comply with our legal obligations and/or to attend administrative, judicial, police, or the corresponding authorities’ official requirements.
Our legitimate interests in (i) offering an enhanced user experience when you access and use the app and operate it efficiently, (ii) monitoring fraudulent activity in order to preserve the security and integrity of our app; (iii) defending and addressing our rights in the event that a claim regarding our app and/or Services may arise.
How long do We keep your personal data for?
We will keep your personal data only for as long as it is necessary to fulfill the purposes for which they are being processed and, beyond that, your personal data will be retained, and securely blocked, for the necessary retention period to meet our legal obligations and/or for our legitimate reasons (i.e to address claims in connection with the services offered through the app; to finish the investigation of detected fraudulent or illicit activity.) In the specific case of cookie information, We will retain it providing that you do not revoke your consent. For further information regarding cookies privacy settings, please see the relevant section.
Regarding cookies or similar technologies used by Apple to collect and store the information on your device that is later shared with the partners of the services offered by this platform, we recommend that you consult the Privacy Policies and Cookies Policy of this platform for information on how to revoke the consent that you have given for the installation of cookies or similar technologies.
Once the necessary retention period has ended, your personal data will be securely deleted from our information systems.
Who do We share the User’s personal data with?
We may communicate your personal data to the following third parties, including but not limited to:
(i) our main service providers, and Apple, where appropriate;
(ii) administrative, police or judicial authorities as long as the data is required in accordance with the applicable law and regulations;
(iii) law firms to respond to claims regarding our app or services offered through it;
The third parties mentioned above may have their headquarters outside the European Economic Area (EEA), therefore, your personal data will be subject to international transfers. In any event, if a personal data international transfer is deemed appropriate, We inform you that We will only transfer personal data to recipients located in countries that ensure an adequate level of data protection or, failing that, offer the appropriate safeguards required by the current applicable law and regulations on the protection of personal data, in order to ensure that your personal data is properly protected and that your individual rights and freedoms are guaranteed. In this sense, please be informed that the third parties mentioned above are committed with standard contractual clauses approved by the EU Commission certification in case of transfers to the USA.
How do We protect your personal data?
Your trust is very important to Us. Therefore, your personal data is stored confidentially and securely in our information systems. We have established the appropriate technical and organizational measures to safeguard and protect your personal data against illegal or unauthorized access, loss or accidental destruction, damage, use, and illegal or unauthorized disclosure.
What are cookies and what are they used for?
For the purposes of this Policy, “cookies” are small files that are installed on the browser of your mobile device with information regarding your interaction with our app, for different purposes such as facilitating your navigation through our app, remembering your browsing preferences , customizing the services offered on this app, among others.
The memorized data recorded by cookies takes up a small space on a device’s memory and does not harm the device in any way.
When are cookies installed?
Interacting with our app and purchasing the paid services offered in it implies the installation of cookies, which may belong to us or be from third parties.
The use of third-party cookies is subject to the Cookies and Privacy Policies of these third parties. Therefore, We will not be responsible for the content or the veracity of the mentioned policies of said third parties. Please consult the website(s) and/or app(s) of said third parties to obtain more information or in the event that you want to change your preferences for setting these cookies. In this regard, you can review the section “How can the User block or refuse cookies?” of this Policy.
What type of cookies are installed?
Cookies that can be installed include the following:
Session cookies: these are used to identify the User during the session, prevent the User from having to repeat processes in the app and are automatically deleted when the browser on the User’s device is closed.
Persistent cookies: these are used to identify the User during the session, prevent the User from having to repeat processes in the app and remain installed for a certain time in the browser of the User’s device.
Owned cookies: these are sent to the User's device from our app and/or computer equipment, managed by Us, and their information is collected for our own purposes.
Third-party cookies: these are sent to the User's device from computer equipment or Website or app managed by another company (partners and/or service providers) and their information can be collected for our own purposes (i.e to know the geographical location of the User) and/or to manage or improve the services that these third-party companies offer (i.e to manage the payment of the app’s services.).
Technical cookies: these allow the management and operation of this app and enable its functions and services, for example, to carry out the purchase process and manage payment, etc.
Analytical cookies: these allow Us to analyze the use of this app and recognize which functionalities interest users the most, in order to improve the quality and functionalities of our services (i.e the app’s look and feel, messages’ design for usability, etc.) This information is obtained from disaggregated data which is not associated with a particular User or his/her personal information.
To install cookies in your device's browser, We need your express consent, although there are other cookies that are exempt from such consent. The exempt cookies are:
User Login cookies
User authentication or identification cookies (session cookies only)
We have enabled adequate mechanisms to obtain your consent for the installation of cookies that require it. However, please be informed that, in accordance with the applicable laws and regulations, (i) it will be understood that your consent has been given if you modify the configuration of the browser by disabling the restrictions that prevent the installation of cookies and that, (ii) when the installation of cookies is necessary to provide you with the services that you have expressly requested, your consent will not be necessary.
How can the User block or refuse cookies?
You can, at any time, revoke the consent given for the installation of cookies by (i) configuring the settings of the browser of your mobile device to disable the use of cookies in your browser and (ii) deleting the cookies stored in your browser associated with this app.
Please bear in mind that in the event that you decide to block, disable or delete cookies on your browser, you will not be able to access the functionalities of this app and, therefore, you will not enjoy the services offered through it.
What rights do you have and how can you exercise them?
You may exercise your data protection rights (i.e access, erasure, etc) by written request addressed to our Company through the following email address: admin@royalmobileapps.com.
As a general rule, We will respond to data protection rights requests within one (1) month. Occasionally, this period may be extended by two (2) further months where necessary, taking into account whether your request is particularly complex or you have made several requests. In this case, We will notify you of this event and explain the reasons for the delay to you.
Finally, We inform you that, should you consider it appropriate, you have the right to lodge a complaint before the corresponding Supervisory Authority, especially if you consider that your data protection rights have not been adequately addressed.
We remain at your disposal for any doubts or questions you may have about this Policy, please contact Us by email: admin@royalmobileapps.com.
