1. Introduction and GDPR Compliance

In accordance with 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 (General Data Protection Regulation – GDPR), Bouncer Digital S.L., informs the users of the mobile and web application: “BOUNCER” (hereinafter, the Application), about the processing of personal data, which they have voluntarily provided during the process of registration, access and use of the service.

IDENTIFICATION OF THE DATA CONTROLLER.

Bouncer Digital S.L., with CIF/NIF no: B72926405 and address for notification purposes at: C/ Fernando VI, 5o 2, C.P. 28004 – Madrid (Madrid) and registered in the Commercial Registry of Madrid Volume 35.857, Folio 24, Section 8, Page M-644237, inscription 1a, (hereinafter, the Data Controller), is the entity responsible for the processing of the data provided by the customers of the Application (hereinafter, the User/s).

2. Data Collection

2.1 Personal Information

In order to proceed with the registration, access and subsequent use of the Application, the User must provide -on a voluntary basis-, essentially personal data, identification, images, and biometric data, which will be processed by automated means owned by Bouncer Digital S.L.

2.2 Facial Data Collection and Use

We collect biometric facial data in the form of 3D Face Maps solely for the purpose of identity verification as part of our Know Your Customer (KYC) process. This data allows us to confirm that the person accessing the account is indeed the authorized user. The data is
encrypted during processing and is not retained or stored after verification is complete. Once the age verification process is complete, the data is immediately deleted and is not retained or accessed again.

3. Purpose of Data Processing

The collection, storage during the process of verification, modification, structuring and, where appropriate, deletion of data provided by Users, will constitute processing operations carried out by the Responsible, in order to ensure the proper functioning of the Application, maintain the service relationship with the User, and for the management, administration, information, provision and improvement of the service. Bouncer Digital S.L. does not retain personal data once they have fulfilled their purpose.

4. Legitimacy

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

● The acceptance of the legal age data verification service through the matching of biometric and identification data, a service offered by the Application to its customers, whose terms and conditions will be made available to the User in any case, in advance, for express acceptance.
● The User’s free, specific, informed and unequivocal consent, by making this privacy policy available to him/her, which he/she must accept by means of a statement or a clear affirmative action, such as ticking a box provided for that purpose.
● In the event that the User does not provide Bouncer Digital S.L. with his/her data, or does so erroneously or incompletely, it will not be possible to proceed with the use of the Application.

5. Retention, Storage and Security of Personal Data

5.1 Preservation of Personal Data

Bouncer Digital S.L. does not retain personal data beyond the time necessary for the purpose of processing. All data is deleted immediately once it is no longer required for the operation of the Application or when the User requests its deletion.

5.2 Facial Data Storage and Security

Facial data is encrypted during processing and is not stored once identity verification is complete. Once the verification process is complete, the data is immediately deleted and is not retained.

We adhere to industry standard security practices, including regular rotation of encryption keys, to protect user data.

6. Recipients and Data Retention

6.1 Preservation and Deletion of Facial Data

Once the identity verification process is complete, the 3D Face Map data is deleted. If a user chooses to delete their account, all user-generated data, including the 3D Face Map, is deleted immediately. This process reflects our dedication to user privacy and control over personal information.

6.2 Other Recipients and Data Retention Provisions

The data will not be communicated to any third party outside Bouncer Digital S.L., except by legal obligation or in any case, upon request of the User’s consent.

DATA RETENTION

The personal data provided by the User are processed in the systems and databases of the Data Controller, as long as the User continues to use the Application, and provided that he/she does not request their deletion, during the legally established period.
legally established period and these will be maintained with all those security measures necessary to ensure security, integrity and confidentiality. All data is deleted immediately once it is no longer necessary for the operation of the Application.

PROTECTION OF HOSTED INFORMATION

The Data Controller takes the necessary measures to ensure the security, integrity and confidentiality of the data in accordance with the provisions of 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.

7. Exercise of rights

Bouncer Digital S.L., informs the User that he/she has the rights of access, rectification, limitation, suppression, opposition and portability, which may be exercised
by sending a request to the following e-mail address: [email protected].

Likewise, the User has the right to revoke the consent initially granted and file claims of rights before the Spanish Data Protection Agency (AEPD).

8. Commercial communications by electronic means

In application of the LSSI (Law of Services of the Information Society), Bouncer Digital S.L., will not send advertising or promotional communications by e-mail or other equivalent means of electronic communication that has not been previously requested or expressly authorized by the recipients of the same.
In the case of users with whom there is a prior contractual, legal or service relationship, the Data Controller is authorized to send commercial communications relating to products or services of the Data Controller that are similar to those initially contracted with the customer. In the event that the User wishes to unsubscribe from receiving the aforementioned communications, he/she may do so by sending an e-mail to the following e-mail address: [email protected].