Date last updated: 7/Oct/2024
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1. Introduction and GDPR Compliance

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​In accordance with Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and the free movement of such data (General Data Protection Regulation - GDPR), Bouncer Digital S.L. informs users of the mobile application and the website: “BOUNCER” (hereinafter, the Application), about the processing of personal data, which has been voluntarily provided during the registration, access, and use of the service.

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IDENTIFICATION OF THE DATA CONTROLLER.

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Bouncer Digital S.L., with Tax ID no: B72926405 and business address for notifications at: C/ Fernando VI, 5th floor 2, C.P. 28004 - Madrid (Madrid), registered in the Commercial Registry of Madrid, Volume 35.857, Folio 24, Section 8, Page M-644237, Entry 1 (hereinafter, the Data Controller), is the entity responsible for processing the data provided by the users of the Application (hereinafter, the User/s).

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2. Data Collection

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2.1 Personal Information

To proceed with registration, access, and subsequent use of the Application, the User must voluntarily provide personal data, including identification, images, and biometric data, which will be processed using automated systems owned by Bouncer Digital S.L.

 

2.2 Collection and Use of Facial Data

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

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3. Purpose of Data Processing

The collection, storage during the verification process, modification, structuring, and, if applicable, deletion of the data provided by Users will constitute processing operations carried out by the Data Controller, with the purpose of ensuring the proper functioning of the Application, maintaining the service relationship with the User, and managing, administering, informing, providing, and improving the service. Bouncer Digital S.L. does not retain personal data once they have served their purpose.

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4. Legitimacy

The processing of the User’s data is carried out based on the following legal grounds:

 

• The acceptance of the legal age verification service through biometric and identification data matching, a service offered by the Application to its clients, whose terms and conditions will be made available to the User in any case, in advance, for their express acceptance.

• The free, specific, informed, and unequivocal consent of the User, provided through the availability of this privacy policy, which must be accepted via a declaration or a clear affirmative action, such as checking a designated box.

• In case the User does not provide their data to Bouncer Digital S.L., or provides incorrect or incomplete data, it will not be possible to proceed with the use of the Application.

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5.  Retention, Storage, and Security of Personal Data

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5.1 Retention of Personal Data

Bouncer Digital S.L. does not retain personal data beyond the time necessary for the processing purpose. All data are deleted immediately once they are no longer needed for the operation of the Application or when the User requests their deletion.

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5.2 Storage and Security of Facial Data

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

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

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6. Data Recipients and Retention

 

6.1 Facial Data Retention and Deletion

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

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6.2 Other Recipients and Data Retention Provisions

The data will not be shared with any third party outside of Bouncer Digital S.L., except as required by law or in any case, upon the User’s prior consent.

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DATA RETENTION

The personal data provided by the User are processed in the systems and databases of the Data Controller while the User continues to use the Application and as long as they do not request its deletion, during the legally established period, and these will be maintained with all necessary security measures to guarantee safety, integrity, and confidentiality. All data are deleted immediately once they are no longer necessary for the operation of the Application.

 

PROTECTION OF STORED INFORMATION

The Data Controller takes necessary measures to guarantee the safety, integrity, and confidentiality of the data in accordance with Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016, on the protection of natural persons regarding the processing of personal data and the free movement of such data.

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7. Exercise of Rights

Bouncer Digital S.L. informs the User that they have the rights of access, rectification, limitation, deletion, objection, and portability, which they can exercise by submitting a request to the email: privacy@bouncer.global.

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Additionally, the User has the right to revoke the consent initially granted and file complaints about their rights with the Spanish Data Protection Agency (AEPD).

 

8. Commercial Communications by Electronic Means

In accordance with the Law on Information Society Services (LSSI), Bouncer Digital S.L. will not send advertising or promotional communications by email or other equivalent electronic means that have not been previously requested or expressly authorized by the recipients.

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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 related to products or services of the Data Controller that are similar to those initially contracted by the customer.

 

If the User wishes to unsubscribe from receiving such communications, they can do so by sending an email to the following address: privacy@bouncer.global.