privacy policy and data protection
Árbol Lápiz, S.L. (hereinafter referred to as "VOY"), in accordance with the current legislation on the Protection of Personal Data, informs the Users of its online platform about the Privacy and Data Protection Policy that will be applied to the processing of the personal data that the User voluntarily provides when accessing the Website: [*] or the corresponding mobile application.
The User, by providing VOY with their personal data through the electronic forms on the Website or the Application, expressly consents to VOY or any of its subsidiaries processing these data under the terms of this Privacy and Data Protection Policy clause and for the purposes expressed herein.
Before registering with VOY, Users must read this Privacy and Data Protection Policy. By ticking the "register" button, Users affirm that they have read and expressly consent to this Data Privacy Policy.
When registering, Users must provide some data to create their account and edit their profile. They must provide the following data: username, email address, phone number, and credit card. Additionally, VOY, provided that Users authorize it, will collect data related to their location, including the real-time geographical location of the User's computer or mobile device.
Once the registration is complete, any User can access their profile and complete and/or edit it as they see fit. The User can also access and create an account through their Facebook profile. The information and data provided by the User will always be available in their user account and can be modified by the User through the edit profile option.
The User commits to entering real and truthful data. They will also be solely responsible for any damage and harm that VOY or any of its subsidiaries or third parties may suffer as a consequence of the lack of truthfulness, accuracy, validity, and authenticity of the data provided.
The data collected by VOY or any of its subsidiaries will be used exclusively to achieve the purpose defined in the General Conditions of Use of the Website, which can be consulted here.
- Applicable Legislation to Users' Personal Data (Personal Data Protection)
- Who is responsible for the Data you provide?
- Processing of Users' data and persons who contact VOY
- Exercise of rights
- Security measures
- Notifications and modifications
1. Applicable Legislation to Users' Personal Data (Personal Data Protection)
VOY expresses its commitment to comply with the current legislation on data protection at all times. Users are informed that the personal data provided on the Website will be subject to automated processing and will become part of the files owned by VOY, with VOY being the data controller for the purposes of managing registered users on the VOY Platform.
Basic information on Data Protection
Identity
Árbol Lápiz, S.L. – CIF: B88100532
Purpose
Management and provision of requested services
Legitimacy
Fulfillment of the contractual relationship, legitimate interest, and User consent
Rights
Access, rectify, and delete data, as well as other rights, as explained in the additional information
Additional Information
You can consult additional and detailed information about Data Protection in the following sections
According to the applicable legislation, the following Privacy Policy is detailed by VOY for the processing of data of Users who register on the Platform.
2. Who is responsible for the Data you provide?
All personal information that you provide or is collected through the App (available in Apple AppStore and Google Play Store) or Website: www.voy.party, www.voyapp.es, will be treated by VOY as the data controller, with its contact details shown below.
Data responsible of your data
Identity
Árbol Lápiz, S.L. – CIF: B88100532
Postal Address
C/ General Arrando, 32 - Piso 1, Puerta Izda., 28010 - Madrid
Phone
+34 649 39 71 95
Contact form
adonde@voy.party
3. Processing of Users' Data and Individuals Who Contact VOY
3.0. Data Processed
The VOY Platform (which includes the Web format and the "App") is used by both Users and our Providers. The information we receive from Users is collected as follows. VOY collects information provided directly by the User and information that is provided indirectly through the use of the VOY platform.
3.0.1 Information Users Provide Directly:
- 3.0.11 Registration Data: Information that the User provides when creating an account on the VOY Platform: Username and email address.
- 3.0.12 User Profile Information: Information that the User adds to the Platform to use VOY's service, such as their mobile phone and delivery address. The User can view and edit their personal profile data at any time. VOY does not store the User's credit card data; these are provided to licensed electronic payment service providers, who will receive and store the included data directly to facilitate the payment process for the User and manage it on behalf of VOY. These data are never stored on VOY's servers. The User can delete their linked card data from their account at any time. With this action, the service provider will proceed to delete the data, and it will be necessary to re-enter or select them to make new orders through the Platform. The User can request the privacy policies of these providers at any time.
- 3.0.13 Additional Information the User Wants to Share: Information that the User may provide to VOY for other purposes. For example, a photograph of themselves or the billing address if they request to receive invoices from VOY.
- 3.0.14 Information About Communications with VOY: VOY will have access to the information that Users provide to resolve doubts or complaints about the use of the platform, whether through the contact form, by email, or through customer service by phone.
- 3.0.15 In certain cases, and based on the legitimate interest and obligation of VOY to monitor all actions that could result in fraud or the commission of a crime related to the payment elements used by users, VOY may request a copy of the user's ID as well as the credit card used for the request. All data will, in any case, be processed by VOY solely for the purpose of fulfilling surveillance and fraud prevention functions and will be stored as long as the relationship with the user remains valid, as well as during the subsequent period as long as the user's or VOY's right to file claims or legal actions related to the payment of products or services requested through VOY has not expired.
- 3.0.16 To enhance your experience, VOY may request access to the User's contact list. This information will be used solely to allow you to add your contacts as friends within VOY. This information is managed as follows: Purpose: VOY uses the User's contact information to help you find and connect with friends who are also using VOY. Privacy: The contact list will be securely stored and encrypted, ensuring it is not accessible to unauthorized third parties. Consent: VOY will never share contact information with third parties without the User's explicit consent.
- 3.0.17 The processing of these data by VOY is necessary to fulfill the contractual relationship established. If the User does not provide them, the requested services may not be available, and VOY will not be able to provide them.
3.0.2 Information Users Provide Indirectly:
- 3.0.21 Data Derived from the Use of the Platform: VOY collects data derived from the User's use of the Platform each time they interact with it.
- 3.0.22 Application and Device Data: VOY stores the data of the device and the Application that the User uses to access the services. These are:
- 3.0.23 Internet IP address that the User uses to connect to the Internet with their computer or mobile.ç
- 3.0.24 Information about their computer or mobile, such as their Internet connection, browser type, version, operating system, and device type.
- 3.0.25 The complete clickstream of Uniform Resource Locators (URLs), including the date and time.
- 3.0.26 User Account Data: Information about the orders placed by the User, as well as the reviews and/or comments they make about them.
- 3.0.27 User's browsing history and preferences.
- 3.0.28 Data Derived from the User's Origin: If the User arrives at the VOY Platform through an external source (such as a link from another website or a social network), VOY collects data from the source from which the User comes to VOY.
- 3.0.29 Data Derived from Incident Management: If the User contacts the VOY Platform through the Contact Form or through the VOY phone, VOY will collect the messages received in the format used by the User and may use and store them to manage current or future incidents.
- 3.0.30 Data Derived from "Cookies": VOY uses its own and third-party cookies to facilitate user navigation and for statistical purposes (see Cookie Policy).
- 3.0.31 Data Derived from External Third Parties: VOY may collect information or personal data from external third parties only if the User authorizes those third parties to share the mentioned information with VOY. For example, if the User creates an account through their Facebook, Facebook may provide us with personal data of that User if they have it in their Facebook profile (name, gender, age…).
- 3.0.32 Likewise, if the User accesses VOY through the products and services offered by Google, Google may send navigation data of the User to VOY when accessing the platform through the links created by Google.ç
- 3.0.33 The information provided by the external third party can be controlled by the User according to the external third party's own privacy policy.
- 3.0.34 Geolocation Data: As long as Users authorize it, VOY will collect data related to their location, including the real-time geographical location of the User's computer or mobile device.
3.1. Purpose
3.1.1. Using the VOY Platform
VOY uses the data it collects from Users so that they can access and communicate with the VOY platform and to provide the services they request through their account on the VOY Platform, as described in the "Terms of Use."
3.1.2. Sending Communications
VOY uses Users' data to send communications via email and/or SMS to the User about the operation of the service.
3.1.3. Detecting and Investigating Frauds and Possible Crimes
VOY also uses the information to investigate and analyze how to improve the services it provides to Users, as well as to develop and improve the features of the service it offers. Internally, VOY uses the information for statistical purposes to analyze Users' behavior and trends, understand how Users use the VOY Platform, and manage and improve the services offered, including the possibility of adding new features to the Platform.
VOY may monitor all actions that could result in fraud or the commission of a crime related to the payment elements used by users. VOY may request a copy of the user's ID and certain information about the bank card used for the order request. All data will, in any case, be processed by VOY solely for the purpose of fulfilling surveillance and fraud prevention functions and will be stored as long as the relationship with the user remains valid, as well as during the subsequent period until the user's or VOY's right to file claims or legal actions related to the payment of products or services requested through VOY has expired. The data related to the credit card used will be retained during the resolution of the incident and for the following 120 days from its resolution date. If irregularities are detected in its use that could be considered illegal activities, VOY reserves the right to retain the data provided and may share them with the competent authorities to investigate the case. VOY may share the data with authorities based on the legal obligation to pursue conduct contrary to applicable regulations.
3.1.4. Ensuring Security and a Suitable Environment for the Safe Provision of Services
VOY may use the data to ensure the proper use of the products and/or services requested on its Platform (guaranteeing delivery to individuals over 18 years old, etc.).
3.1.5. Compliance with Regulations, Defense, and Legal Actions
VOY informs the user that conversations carried out through the chat for communication may be reviewed and used by VOY to file and/or defend necessary claims and/or legal actions, as well as to manage order incidents.
3.1.6. Promotion and Offers (online and offline)
VOY uses third-party technology integrated into its Platform to collect your data and preferences and use them with CRM systems and advanced technology for the Users' benefit. With the collected information, the following data processing will be performed:
- VOY may send promotional messages and/or offers related to the service it offers via email that may interest the User. VOY may measure and personalize this advertising based on the preferences of VOY Users. If the VOY User does not wish to receive this information and/or commercial communications, they can opt-out at any time by selecting the "Unsubscribe" option in the email itself, and consequently, VOY will immediately cease sending this information.
- VOY may also send the User messages and/or offers related to these services through "push" notifications, consisting of sending promotional messages and/or offers to their mobile phone. If the VOY User does not wish to receive commercial communications from this point and the previous 3.1.1, the User can remove them together by deactivating their privacy preferences in their profile with one click.
- VOY and/or third parties associated with VOY may use the address provided by the User to carry out promotional activities for delivering samples or free products related to the VOY service (i.e., advertising brochures).
- By using the VOY Platform, Users may also receive commercial communications from third parties associated with the Platform, such as Facebook and Google, all based on the privacy preferences the User has on these Platforms. Users can use their privacy management center to unsubscribe from "marketing" services online or cancel their account.
3.1.7. Statistical Purposes and Service Analysis
VOY uses the information for statistical purposes to analyze Users' behavior and trends, understand how Users use the VOY Platform, and manage and improve the services offered, including the possibility of adding new features to the Platform. VOY also uses the information to investigate and analyze how to improve the services it provides to Users, as well as to develop and improve the features of the service it offers.
3.1.8. Ensuring Security and a Suitable Environment for the Safe Provision of Services
VOY may use the data to ensure the proper use of the products requested on its Platform (ensuring pharmaceutical advice, guaranteeing delivery to individuals over 18 years old, etc.).
3.1.9. Processing Claims and Complaints with Insurers
If the User contacts VOY to report any damage or unforeseen event that may be covered by the insurance contracted by VOY, it will process all data related to the incident to manage and respond to requests.
3.2. Legal Basis for Processing
The processing of Users' data is based on the following legal bases:
- Execute the contractual relationship once registered on the Platform (e.g., processing your data to deliver a requested order).
- Based on our legitimate interest (e.g., conducting checks to prevent fraud through the Platform).
- Compliance with legal obligations (e.g., when competent authorities request data in the context of judicial investigations and/or the filing of necessary actions to protect VOY's interests).
- Explicit consent for the communication of user data to third parties to carry out commercial communications.
3.3. Recipients of Data
VOY guarantees that all business partners, technical providers, suppliers, or independent third parties are contractually bound to process information shared with them according to VOY's instructions, this Privacy Policy, and applicable data protection legislation. We will not transfer your personal data to any third party that is not subject to our instructions, and no communication will include selling, renting, sharing, or otherwise disclosing customer personal information for commercial purposes contrary to the commitments made in this Privacy Policy.
3.3.1. Sharing Users' Data with Third Parties
To continue providing the services offered through the Platform, VOY may share certain personal data of Users with:
- Service Providers: Third-party service providers that have permission to operate on the VOY platform will have access to the necessary personal information of Users to perform their functions, but they may not use it for other purposes. They must process personal information in accordance with this Privacy Policy and applicable data protection legislation.
- Payment Service Providers: When a User enters their card number on the VOY Platform, it is stored directly by the Payment Platforms contracted by VOY, who will allow the User's account to be charged. The payment service providers have been chosen based on their security measures and always comply with the security measures established by payment services regulations, being PCI Compliant according to the Payment Card Industry Data Security Standard or PCI DSS. VOY does not store these data in any case.
- Fraud Control Service Providers: VOY will share User data with providers offering fraud control services to assess the risk of operations carried out.
- Data Anonymization Service Providers: To prevent the misuse of User data by third-party service providers, VOY may transfer User data so that they can be anonymized and used only to provide the service to Users. For example, VOY may transfer Users' phone numbers to third parties to anonymize them and provide them in this format to providers used to fulfill the services contracted by Users.
- Security Companies and Law Enforcement Agencies: VOY may disclose personal information and account data of our clients when it believes that disclosure is necessary to comply with the law, enforce or apply the "Terms of Use" or protect the rights, property, or safety of VOY, its users, or third parties. This includes, therefore, sharing information with other companies and organizations, as well as with Law Enforcement Agencies to protect against fraud and reduce credit risk. Upon legal request, VOY may share information with executive authorities and/or third parties regarding requests for information related to criminal investigations and alleged illegal activities.
- Call Center Services and Incident Management: To offer Customer Service and call centers, actions aimed at measuring User satisfaction, and providing administrative support services, VOY may communicate User data to companies located in countries outside the EEA, provided they are authorized and comply with the security requirements mentioned in the previous point.
- Telecommunication Services: To provide Users with telephone contact services, VOY may contact telecommunications companies that provide secure lines and systems to contact Users.
- VOY Group Companies: To provide VOY services, according to the geographic area from which users request services, certain personal data of Users may be transferred to VOY's subsidiaries or group companies. Users are informed that when registering on the Platform from any country where VOY operates, their data will be stored in the VOY database located in [Spain] and owned by the Spanish company VOY. Data will be communicated, in the case of subsidiaries outside the EEA, through systems enabled by the European Commission and the Regulation, to countries that have an adequate level of personal data protection recognized or through contracts approved by the European Commission establishing and guaranteeing the rights of data subjects.
- Social Networks Connected by the User: If the User connects their VOY account to another social network or a third-party platform, VOY may use the information provided to that social network or third party, provided that such information has been made available to VOY in compliance with the privacy policy of that social network or third-party platform.
- Third Parties Associated with VOY for Commercial Communications: With explicit consent, VOY may transfer your personal data to third parties associated with VOY as long as the User has expressly, informed, and unequivocally accepted such data transfer and knows the purpose and recipient of the data.
- Change of Ownership Scenarios: If VOY's ownership changes or most of its assets are acquired by a third party, Users are informed that VOY will transfer their data to the acquiring entities to continue providing the services subject to data processing. The new controller will communicate their identification data to Users. VOY states that it will comply with the duty to inform the relevant Control Authority if the mentioned situations occur and will communicate the change of controller to Users when it occurs. This processing will be carried out under the contract signed with VOY.
- Insurance Companies: VOY may communicate user data to insurance companies and brokers with whom VOY has an agreement to manage and process claims and incidents arising from VOY's and its collaborators' activities.
The data of VOY Users will not be transmitted to any third party except (i) it is necessary for the requested services, in case VOY collaborates with third parties (ii) when VOY has the express and unequivocal authorization from the User, (iii) when requested by a competent authority in the exercise of its functions (to investigate, prevent or take action regarding illegal activities) or (iv) if required by law.
3.4. International Data Transfers
When choosing service providers, VOY may transfer user data outside the European Economic Area. In such cases, and prior to the transfer, VOY will ensure that these service providers comply with the minimum security standards established by the European Commission and that they process the data according to VOY's instructions. VOY may have a contractual relationship with them where the service providers commit to complying with VOY's instructions and incorporating necessary security measures to protect User data.
3.5. Data Retention Period
User data will be retained during the execution and maintenance of the contractual relationship, i.e., as long as they remain Users of VOY or until they exercise their right to limit processing. If Users unsubscribe from the Platform, VOY will retain their data for the period established by tax, health, criminal, and other applicable regulations, to execute and defend actions in which VOY might be involved. VOY will, in any case, block the Users' data so that they can only be consulted if action needs to be taken or in defense of such actions.
Specifically, without limiting other applicable regulations, the data will be retained after the User's unsubscribe period according to the deadlines provided in applicable Spanish legislation.
Regarding anonymous information, VOY will apply the provisions of Recital 26 of the GDPR, which states that "Data protection principles should not apply to anonymous information, i.e., information that does not relate to an identified or identifiable natural person, nor to data rendered anonymous in such a way that the data subject is not or no longer identifiable." Consequently, this Regulation does not affect the processing of such anonymous information, including for statistical or research purposes.
4. Exercise of Rights
- How long will we keep your data?
The personal data provided will be retained unless the data subject requests its deletion for a period of 24 months from the last interaction. If consent is withdrawn or if the processing is objected to, the data will be blocked and no longer processed, and will be retained for a period of 4 years to be able to claim or defend against possible claims.
- Right to withdraw consent
The User may withdraw their consent for data processing by VOY at any time. To withdraw consent, the User simply needs to use the "Delete account" function in the Settings section of the App. Withdrawal of consent can be done at any time by the data subject. Users acknowledge and agree that withdrawing consent will mean that VOY cannot provide the services of its Platform.
- ¿A qué información pueden acceder los Usuarios?
VOY da al Usuario acceso a una gran cantidad de información sobre su cuenta y sus operaciones para que pueda ver, y en ciertos casos, actualizar dicha información.
Todo Usuario podrá acceder a su perfil y completarlo y/o editarlo según estime conveniente. Como se ha indicado anteriormente, el Usuario podrá acceder y crear una cuenta a través de su perfil de Facebook. La información y datos facilitados por el Usuario estarán en todo momento disponibles en su cuenta de usuario y podrán ser modificados por el Usuario a través de la opción editar perfil.
- Rights of access, rectification, deletion, restriction of processing, objection, and data portability
The right of access is conceived as the right of the user to request VOY whether it processes any of their data, along with the information established in Article 15 of the Regulation. As established in Article 16 of the Regulation, the User may request VOY to rectify the data in its database if it is incomplete. The right to deletion allows the User to request VOY to delete their personal data in the cases provided for in Article 17 of the Regulation. If the User requests it, based on the conditions of Article 18 of the Regulation, VOY will limit the use of their data to what is established in that article. Article 20 of the Regulation regulates the right to data portability, which allows Users to request VOY to send all the data it has in a structured and machine-readable format, and request that it be transmitted to another data controller as requested by the User. The User also has the right to object to the processing of personal data held by VOY, as established in Article 21 of the same Regulation.
The exercise of these rights is personal, so the data subject must prove their identity. The exercise of these rights must be done in writing, signed by the data subject, indicating their address, and attaching a copy of their National Identity Document or other proof of identity, addressed to VOY, through its Contact Form or VOY's offices.
- What options do Users have?
As previously indicated, if the User wishes to stop receiving emails from VOY, they can adjust their subscriptions in their email inbox and click the "Unsubscribe" button. Additionally, Users can choose that VOY does not know their geolocation. Most mobile devices provide users with the option to disable location services. This option is usually found in the device's settings menu. If you have any questions about how to disable location services on your device, VOY recommends that Users contact the device manufacturer or service provider. In addition to exercising the above-mentioned rights, Users have the right to file a complaint with the supervisory authority for their claim to be acknowledged.
5. Security Measures
VOY has adopted the necessary measures recommended by the European Commission and the competent authority to maintain the required level of security, according to the nature of the personal data processed and the circumstances of the processing, to avoid, as far as possible and always according to the state of the art, their alteration, loss, unauthorized processing, or access. As previously mentioned, the personal data provided will not be disclosed to third parties without prior authorization from the data subject.
6. Notifications and Modifications
As previously indicated, all Users have the right to access, update, and cancel their data, as well as object to their processing. You can exercise these rights or make any inquiries regarding VOY's Privacy Policy through the Contact Form. Due to the continuous evolution of VOY's activities, this Privacy Policy, the Cookie Policy, and the Terms of Use may also be modified. VOY will send Users notices about changes and substantial modifications to these documents via email, or another means that ensures their receipt. In any case, VOY will not modify policies or practices to make them less effective in protecting the personal data of our previously stored customers.
In case of any discrepancy between the translated versions and the Spanish version of this text, the latter will prevail.
Last revision: 4.12.2024