Privacy Policy

PRIVACY POLICY

1. Identity of the Data Controller

This Privacy Policy governs the processing of personal data carried out through the ACTA application, as well as the websites **[www.actaobra.com](http://www.actaobra.com)** and **[www.acta.site](http://www.acta.site)**.

The data controller is:

SKY PROYECTOS TECNICOS, SLU
Tax ID (NIF): B75760140
Registered Office: C/ Fernando el Católico 34, Bajo A, 12005, Castelló de la Plana, Castellón, Spain
Email: [info@actaobra.com](mailto:info@actaobra.com)

The individual responsible for and representing the project is:

RAÚL PALACIOS MOLLÓN
Tax ID (NIF): 20493715W

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2. Personal Data We Process

Through ACTA, we may process the following categories of personal data:

* Identification data: first name and surname.
* Contact details: email address and telephone number.
* Professional information: job title or professional role.
* Construction project data: project addresses, technical information entered by the user, observations, and information related to the management of construction site reports.
* Information relating to parties involved in construction projects: names and any other information entered by the user concerning third parties involved in a project.
* Construction site photographs and documents uploaded by the user.
* Usage, navigation, and device data: technical identifiers, logs, IP address, usage events, analytics, and interaction metrics.
* Data associated with push notifications where required for the provision of the service or the proper functioning of the app.

3. How We Collect Personal Data

Personal data may be obtained:

* Directly from the user when registering for or using the app.
* When the user uploads information, photographs, or documents to a project or report.
* Automatically through analytics technologies, technical logs, and the functional use of the app.
* Through interactions with our communications, contact forms, or support services.

4. Purposes of Processing

We process personal data for the following purposes:

a) User Registration and Account Management

To create user accounts, provide access to the app, authenticate users, and manage user profiles.

b) Provision of ACTA's Core Service

To enable the creation, editing, storage, organization, and export of construction site reports, including the generation of documents and PDF files.

c) Technical Management and Customer Support

To resolve technical issues, provide customer support, respond to enquiries, and ensure the proper operation of the app.

d) Service-Related Communications

To send technical, operational, legal, security, or account-related communications.

e) Analytics and Product Improvement

To analyse how the app is used, monitor performance, identify errors, improve features, and enhance the user experience.

f) Commercial Communications

To send information about ACTA, including news, updates, improvements, products, and related services by electronic means.

5. Legal Basis for Processing

The legal bases applicable to the processing of personal data are as follows:

Performance of a Contract or Pre-Contractual Measures

For user registration, access to the app, provision of the service, generation of reports and PDF documents, and customer support.

Compliance with Legal Obligations

Where processing is necessary to comply with applicable legal obligations.

Legitimate Interests

For maintaining the security of the platform, preventing fraud, improving the service, carrying out reasonable internal analytics, providing support, sending operational communications, and, where permitted by law, sending commercial communications relating to similar services provided by ACTA.

Consent

Where required for certain commercial communications, specific notifications, device permissions, or processing activities that are not necessary for the performance of the service.

Where processing is based on consent, the user may withdraw that consent at any time without affecting the lawfulness of processing carried out before its withdrawal.

6. Commercial Communications

ACTA may send commercial communications by electronic means where the user has provided their consent or where another valid legal basis exists under applicable data protection legislation.

The user may object to receiving such communications at any time by using the unsubscribe mechanism included in each communication or by contacting **[info@actaobra.com](mailto:info@actaobra.com)**.

7. Third-Party Data Uploaded by the User

The app allows users to upload personal data, images, names, documents, or other information relating to third parties, including individuals involved in construction projects or otherwise associated with a project.

In such cases, the user represents and warrants that:

* They have a sufficient legal basis to upload such data to ACTA.
* They have complied with any applicable information obligations towards the data subjects where required by law.
* The processing carried out through the app is lawful and complies with applicable data protection legislation.

The user shall be solely responsible for any third-party content and personal data uploaded or incorporated into ACTA.

ACTA will process such data solely as necessary for the provision of the service requested by the user, including its storage, organization, functional processing, and the generation of documents or PDF files, strictly to the extent required to provide the service.

8. Data Retention

Personal data will be retained for as long as necessary to fulfil the purposes for which it was collected and, thereafter, for the periods required by applicable law or for as long as liabilities may arise.

As a general rule, personal data will be retained for **four (4) years**, unless:

* A longer retention period is required by law.
* The data must be retained for the duration of the relationship with the user.
* The data must be blocked or retained during the applicable limitation periods for legal claims.

Where the user requests the deletion of their account, their personal data will be erased or, where appropriate, restricted or blocked, except where retention is required by law or is necessary for the establishment, exercise, or defence of legal claims.

9. Recipients and Data Processors

Personal data may be processed by service providers acting as data processors or service providers on behalf of ACTA where such services are necessary for the operation of the app, including:

* Hostinger
* Odoo
* Firebase
* Google Analytics
* WhatsApp

These providers will have access only to the personal data necessary to perform their services and will do so subject to the appropriate contractual, confidentiality, and data protection obligations.

10. International Data Transfers

Based on the information currently available, ACTA does not anticipate transferring personal data outside the European Economic Area (EEA).

However, if the use of a technology provider were to involve an international transfer of personal data in the future, ACTA will implement the safeguards required by applicable data protection legislation and will update this Privacy Policy accordingly, where appropriate.

11. Push Notifications and Analytics

ACTA may use push notifications to inform users about matters relating to the operation of the app, operational notices, relevant activity, or other aspects of the service.

ACTA also uses analytics tools to better understand how the app is used, measure performance, identify technical issues, and improve the user experience.

Based on the information currently available, the app does not display advertisements or include third-party advertising.

12. Free Nature of the App

ACTA is a free application.

The fact that the app is provided free of charge does not affect the need to process certain personal data that are essential for its operation, security, customer support, analytics, and the proper provision of the service.

13. Users' Rights

Users may exercise the following rights with respect to their personal data:

* Right of access.
* Right to rectification.
* Right to erasure.
* Right to object.
* Right to restriction of processing.
* Right to data portability.
* Right to withdraw consent where processing is based on consent.

To exercise any of these rights, users may send a request to:

[info@actaobra.com](mailto:info@actaobra.com)

The request should clearly identify the requester and specify the right they wish to exercise.

If a user believes that their data protection rights have not been adequately respected, they may lodge a complaint with the **Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD)** or with the competent supervisory authority in their jurisdiction, where applicable.

14. Account Deletion

Users may request the deletion of their account and the associated personal data by sending an email to **[info@actaobra.com](mailto:info@actaobra.com)**.

Such requests will be handled in accordance with applicable law, without prejudice to the retention of any personal data that must be kept to comply with legal obligations or for the establishment, exercise, or defence of legal claims.

15. Information Security

ACTA implements reasonable technical and organizational measures to protect personal data against loss, alteration, unauthorized access, or unlawful processing, taking into account the state of the art, the nature of the data, and the risks associated with the processing.

However, users should be aware that no platform or electronic system can guarantee absolute security.

16. Children

ACTA is not intended for use by children and does not knowingly collect personal data from minors.

If it becomes aware that personal data relating to a minor has been collected without an appropriate legal basis, ACTA will take the necessary steps to delete such data.

17. Changes to this Privacy Policy

ACTA reserves the right to amend this Privacy Policy at any time to reflect legal, technical, operational, or functional changes.

Where the changes are material, users will be informed through reasonable means.

18. Governing Law

This Privacy Policy shall be interpreted in accordance with the applicable laws of Spain and the European Union relating to the protection of personal data.