Privacy Policy
1. Data controller
The controller of the data collected is Ciclogreen Move and Win, SL, tax ID B90281502 (hereinafter, Ciclogreen), with registered address at Avenida Sabino Arana, 8, 2nd floor, 48013 Bilbao, Spain, owner of the Ciclogreen App and the Website https://ciclogreen.com/.
This Privacy Policy governs the collection and processing of personal data provided by Users when they access, browse, or use the features of the Ciclogreen App or the Website.
2. Data collection, purposes, legal basis, and retention periods:
a. Contact: Users may contact us through the forms provided for this purpose in the App. They must provide their identifying information and the reason, subject, or question. Ciclogreen will use this data to process the inquiry and contact the User.
The legal basis for processing this data is the User's consent.
Data processed for this purpose will be retained for one year, unless other retention periods apply.
Ciclogreen also uses the HubSpot interactive chat on its Website. Its Privacy Policy is available at the following link: https://legal.hubspot.com/privacy-policy.
b. Registration: When registering in the App, Users must provide their identifying information so that the registration can be processed and they can access the features of their personal account.
Access to the App will generally be through a corporate program, so Users must select the organization to which they belong during registration.
The legal basis for processing this data is the User's consent.
Their data will be retained for as long as they are part of the community and remain registered.
Organizations wishing to join the “Business Solutions” provided by Ciclogreen must first contact the owners of Ciclogreen so that a complete, tailored registration can be formalized. In this case, data will be processed on the basis of contract performance.
c. Rankings: Users may participate in corporate challenges with incentives, rewards, or prizes offered by Ciclogreen, the organization to which they belong, or third parties. To participate and subsequently receive rewards, a User ranking must be established. This ranking will be displayed publicly so that the progress of those challenges can be followed. The information shown in these Rankings is limited to the user name or nickname and the kilometers or points (or “ciclos”) recorded.
The legal basis for processing this data is the User's consent.
Ranking data will be displayed and retained while the User participates in the challenge and remains registered in the App.
d. Challenges and rewards: Based on their journeys and activities, Users may earn points (or “ciclos”) and participate in challenges offered in the App. To do so, Users must first be registered and have geolocation enabled on their device.
Users may then obtain rewards by redeeming the ciclos earned through their sustainable travel. These rewards and promotions are offered by Ciclogreen, the organization to which the User belongs, or third parties. Each is therefore subject to different conditions and requires a specified number of ciclos for redemption.
The legal basis for processing this data is the User's consent.
Data will be retained for the period necessary to fulfill contractual obligations and, in all cases, for up to five additional years for tax administration purposes and to cover potential liabilities, unless other retention periods apply.
e. Newsletter: If Users wish, they may provide their identifying information and email address to subscribe to Ciclogreen news, promotions, and updates and periodically receive communications by email or on their mobile device, where applicable.
The legal basis for processing this data is the User's consent.
We will retain the data while the User remains subscribed to our newsletter delivery system. We will then block it for three years due to statutory limitation periods, after which it will be deleted.
f. Blog: Users may post comments on the Ciclogreen blog. The data provided will be processed to manage publication both in the App and on the Website.
The legal basis for processing this data is the User's consent.
Their comments will remain permanently in the App and on the Website unless they request their deletion.
g. Geolocation: Ciclogreen will collect information about the User’s location while the User records an activity (journey) in the app in order to display and save the route, allow the User to accumulate points or “ciclos” based on their activity, and enable participation in incentive programs such as Challenges, Rankings, or Rewards.
The data will be retained securely for 12 months after the User leaves the Application.
Ciclogreen will under no circumstances share this User data at the individual level. It may only be used in aggregated, anonymized form, ensuring the User’s complete privacy.
h. Social Media: Through the App, Users may register for and access services provided by Ciclogreen using their profile on the available social media networks. Ciclogreen will use this data solely and exclusively for the purpose consented to by the User, together with any data to which the User has granted Ciclogreen access.
The legal basis for processing this data is the User's consent.
The data will be retained for 12 months after the User leaves the App.
i. Cookies: The App uses technology that places files known as cookies on the device used to access and browse the App. Cookies may be blocked or disabled at any time through the browser settings. For more information, see our Cookie Policy (https://ciclogreen.com/en/cookie-policy/">https://ciclogreen.com/en/cookie-policy/).
The legal basis for processing this data is the User's consent.
j. Advertising: If the User expressly authorizes it, Ciclogreen may send advertising about services and/or promotions available in the App, such as news and/or new challenges, among other things.
The legal basis for processing this data is the User's consent. The User may withdraw that consent at any time.
The data will be retained for as long as the User remains registered in our advertising delivery system and has not withdrawn their consent.
k. Inbound marketing: If the User expressly authorizes it through the applicable information download form, we may carry out marketing activities based on the company information provided and information obtained from browsing and using Website services, uploaded content, comments, and similar data. We use this information to personalize access to and use of our Website and to send personalized advertising.
The legal basis for processing this data is the User's consent.
The data will be retained for as long as the User remains registered in our advertising delivery system and has not objected or withdrawn consent, unless other retention periods apply. Users may unsubscribe at any time through the addresses provided for this purpose.
3. Disclosure of data to third parties for Users enrolled in organization plans
For Users enrolled in corporate sustainable mobility programs run by companies, city councils, or educational institutions associated with Ciclogreen, their data may be disclosed to the organization with which they are affiliated. The purpose of this disclosure is to allow the companies, city councils, or educational institutions to properly administer the incentives, registrations, challenges, discounts, or rewards they have agreed to as part of the services provided to them. This disclosure of data is, however, based on the User’s express consent.
Mobility data collected by the Ciclogreen app may be provided to third parties for mobility studies. The data supplied will always be anonymous, making it impossible to identify Users. For corporate programs purchased by organizations or other entities, the data will be processed as agreed with that entity and expressly consented to by the User when registering for the program.
4. Disclosure of data to third parties when redeeming rewards
When Users wish to redeem their “ciclos” for rewards, their User name and email address will be disclosed to the provider with which the User wishes to make the redemption so that it can be processed. If the User does not authorize this, they will not be able to redeem points. This disclosure of data is, however, based on the User’s express consent. Users may consult information about the providers and the conditions they impose at any time on the page and in the section for each reward.
5. Exercising your rights
Users may also withdraw consent to processing and exercise their rights of access, rectification, erasure, portability, objection, and restriction of processing by notifying Ciclogreen in an email sent to info@ciclogreen.com or soporte@ciclogreen.com with “Data Protection” in the subject line. On certain occasions, we may ask Users to prove their identity using an official document, for example to prevent third parties from accessing their data.
Users may also communicate any changes in writing or request removal by writing to any of the addresses provided.
Users may file a complaint with the Spanish Data Protection Agency at any time to assert their rights.
6. Changes to the Privacy Policy
Ciclogreen reserves the right to amend its Privacy Policy at any time, in compliance with current data protection legislation and after providing due notice to the interested parties.
7. Language applicable to this Privacy Policy
The language applicable to this Privacy Policy is Spanish. Any version in another language is provided for the User’s convenience and to aid understanding. This Privacy Policy will, however, always be governed by its Spanish version.
If there is any conflict between the Privacy Policy in any language and its Spanish version, the Spanish version will prevail.