Privacy Policy

1st Layer – Application

Navilens Tech SL (NaviLens) will process your personal data in order to provide the requested service, ensure the correct functioning of the application, and manage your preferences and communications. You can exercise your rights of access, rectification, deletion and portability of your data, limitation and opposition to their processing, as well as not to be subject to decisions based solely on automated processing, where applicable, at dpd@navilens.com.

COPPA Warning

This application may collect data from children under the age of 13 residing in the United States only under the legal exception of Support for Internal Operations (functionality and security). Any changes to this exception will require verifiable parental consent under COPPA.

We recommend that you read the privacy policy and terms of use before providing us with your personal data.

2nd Layer

Contents

  • Who is responsible for the processing of your data?
  • What kind of data do we process?
  • For what purpose do we process your personal data?
  • What is the legitimacy for the processing of your data?
  • How long will we keep your data?
  • Will we share your data with third parties?
  • What are your rights when you provide us with your data?
  • Changes to the Privacy Policy
  • Cookie Information

Navilens Tech SL (NaviLens) informs you of its privacy policy applied to personal data. The use of the website does not imply that the user must provide any information regarding their identity and cannot be associated with a specific user by the company. If personal data is provided, it will be collected and used in accordance with applicable regulations.

Who is responsible for the processing of your data?

  • Controller: Navilens Tech SL (dba NaviLens)
  • CIF: B73351520
  • Postal address: Calle Central Nº10, Edificio Azor, Planta 4ª, 30100, Murcia, Spain
  • Email: info@navilens.com
  • Data Protection Officer: dpd@navilens.com

What kind of data do we process?

1. Data collected for the provision of the service

  • Content presentation preferences selected by the user (accessible route, pictograms, etc.)
  • Date and time of marker reads
  • Identification code of the marker read
  • App install identifier (random identifier not linked to the device)
  • User email (if previously entered)
  • Device make, model, and operating system version
  • Language set in the app
  • App version
  • Network operator data

2. Technical infrastructure data (Internal Operations)

IP address is recorded exclusively at the infrastructure layer and used only for:

  • Forensic analysis and internal security auditing when legally required
  • Monitoring platform operation and detecting security attacks or anomalies
  • Updating security rules and protecting service integrity

Not used for:

  • User behavior analysis
  • User profiling or individual identification
  • Personalized or behavioral advertising

Access to this information is restricted exclusively to technical system administrators.

3. Device permissions

  • Camera: Required for marker reading. Image processing is performed entirely on the device and is not sent to NaviLens servers or third parties.
  • Notifications: Used in certain integrations.

4. Contact details

If you contact us with questions or suggestions, we may process identification data such as name, surname, language, country, and contact details.

For what purpose do we process your personal data?

  • Responding to requests:

    We only process data strictly necessary to manage or resolve your request.

  • Marker reading:

    To provide environmental information and guidance through digital marker scanning.

  • Notifications:

    When necessary for application functionality or updates.

  • Sharing your tags:

    If you choose to share tags, related personal data will be stored exclusively for that purpose.

  • Social media management:

    To respond to messages and manage contact lists.

  • Technical infrastructure maintenance and security:
    • Ensuring proper functioning of the application
    • Preventing and detecting security threats
    • Forensic analysis when legally required
    • Updating security rules
  • Usability and quality analysis (Cookies):

    To analyze browsing behavior for statistical and improvement purposes.

What is the legitimacy for the processing of your data?

  • Information requests: Consent
  • Marker reading: Contractual basis
  • Notifications: Consent
  • Sharing tags: Express consent
  • Social media: Consent
  • Technical infrastructure data:
    • Legitimate interest (Art. 6.1.f GDPR)
    • Legal obligation (Art. 6.1.c GDPR)
  • COPPA compliance (U.S. children under 13):

    Collection of technical data exclusively for internal operations qualifies as “Support for Internal Operations” under 16 C.F.R. § 312.2 and does not require verifiable parental consent.

  • Cookies: User consent and legitimate interest where applicable

How long will we keep your data?

  • Information requests: Time necessary to respond + 1 year
  • App user data: Until account deletion + 4 years for legal obligations
  • Technical infrastructure data:
    • IP logs retained up to 5 years for security and compliance
    • Automatically deleted afterwards unless legally required
    • For children under 13 (U.S.), deleted when no longer necessary for internal operations (16 C.F.R. § 312.10)
  • Social media: While you remain a follower

Will we share your data with third parties?

  • Infrastructure providers:
    • Access to usage and operating data
    • No access to IP address
  • Analytics providers:
    • Access to aggregated non-identifying data
  • Notification providers:
    • Access to device identifier for service notifications only

COPPA Limitation

For children under 13 residing in the United States, data sharing is strictly limited to what is necessary for application operation. IP addresses are never disclosed to third parties.

What are your rights?

You may exercise your rights free of charge by contacting dpd@navilens.com.

  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restriction of processing
  • Right to withdraw consent
  • Right to object

You may also lodge a complaint with the Spanish Data Protection Agency: https://www.agpd.es

Specific rights for children under 13 (COPPA)

  1. Right to review the child’s data
  2. Right to request deletion
  3. Right to refuse disclosure to third parties
  4. Right to withdraw consent
  5. Right not to direct marketing contact

Parents may contact dpd@navilens.com to exercise these rights.

Changes to the Privacy Policy

We may update this Privacy Policy from time to time and will notify users of significant changes. If changes affect data of children under 13 in the U.S., verifiable parental consent will be obtained where required under COPPA (16 C.F.R. § 312.5).

Cookie Information

We use cookies and similar technologies to facilitate navigation, analyze usage, and improve services. Please refer to our Cookie Policy for detailed information.