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Privacy policy

Privacy policy

Technical document in progress, pending professional and legal review before launch.

Last updated: [PENDIENTE: fecha de aprobación del texto definitivo].

1. Data controller

The data controller for your personal data is Jenifer Lozano Moreno, with NIF 47544280Z and address at Calle Castaño 11, 45930 Méntrida (Toledo), España. You can contact the controller at [PENDIENTE: correo electrónico legal].

2. What data we collect

We collect only the data necessary to provide the service:

  • Registration data: first name, last name, email address, phone (WhatsApp), country, account type and password (hashed). If you register a store: trade name and, optionally, CIF/NIF and website.
  • Account verification: verification codes sent by WhatsApp and your account verification status.
  • Professional verification (KYC): identity document type and number, photographs of the document, selfie and links to your social media or stores.
  • NFC chip orders: shipping zone, country and delivery address.
  • Payments: if you pay by bank transfer or Bizum, the data you provide so we can identify your payment (for example, the receipt). We do not store bank card data.
  • Platform use: registered kits, transfers, comments and technical access logs (IP address and browser) for security and fraud prevention purposes.
  • Kit documentation and activity: invoices, delivery notes, payment receipts and merchandise photos you upload when registering kits; the recipient's phone or email when you declare or request a transfer; the logo, description, photos and links of your professional profile; the baby's name, physical characteristics and photos of the finished doll shown in the passport; your private stock diary notes; the reports and incidents you file or receive, with their attachments; and the notification and security history (logins, verification scans and anti-fraud measures).

3. Why we use it and legal basis

  • Create and manage your account (performance of a contract).
  • Verify your identity via WhatsApp and validate professional accounts (performance of a contract and legitimate interest in preventing fraud).
  • Send you notifications via WhatsApp about your account, payments and transfers (performance of a contract; you can disable them from your dashboard).
  • Manage NFC chip orders and their shipping (performance of a contract).
  • Ensure the security of the platform and prevent fraud (legitimate interest).
  • Comply with our legal obligations (legal obligation).

4. How long we keep it

We keep your data while your account is active. If you request the deletion of your account: [PENDIENTE: plazo concreto]. The identity documents provided for professional verification are kept [PENDIENTE: plazo concreto].

5. Who we share your data with

We do not sell your personal data. We only share it with the providers needed to provide the service: the WhatsApp messaging service (WasenderAPI) to send you codes and notifications; the hosting provider where the platform runs [PENDIENTE: proveedor de hosting]; and the competent authorities when required by law.

6. Your rights

You have the right to:

  • Access the personal data we hold about you.
  • Rectify inaccurate or incomplete data.
  • Erase your data ("right to be forgotten").
  • Object to certain processing.
  • Restrict processing in the cases provided by law.
  • Data portability: receive your data in a structured format.

You may also withdraw your consent at any time (for example, by disabling WhatsApp notifications from your dashboard or requesting cancellation), without this affecting the lawfulness of processing already carried out.

7. How to exercise your rights

Write to us at [PENDIENTE: correo electrónico legal] stating your name, your RebornPass account and the right you wish to exercise. We will reply within the legal time limit. If you consider that we have not handled your request correctly, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).

8. Minors

[PENDIENTE: edad mínima para usar RebornPass y política aplicable a menores].

9. Changes to this policy

If we make significant changes to this policy, we will notify you on the website or by email or WhatsApp before the changes take effect.