DWP PRIVACY POLICY


DIGITAL WELCOME PACK, SOCIEDAD LIMITADA (“DWP”, “we”, “our” or “us”) provides its customers and users (“User(s)” or “you”) with a mobile application platform and web services providing welcome services information and enabling Users to plan and optimize their professional travelling and location stay (the “Services”). DWP is committed to your privacy. This Privacy Policy is intended to inform you of our collection, use, disclosure, retention, and protection of your personal information when using our Services.

Our Services include our websites at https:\\www.digitalwelcomepack.com and any additional websites owned and operated by DWP or its affiliates (the “Site(s)”), our downloadable mobile application(s) (the “App”) and additional services.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use available at legal@dwpack.eu which this Privacy Policy is incorporated thereto by reference (together, the “Terms”).

Please read this Privacy Policy carefully before accessing and using our Services. By Accessing or using our service you are accepting the practices described in this Privacy Policy. If you disagree with any term provided herein, you may not access or use the Services. Please note: you are not obligated by law to provide us with any personal information.


1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

Personal information.

Personal information is information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or information relating to an identified or identifiable natural person which may be of a private or sensitive nature. Under certain applicable laws identification of an individual also includes any information which associates an individual with a persistent identifier such as a media production company contractor, name, an identification number, telephone, production, city, professional functions, production Project, etc.

Personal information does not include information that has been anonymized or aggregated so that it can no longer identify or be used to identify a specific natural person.

What and when do we collect personal information?

We collect personal information from your contractor or employer and from any devices (including mobile devices) you use when you install or have the App installed (or pre-installed) on your device, or when you use or access our Services, register for an account with us, provide us with information such as your favorites and travel habits, provide us information on a web form, run searches on our Services, update or add information to your account, or through correspondence you conduct with us.

More specifically we collect and use the following categories and types of information:

Personal information we collect automatically when you use our Services:

Information collected previously and when installing the App

We collect personal information concerning you from your media company employer or contractor who have assured us that they have either obtained your consent for the provision of such information or that you have freely and publicly provided such information yourself.

When you install the App (or have the App installed or pre-installed) on your mobile device, DWP will set up a user account associated with that mobile device and create a User ID for you. This is a unique identifier generated by us in accordance with this Privacy Policy, which is necessary in order for us to provide you with our Services. After installation of the App, we will collect and use the User ID, together with certain other information including certain device information which may include your device ID or other unique identifier, advertising ID, unique device token, device type, operating system (including version and settings), as well as your device screen resolution and keyboard language, all in accordance with this Privacy Policy. We may link this information with the account created in connection with your mobile device and User ID.

Usage Information

We receive information from you when you access and use our Services, as follows: your IP address, tokens of social networks, if it is made avalaible, you choose to connect to your account (as described below), information regarding your clicks, views and engagement with the Services and with advertisements we may display on the Service, information concerning your traffic to and from the Services, your referral URL, our communications with you, your public transit historical searches on the Services, information about your use and your interaction with our Services, including the duration of such use; and your in-app settings if available.

Geo-Location Information and other Sensors data

DWP, unless you agree, may not automatically collects any location information such as your geolocation and your route and travel information (for example, routes and times of travel from one destination to another). In order to provide you with some of our Services, when using the App, we will request you yout authorization for collecting detailed location, including GPS signals and other device sensor data such as gyro/oscilloscope, sent by your mobile device on which the Service is installed and activated.

DWP should use this location and sensor information only to provide you with the Service.

Cookies & Similar Technologies

We perform some of the automatic collection described above through use of cookies, web beacons, software development kits (or SDKs), application program interfaces (or APIs), unique identifiers, and similar technologies which allow us and our advertising and analytics partners to collect information about the pages and screens you view, the links or ads you click, and other actions you take when using our Services.

Please take into consideration that certain portions of such above mentioned information may also be collected from your device or software, when the Services are running in the background, i.e. when they have been launched but are not actively used.

For more information about our use of these technologies, and how you may exercise control over them, see our policy of cookies legal@dwpack.eu.

Please keep in mind that most mobile devices and operating systems allow you to control or disable the use of certain collectable information including location services by applications, in the device’s settings menu.

Personal information you give us when you use our Services:

Generally, this category refers to any information, data or content you actively and voluntarily create, upload, or provide to us through our Services.

Account Information.

Only if your media production company set up a registered SWP User Account for you, such an account may allow you to enjoy the App Services because they are only available to registered DWP Users.

Actively Provided Points of Interests (POI) Data

In addition, you may choose to upload specific destinations and POIs such as your hotel address, work address or other favorite destinations in order to personalize the Service.

Additional Content you Choose to Share with us when using the Services

You may choose to upload to the Service User Content, such as images, text, reviews and reports of data gaps or errors, and other types of content which you actively choose to provide. We also collect your responses to surveys we may send you on our behalf or on behalf of our partners.

Personal information collected from other sources:

Third Parties

We may collect personal information concerning you from third parties who have assured us that they have either obtained your consent for the provision of such information or that you have freely and publicly provided such information yourself.

Information we derive

We may derive information or draw inferences about you based on the information we collect. For example, we may infer your location based on your IP address, or we may make inferences about your preferences and activities you may enjoy based on, among other things, your past location searches and other usage of the App.


2. DATA CONTROLLER OF YOUR PERSONAL INFORMATION

DIGITAL WELCOME PACK, SOCIEDAD LIMITADA is the data controller of the Personal Information collected in connection with the use of DWP’s services.


3. HOW WE USE YOUR INFORMATION

Legal basis for use – We collect, process and use your information for the purposes described in this Privacy Policy based on at least one of the following legal grounds:

When Performing this Agreement or the Agreement signed with your employer or contractor: We collect and process your personal information in order to provide you with the Services, following your acceptance of these Terms, and to maintain and our Services to you.

With your consent: We ask for your agreement to process your personal information for additional specific purposes and you have the right to withdraw your consent at any time. For example, we may ask for your consent to provide you with personalized content or advertisements, including through the use of cookies.

Legitimate interests: We process your personal information for our, and/or our third-party partners’’ legitimate interests, while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our Services; protecting against harm to the rights, property or safety of our properties, our users or the public as required or permitted by law; for the development and enhancement of our Services; to develop new features for our Users; to personalize the Services in order to deliver better user experience; for enforcing legal claims, including investigation of potential violations of this Privacy Policy; in order to comply and/or fulfil our obligation under applicable laws, regulations, guidelines, industry standards and contractual requirements, legal processes, subpoena or governmental requests, as well as our Service Terms.

Purpose of Use

We may use information that we collect about you for the following purposes:

  • to provide you with and to operate the Services, including for aggregation, statistical and research purposes and to create and use aggregated anonymous data which is necessary to maintain, develop and improve DWP’s services, including to determine navigation and routes, connect riders, and, at times, calculate costs of trips.
  • in order to determine and ascertain User Accounts, verify User identity and enable Users, if relevant, to transfer or receive payments, which may include calculation of the costs for such services.
  • to track your trips and aid you with navigation
  • to process your payment for various features, such as ticketing.
  • to personalize the Services and the content provided to you, to customize your user experience with the Services, to communicate with Users about their trips, including transport recommendations based on your preferences and to enable you to retrieve your information.
  • to develop, improve and customize the Services, the experience of other Users and the offerings available through the Services.
  • to be able to contact Users for the purpose of providing them with technical assistance and support, to handle requests and complaints, and to collect feedback in connection with our performance of the Services and in connection with public transportation needs.
  • to send you updates, notices, announcements, and additional information related to the Services, such as changes in public transportation services or closures.
  • to be able to reply to User online queries in connection with performance of the Services.
  • to customize and improve the Service’s accuracy and interface.
  • to comply with any governmental agencies’ legal requests or court orders, and/or with any applicable law, rule or regulation, such as reporting an abusive user or fulfilling tax regulation obligations with regard to promotions and which require the use of User data.
  • to use the information to create statistical, aggregated or anonymous data which may be used at our discretion for any purpose
  • to allow us, and our selected third parties (as further detailed in this Privacy Policy), to provide you with personalized interest based advertisements, which may be served either on the Services and/or on other websites, apps, and services, and to better understand your activity.

We may also use the data we collect to market our services to our Users. This includes sending Users communications about DWP services, features, promotions, sweepstakes, studies, surveys, news, updates and events. We may also send communications to our Users to provide promotional information and participation in the promotions, as well as information regarding offers, discounts and promotions related to our services and the services of our collaboration partners.

We may also use the information we collect to send Users communications about products and services offered by our partners, but we do not sell your email address, name, or other identifying information to, or share such information with, such partners or others for purposes of their own direct marketing or advertising, except as set forth in this Privacy Policy.


4. TO WHOM WE SHARE PERSONAL INFORMATION

We may share your personal information with third parties (or otherwise allow them access to it) only in the following manners and instances:

Service Providers/Data Processors

We perform some of the automatic collection described above through use of cookies, web beacons, unique identifiers, and similar technologies which allow us to collect information about the pages and screens you view, the links or ads you click, and other actions you take when using our Services.

DWP has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, database and server co-location services (such as AWS), data and cyber security services, payment processors, fraud detection and prevention services, data analytics services, App analytics tools including session replay records for usability and functionality monitoring and analysis, services for measuring our Services attribution and the efficacy of our publication and marketing efforts (such as Appsflyer), e-mail distribution and monitoring services, and our business, legal and financial advisors. These service providers may receive or otherwise have access to our Users’ personal information, depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes.

Third Party Advertising Partners

We may allow third parties to serve you advertisements through the Services. This Will only possible if the media production company agrees. These third parties, may use software development kits (SDKs), cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other services, websites, and applications. This information may include advertising identifiers, other device identifiers, cookies, your IP address, location data (including segmented data and/or derived location data), web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by us and selected third parties to, among other things, to provide you with personalized interest-based advertisements on the Services and other websites, apps, and services and to better understand your activity.

We may also work with selected third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you relevant advertising that is personalized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

You maintain control over your information and can manage your preferences related to our use of cookies and similar technologies used, among other things, to provide you with personalized interest-based advertisements and to analyze your use of our Services by visiting our Cookie Policy for web users or the ads preferences tab under the privacy preferences section in your Settings on the App. We may ask your consent to allow tracking before allowing our partners to engage in personalized advertising. If you consent, you may later withdraw your consent at any time by contacting us at: legal@dwpack.eu

Third Party Services

DWP may offer you the option to link DWP to third party services that may be useful to you, such as ride hailing services. Where DWP detects that an integration may be available (either because a third party service attempts to link to DWP, DWP detects an installed service on the device which has an integration option or you request a particular integration), DWP will ask for confirmation to connect the accounts. If you choose to connect the accounts or the media production company, DWP will ask for your permission to share data with the third party service. DWP is not responsible for the third party service’s use of such data. You can disconnect DWP and the third party service at any time and DWP will cease sharing data with that service from the point of disconnection onwards.

Cross Border Data Transfers

We may need to transfer your personal information to countries where we and/or our service providers opérate. The law regulations may be different from the country in which your information is originated and where data Will be handle. By using our Services, you agree, as you alrready have done with the production company, to any such transfers. In order to protect your information when being transferred across borders, we put in place agreements with our service providers to ensure a level of privacy consistent with the terms of this Privacy Policy.

With regards to the collection, use of and retention of your personal information which is transferred from the United States to the European Economic Area (“EEA”) and viceversa, and/or other jurisdictions, your production company contractor ensures to DWP that it maintains compliance with all applicable laws in respect of such transfers and uses standard contract clauses approved by the European Commission or other suitable safeguards in our data protection agreements with the relevant service provider to manage such data transfers and protect the privacy and security of your information.

Governmental/Law Enforcement Agencies and Legal Requests or Duties

We may disclose or otherwise allow access to your personal information pursuant to a legal request, such as an Administrative order, search warrant or court order, or otherwise in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud or other wrongdoing.

Protecting Rights and Safety

We may share your personal information with others, with or without notice to you, if we have a good faith belief that this will help protect the rights, property or personal safety of DWP, any of our Users or any member of the general public.

DWP Subsidiaries and Affiliated Companies

We may share personal information internally within our family of companies for the purposes described in this Privacy Policy. In addition, should DWP or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of their assets, your personal information may be shared with the parties involved in such event.

For the avoidance of doubt, DWP may share your personal information in additional manners, pursuant to your explicit approval or following the terms of our agreement with your media production company contractor with your conformity . Additionally, we may transfer, share or otherwise use anonymized, aggregated or non-personal information in our sole discretion and without the need for further approval.


5. WHERE DO WE STORE USER’S PERSONAL INFORMATION

Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and service providers in Spain, a country offering an adequate level of protection in accordance with European Commission Decision 2011/61/EU (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011D0061) of 31 January 2011 for the management of the App platform, in Spain, and, as necessary, in secured cloud storage provided by our third party service providers.

While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that we, our affiliates and our third party service providers that store or process your personal information on our behalf are each committed to keeping your information protected and secured pursuant to this Privacy Policy and prevailing industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

You hereby accept the place of storage and the transfer of information as described above.


6. SECURITY

We take great care in implementing and maintaining the security of DWP’s Services and our User’s personal information. DWP employs industry-standard procedures and policies to ensure the security of its Users’ personal information and to prevent unauthorised access, disclosure or alteration of any such information. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres and information access authorization controls. We cannot, however, guarantee that unauthorized access will never occur.


7. COMMUNICATIONS FROM DWP

Service Messages

DWP may contact you with information regarding our Services or your use thereof. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, including changes to these Terms, transactions performed, payment issues, service maintenance, etc. You will not be able to opt-out of receiving such service messages.

Promotional and Surveys Messages

In addition to communications that are an inherent part of our Services, occasionally we may also use your contact information to contact and notify you about new related services and special opportunities or promotions we think you will find valuable and may also contact you in connection with surveys we conduct with respect to our services or in connection with general public transportation issues, either on our own behalf or on behalf of our partners. We may contact you through e-mail, push notifications, through notices on the Services themselves or through any other contact methods available to us, including with the help of our service providers.

Accordingly, we shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages, web chat, marketing calls and similar forms of communication, with your prior written consent.

If you wish not to receive such promotional messages or calls, you may notify DWP at any time by e-mailing us at info@dwpack.eu, or by following the “unsubscribe” or “stop” instructions contained in the promotional communications you receive. As for messages we send through push notifications, you may opt-out of receiving such notification by changing your device or App settings.


8. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

If you are an European Union (“EU”), EEA, UK or Switzerland based individual and to the extent entitled under the applicable law of your jurisdiction, you may contact us to exercise your right to access your personal information, to request that we make corrections to your personal information that you have stored with us, to object to any form of processing, or to have such personal information deleted or exported to you or a third party of your choice in a portable copy. To exercise any of the above rights, please send us an e-mail to legal@dwpack.eu and we will respond within a reasonable timeframe and in accordance with applicable laws and regulations.

In certain circumstances, you may request that the processing of your data be restricted, in which case DWP will only keep it for the exercise or defense of legal claims.

We also remind you that, as a User, you may oppose the processing of your data for promotional or advertising purposes at any time.

Furthermore, you have the right to withdraw your consent at any time; however please note that such withdrawal will not affect the lawfulness of the processing based on your consent prior to its withdrawal.

To exercise the rights regarding data protection noted above, or revoke the consents previously given, you may write to:

DIGITAL WELCOME PACK, SOCIEDAD LIMITADA
CALLE ALZINA, NUM. 43, 28054 MADRID - (MADRID), or send an email to DWP at legal@dwpack.eu, indicating “Data Protection” as a reference.


9. HOW LONG MAY WE KEEP YOUR PERSONAL INFORMATION

We will retain your personal information for as long as your contractor maintain an agreement with us related to you and our services or as otherwise necessary to provide you the Services. We will also retain your personal information as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, to enforce our agreements and/or to protect our legitimate interests.

Where we no longer need to process your personal information for the purposes set out in this Privacy Policy or following your request to delete your personal information, we will delete or anonymize your personal information from our systems.


10. MINORS

To use our Services, you must be over the age of sixteen (16). DWP does not knowingly collect personal information from individuals under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that individuals under the age of sixteen (16) are not using the Services.


11.CHANGES TO THE PRIVACY POLICY

The terms of this Privacy Policy will govern the use of the Services and any information collected therein. DWP reserves the right to change this Privacy Policy at any time. We encourage you to re-visit this page frequently to stay informed about your rights and choices. In the event of any substantial change of this Privacy Policy, we will provide you with reasonable prior notice via any of the communication means available to us, or by posting a prominent notice of the change on the Site. After this notice period, all amendments to this Privacy Policy shall be deemed accepted and shall become effective. Except if and as stated otherwise, our most current Privacy Policy shall apply to all personal information described in such Privacy Policy.


12. CONTACT US; DATA PROTECTION OFFICER; EU REPRESENTATIVE

If you have any questions about this Privacy Policy or DWP’s privacy practices, please contact us at legal@dwpack.eu

DWP has appointed a Data Protection Officer for monitoring and advising on its ongoing privacy compliance and to serve as a point of contact on privacy matters for data subjects and supervisory authorities. To contact DWP’s Data Protection Officer, please email us at legal@dwpack.eu.

You maintain the right to file a complaint with your national data protection authority if you have a concern about our privacy practices, including the way we handle your personal information.

By contacting us, you represent that you are free to do so and that you will not knowingly provide information that infringes upon the rights of third parties, including any intellectual property rights. You further acknowledge that, notwithstanding anything herein to the contrary, any and all rights, including without limitation any intellectual property rights in such information provided, shall belong exclusively to DWP, and we may use or refrain from using such information at our sole discretion.