Privacy Policy

1. Data Controller

In compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (GDPR), and Organic Law 3/2018 of 5 December on Personal Data Protection and guarantee of digital rights (LOPDGDD), we inform you that the data controller is:

• Company name: Orbit Advices S.L.
• Tax ID (CIF): B66535642
• Address: Av. del parc, 1 - 08402 Granollers (Barcelona), Spain
• Email: consultor@orbitadvices.com
• Website: https://directivo.app

2. Data we collect and purposes

2.1 Website browsing

When you visit directivo.app, our servers may automatically log technical information such as your IP address, browser, operating system and pages visited. This information is used solely for statistical and security purposes and is not linked to any identifiable personal profile.

2.2 Google Analytics (with your consent)

If you accept analytical cookies, we use Google Analytics 4 to measure traffic and visitor behaviour on the website. Google may transfer this information to third parties when legally required to do so, or when such third parties process the information on Google's behalf.

You can consult Google's privacy policy at: policies.google.com/privacy

2.3 Contact by email

If you contact us by email, we will process the data you provide (name, email address and message content) solely to handle your enquiry.

• Legal basis: Legitimate interest (Art. 6.1.f GDPR) or consent (Art. 6.1.a GDPR).
• Retention period: Until your enquiry is resolved and, thereafter, as long as required by applicable law.

2.4 DIRECTIVO app data

The DIRECTIVO app is distributed via the Google Play Store. Orbit Advices S.L. does not directly collect personal data through the app beyond what is strictly necessary for the service to function. In-app purchases are processed via Google Play Billing and payment data is managed exclusively by Google.

For more information on how Google handles your data on Google Play: play.google.com/about/privacy-security/

3. Legal basis for processing

Processing activity	Legal basis (GDPR)
Web analytics statistics (GA4)	Consent — Art. 6.1.a
Essential technical cookies	Legitimate interest — Art. 6.1.f
Responding to email enquiries	Legitimate interest — Art. 6.1.f
Compliance with legal obligations	Legal obligation — Art. 6.1.c

4. Retention periods

Your data will be retained for as long as necessary to fulfil the purpose for which it was collected and, in any event, for the periods required by applicable law. Upon withdrawal of your consent, we will cease processing the relevant data unless another legal basis justifies its continued processing.

5. International data transfers

Google Analytics may involve the transfer of data to Google LLC servers located in the United States. This transfer is carried out under the Standard Contractual Clauses approved by the European Commission and within the framework of the EU-US Data Privacy Framework. You can consult Google's safeguards at: privacy.google.com/businesses/compliance/

6. Your rights

As a data subject, you may exercise the following rights against Orbit Advices S.L. by sending an email to consultor@orbitadvices.com with a copy of your ID or equivalent document:

• Access: Obtain confirmation of whether we process your data and, if so, access to it.
• Rectification: Request the correction of inaccurate or incomplete data.
• Erasure ("right to be forgotten"): Request deletion of your data when it is no longer necessary or you withdraw consent.
• Restriction of processing: Request that the processing of your data be restricted in certain circumstances.
• Data portability: Receive your data in a structured, commonly used format to transmit it to another controller.
• Objection: Object to processing based on legitimate interest.
• Withdrawal of consent: At any time, without retroactive effect, for processing based on consent.

If you believe that the processing of your data infringes data protection regulations, you may lodge a complaint with the Spanish Data Protection Agency (AEPD): www.aepd.es

7. Security

Orbit Advices S.L. implements appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction or accidental disclosure, in accordance with Article 32 of the GDPR.

8. Changes to this policy

We reserve the right to modify this Privacy Policy to adapt it to legislative or functional changes. Modifications will be notified on this page with the date of update indicated. We recommend you review it periodically.

9. Contact

For any queries related to data protection, you can contact us at: consultor@orbitadvices.com