Privacy Policy

1. Data controller

• Owner: CLOUDANA SOLUTIONS, S.L. (“Snurkel”)
• Tax ID (NIF): B-67146324
• Address: Avinguda Bon Pastor 15, 08380 Malgrat de Mar (Barcelona)
• Phone: 938 553 938
• Email: info@snurkel.com

2. Data we process

• Registration data (only if you create an account): username, email address and password (stored encrypted).
• Location: approximate or precise location, only with your permission, to show you news and posts from your area.
• Content: posts, photos, comments and reactions you share in the app.
• Usage and technical data: device type, operating system, language and identifiers needed for the operation and security of the service.
• Use without an account: you can use Snurkel to read without registering. In that case we generate a random identifier, stored on your device and on our servers, with no name or email, to remember the area you chose between one use and the next. It is not combined with other data or shared with third parties. If you later create an account, that identifier is deleted.

3. Purposes and legal basis

• Providing the service (managing your account and content): performance of the contract.
• Showing geolocated content based on your location: your consent, which you can withdraw at any time from your device or app settings.
• Ensuring security and preventing abuse: legitimate interest.
• Complying with applicable legal obligations.
• Remembering your area when you use the app without an account: provision of the service you requested (art. 6.1.b GDPR). The identifier is essential for the app to work without registration.

4. Usage analytics

To understand how Snurkel is used and to improve it, we measure activity inside the app: which screens are visited, which features are used (creating a zone, posting, sharing) and basic technical data about the device.

• Only with your consent. This measurement is enabled only if you authorise it. The first time you use the app we ask you, and until you accept no data is sent.
• You can change your mind. Withdraw your consent at any time in your profile settings: measurement stops and we stop linking that data to your account.
• Provider. The service is provided by Google (Firebase Analytics / Google Analytics), acting as data processor. This involves an international transfer of data to the United States, covered by the European Commission’s standard contractual clauses and the EU–US Data Privacy Framework.
• No advertising, no tracking. We do not use this data for advertising, we do not sell it and we do not track your activity across other apps or websites. Ad personalisation signals are disabled.

Legal basis: your consent (Art. 6(1)(a) GDPR).

5. Advertising and install attribution

Snurkel advertises on TikTok and on Meta (Facebook and Instagram). To know which ad brought each person to the app — and to avoid paying to show it again to someone who already has it — we use the TikTok Business SDK and the Meta SDK.

• Only with your consent, and it is a separate permission. Agreeing to usage analytics is NOT agreeing to this. We ask you separately and, until you accept, the SDK is not even loaded.
• What is sent. App opens and, at most, conversion events (sign-up, login, subscription). We do not send your email, your user ID, or what you read. The screens you visit are not sent either: that SDK option is deliberately switched off.
• On iOS. If you accept, the system will also ask for tracking permission (ATT). Our question comes first and Apple’s second; if you deny it, attribution is poorer but the app works exactly the same.
• Providers. TikTok (TikTok Technology Limited / ByteDance) and Meta (Meta Platforms Ireland Limited), each acting as an independent controller for its own advertising measurement purposes. This involves international transfers of data outside the EEA, covered by the European Commission’s standard contractual clauses.
• You can change your mind. Withdraw your consent at any time from your profile settings.

Legal basis: your consent (Art. 6(1)(a) GDPR).

6. Retention

If you have an account, we keep your data while it is active or until you exercise your right to erasure. After that, it will be blocked for the legally required periods and then deleted. If you use Snurkel without an account, the identifier and the associated area are deleted automatically after 6 months without opening the app.

7. Recipients and processors

We do not sell your data. To provide the service we rely on providers acting as data processors with the safeguards required by the GDPR, including hosting and file storage services (including object storage at Hetzner, in the European Union) and communications. Where a provider is outside the EEA, appropriate safeguards will be applied (standard contractual clauses or others provided by law).

8. Minors

Snurkel is not intended for children under 14. If you are under that age, you must not register or provide personal data. If we detect an account belonging to a child under 14, we will delete it.

9. Your rights

You can exercise your rights of access, rectification, erasure, objection, restriction of processing and portability by writing to info@snurkel.com with the subject “DATA PROTECTION: RIGHTS OF THE DATA SUBJECT”. If you believe we have not handled your request properly, you may lodge a complaint with the Spanish Data Protection Agency (aepd.es).

10. Changes to this policy

We may update this policy. We will inform you of relevant changes through the app or the website.