1Responsible and description

1.1.- Responsible

The party responsible for the treatment of this website and its services is Meal Pass Mallorca, S.L. (hereinafter Meal Pass), with address at Avenida Albufera 23, 07458 Muro, Balearic Islands, Spain.

Tax ID: B72973936
E-mail: contacto@mealpass.com

1.2.- Description

Acceptance of the Meal Pass privacy policy (hereinafter "
Privacy Policy"), is a necessary condition for the use of our website, application, services and social networks (hereinafter the "Service").

This Privacy Policy governs the collection, processing and use of your
personal and non-personal information as a user of Meal Pass, as of the
effective date shown in the header.

In processing your personal data, Meal Pass complies with current legislation, local and European
and its implementing regulations.

2.- Information gathered

The Service can be used without providing any data, although in order to contract services through our platform you will need to provide us with some personal data. The information (personal or non-personal) collected by the Service may vary accordingly.

Personal and non-personal information collected by the Service will come to us in three ways: 1)
automatically collected information; 2) information you voluntarily provide to us; and 3)
provided by third parties.

2.1.- Automatically collected

Usage Information and Logs. We collect information about your activity on our Services, such as service, diagnostic and performance data. This includes information about your activity (including how you use our Services and how you interact with others through them, the settings options you chose, and the timing, frequency and duration of your activities and interactions), log files, as well as diagnostic, error, website and performance logs and reports. It also includes information about when you registered to use our Services, the features you use, as well as the last time you used our Services.

Device and connection information. We collect specific device and connection-related information when you use or access our Services. This includes information such as hardware model, operating system, battery level, signal strength, browser and/or mobile network. It also includes connection information, such as phone number, mobile carrier or Internet service provider, language and time zone, and IP address, as well as transaction data and identifiers, such as device identifiers.

Location Information. We collect precise or approximate location data from your mobile device if you use our location or location features. We use a variety of technologies to determine location, including IP addresses, GPS, Bluetooth signals, and information about nearby Wi-Fi hotspots, beacons and phone antennas.

Transaction Information. We collect transaction data related to the use of our services, including information about the type of services requested or provided, the date and time the service was performed, the amount charged, and the method of payment. In addition, if someone uses a user's promotional code, we may associate it with that person.

Cookies. We use cookies to operate and provide our Services, including to provide you with our web-based Services, improve your experiences, understand how they are used and personalize them. Cookies also help us understand what our most popular Services are and allow us to show you relevant content related to our Services. We may also use cookies to remember choices you have made, such as language preferences, to provide you with a more secure experience and to otherwise customize our Services based on your interests. Please see our Cookie Policy for more information on how we use cookies to provide you with our Services.

In addition, Meal Pass uses Google Analytics, an analytical service provided by Google, LLC. domiciled in the United States with headquarters at 1600 Amphitheatre Parkway, Mountain View, California 94043. For the provision of these services, they use cookies that collect information, including the IP address of the user, which will be transmitted, processed and stored by Google on the terms set out in the web www.google.com. Including the possible transmission of such information to third parties for reasons of legal requirement or where such third parties process the information on behalf of Google.
In any case, you can disable Google Analytics cookies from here.

2.2.- The one you provide voluntarily

This information will consist of:

As required by Meal Pass to build your User Profile: We collect data when you create or update your Meal Pass account. The information we collect includes your name, email address, phone number, username and password, address, date of birth, and banking or payment information (including information related to payment information).

All data are mandatory.

The information required by Meal Pass to complete the provision of the service and perform the corresponding billing: name or company name, email, address, telephone, tax and bank details.

All data are mandatory.

If you contract a service on behalf of another person through the platform, you guarantee that you have legitimately obtained the personal information of those other persons before providing us with their data.

The information, personal or not, that could contain the messages sent through the contact or opinion channels established through e-mail, for example your name, alias or e-mail address.

The information, personal or not, that could contain the comments and evaluations to the service and the platform, for example your name, email and message.

The personal information required to subscribe to the newsletter, such as your email address.

Your photo, name, nickname or geolocation if you decide to participate in any of our social media activities.

Technical Support. You may provide us with information regarding your use of our Services, including copies of your messages, and how to contact you so that we can provide you with technical support. For example, you may email us with information regarding the performance of our website or other problems you are experiencing.

Demographic Data. We may collect demographic data about users, for example, through surveys.

2.3.- That provided by third parties

This information will consist of:

The information provided by payment systems or credit card processors, such as the time of purchase or the amount of the purchase.

Provided by the various suppliers, resellers or commercial agents with whom you interact through Meal Pass or through whom you purchase Meal Pass products or services. They provide us with information about their interactions with you in connection with the provision of the service, such as service engagement or name and time of service provision. Please note that when businesses use third-party services, their own terms and privacy policies apply to your use of those services and their use of your information.

Provided by social networks or similar services.

User feedback. We receive feedback from users, such as ratings and comments.

Third-party services. We allow you to use our Services in connection with third party services. If you use our Services in conjunction with such third party services, they may provide us with information about you.

Public Sources.

3.- Rights and purposes

Please note that the completion of the forms is voluntary. Now
well, if you do not fill in the required fields (usually marked with an asterisk), the
use of some functions of the Service will not be possible or will be limited.

The personal data you provide will be incorporated and will be processed in the Meal Pass Register of Processing Activities, in order to respond to your requests, provide the requested service and keep you informed on matters relating to the activity of the company and its services.

You may at any time exercise your rights of access, rectification, deletion,
limitation of processing, opposition and portability of your personal data
by sending an e-mail to: contacto@mealpass.com.

Or the postal address: Avenida Albufera 23, 07458 Muro, Balearic Islands, Spain.

In both cases you must identify yourself with your name and surname, as well as a copy of your DNI or national ID, if necessary.

In the event that you have given consent for a specific purpose, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

In addition, if you feel that there is a problem with the way Meal Pass is handling your data, you can direct your complaints to the appropriate data protection authority, being the Spanish Data Protection Agency the one indicated in the case of Spain.

4.- Age

With respect to your use of the online service, you represent that you are of legal age and have the legal capacity to be bound by this agreement and to use the site in accordance with its terms and conditions, which you fully understand and acknowledge.

You declare that all the information you provide to access the Service, before and
during its use, is true, complete and accurate.

5.- Use of data

We use the information we have (subject to the choices you make) to operate, provide, improve, understand, customize, support and promote our Services.

Here's how we do it:

Operate and provide our services. Meal Pass uses the data it collects to provide, personalize, maintain and improve its services. To do this, we perform the following tasks:

To administer, provide and update the Service (the legal basis being our legitimate interest in keeping and maintaining the Service up to date and in good order).

To create, process, manage and update user accounts (the legal basis being your consent).

To offer, process or facilitate payment for our services (the legal basis being the contract).

To record and exchange booking progress with suppliers (the legal basis being the contract)

To provide features that allow users to share information with others, for example, when users give feedback about a business, or when a user recommends a friend to Meal Pass, or shares their booking with their contacts. (the lawful basis being your consent).

To provide personalization features for Meal Pass accounts, such as creating favorite businesses or quick access to the latest searches (the lawful basis being your consent).

To perform internal operations necessary to provide our services, such as correcting software bugs and operational problems, performing data analysis, testing and research, or monitoring and analyzing usage and activity trends (the lawful basis being our legitimate interest in keeping and maintaining the Service up to date and in good standing)

Security and safety. We use Personal Data to maintain the security and integrity of our Services. These include the following:

Verify businesses before allowing them to use our services (the legal basis being our legitimate interest in providing a reliable and secure Service)

Use device, location, profile or other source data to prevent, detect and combat fraud and security risk activities. (the legal basis being our legitimate interest in providing a reliable and secure Service)

Use user ratings and feedback to encourage compliance with our Terms and to deactivate the accounts of businesses that have low ratings or have violated guidelines in certain countries (the legal basis being our legitimate interest in providing a reliable and secure Service).

Allow users to communicate with businesses. We will allow you to communicate with independent third-party vendors, such as businesses, through Meal Pass to, for example, provide or receive information about reservations, special requests, allergens, etc.

Provide customer support. Meal Pass uses all the information it collects to provide support to its customers. To achieve this, we carry out the following tasks:

Refer questions to the appropriate support agent (the legal basis being our legitimate interest in addressing our users' requests and concerns)

Investigate and resolve user concerns (the legal basis being our legitimate interest in addressing our users' requests and concerns)

Monitor and improve our customer support processes and responses (the legal basis being our legitimate interest in addressing our users' requests and concerns)

Research and development. We may use the data we collect to conduct testing, research, analysis, product or service development and machine learning to enable us to improve the user experience. This allows us to enhance the security of our services, prevent the use of our services for illegal or inappropriate purposes, and develop new features and products.

Marketing. Meal Pass may use the data we collect to market our services to users. This includes:

Send communications about Meal Pass services, functions, promotions, sweepstakes, studies, surveys, news, updates and events (being the legal basis, depending on the case, the contractual relationship or our legitimate interest based on the previous contractual relationship, according to art. 21.2 LSSICE)

Send communications to our users about the products and services offered by the businesses in Meal Pass. Although we send communications about our partners' products and services, we do not sell or share users' personal data to businesses or third parties without users' permission (the legal basis being, depending on the case, the contractual relationship or our legitimate interest based on the prior contractual relationship, according to art. 21.2 LSSICE)

Use the data we collect to personalize our marketing communications, including the advertisements we serve, based on the user's location, use of Meal Pass services, preferences and account settings (the legal basis being, as the case may be, the contractual relationship or our legitimate interest based on the prior contractual relationship, in accordance with art. 21.2 LSSICE)

Send informational communications. Meal Pass may use the data it collects to generate receipts and send them to users, inform them about changes to our conditions, services and policies, or send other types of communications whose purpose is not to promote the services and products of Meal Pass or its partners.

You will be able to unsubscribe from them from the email you receive or by contacting us at contacto@mealpass.com . However, you will not be able to unsubscribe from certain correspondence from us, such as messages regarding the security of your data or the terms and conditions of Service.

To comply with legal requirements and procedures. We may use the personal data we collect to investigate or address claims or disputes relating to your use of Meal Pass services, as permitted by applicable law or in response to requests from regulators, government entities and official bodies.

Measurement, analytics and other business services. We help businesses that use Meal Pass to measure the effectiveness and delivery of their services and messages, and to understand how people interact with them on our Services.

In addition, Meal Pass may use user information in the form of aggregated, anonymous data for display to third parties. We may also share statistical and
demographic information about users and their use of the Service with third parties. But none of this will allow those third parties to identify you personally.

5.1.- In mails and contact forms

The Service's website has a TLS encryption that allows the user to securely submit your personal data through standard contact forms.

The personal data collected will be subject to automated processing and incorporated into
the corresponding files of the register of processing activities and of which Meal Pass is the owner.

In this sense:

We will receive your IP, which will be used to check the origin of the message in order to provide you with appropriate recommendations (e.g. to present the information in the correct language) and to detect possible irregularities (e.g. possible attempts of cyber-attack on the Service), as well as data concerning your ISP.

You may also provide us with your information by telephone, e-mail and other means of communication as indicated.

Regarding the means of payment used:

Our payment service providers to pay for the provision of our services or the amount of the product are credit card and bank transfer via payment gateway. At no time will the Service or its staff have access to the bank details (e.g. credit card number) that the user as a customer will provide to these third parties.

On the other hand, certain services provided through the site (for example, the possibility of
to participate in a contest or promotional code sweepstakes) may contain conditions
particular conditions on the protection of personal data. It will be necessary to accept them before
to participate in these services.

5.2.- In social networks

Meal Pass has profiles on some of the main social networks, being responsible for the processing in relation to the data published on them (for example, photos uploaded by Meal Pass in which people's faces appear).

The treatment that Meal Pass will carry out with the data within each of the aforementioned networks will be, at most, the one that the social network allows to the corporate profiles.

Thus, Meal Pass will be able to inform, when the law does not prohibit it, our followers by any means that the social network allows about its activities or offers, as well as to provide a personalized customer service.

Under no circumstances will Meal Pass extract data from social networks, unless the user's consent to do so is expressly and timely obtained.

5.3.- In draws

When participating in promotional actions organized exclusively by Meal Pass, the data you provide will be processed only by us for the purpose indicated in the action's statement and its corresponding legal conditions.

6.- Data retention

The following is an indication of how long the data processed by the Service is retained:

Disaggregated data will be retained with no time limit for deletion.

Customer data will be retained as little as necessary, and may be kept until:

5 years, according to art. 1964 of the Civil Code (personal actions without special term).

6 years, according to art. 30 of the Commercial Code (accounting books or invoice, for example).

The data of newsletter subscribers will be retained from the time the user subscribes until the user unsubscribes.

User data uploaded by Meal Pass to its social networks will be retained from the time the user gives consent, or the data has been uploaded according to the legitimate interest of Meal Pass, until the user withdraws it.

7.- Data shared with third parties

There are third parties that manage part of the Service.

They are required by Meal Pass to comply with this Privacy Policy to the extent applicable to them, in addition to having their own. However, Meal Pass will not be responsible for their compliance with this policy.

Under some circumstances, Meal Pass may share, use or preserve some of the personal information collected with third parties:

To provide the Service:

Service providers who perform functions on our behalf, such as authorized resellers, partners or sales agents, payment services, web hosting, business analytics, customer service or web marketing. These service providers may collect and have access to information that is necessary for them to perform their functions, but are not permitted to share or use the information for any other purpose.

To cooperate with the competent authorities:

If we believe it is reasonably necessary to satisfy any law, legal process or legitimate interest. In any case, we will only provide information that is strictly required.

International Data Transfers

For efficiency of service, some of the above mentioned providers are located in territories outside the European Economic Area that do not provide a level of data protection comparable to that of the European Union, such as the United States. In such cases, we inform you that we transfer your data with adequate safeguards and always guarding the security of your data. Specifically:

We use Mailchimp, based in the USA, for the purpose of providing its email marketing services. The relevant EU standard contractual clauses have been incorporated into the contract with Mailchimp as a Data Processing Addendum (DPA), which applies to customer data protected by EU law.
We use Google Analytics, based in the USA, for the purpose of collecting information about the use of our Services through its cookies. Having incorporated into the contract with that entity the relevant EU standard contractual clauses, which applies to customer data protected by EU law. You can consult the standard contractual clauses adopted by the European Commission here, here and here.

9.- Safety measures

Meal Pass takes all necessary technical and organizational measures to protect the security and integrity of personal and non-personal information collected. Both against unauthorized access and against accidental alteration, loss or destruction.

In any case, Meal Pass cannot guarantee the absolute security of the information collected, so you must cooperate and use common sense at all times about the information shared.

You understand and acknowledge that, even after deletion, personal information and non
personal information may remain visible in cache or if other users have copied or stored it.

10.- Changes in the Privacy Policy

We may update this Privacy Policy in the future.

We will inform you of any changes by sending a notice to the e-mail address
provided and/or by placing a notice in a prominent place on our website.

11.- Contact

If you have any questions about this Privacy Policy, please contact us at:

E-mail: contacto@mealpass.com

Address: Avenida Albufera 23, 07458 Muro, Balearic Islands, Spain.