Privacy Policy

1. Who We Are (Data Controller)

This Privacy Policy is provided by Nuvola Di Pioggia, S.L. ("Pioggia," "we," "us," or "our"), a sociedad limitada incorporated in Spain and the data controller for the processing described here. We operate the Pioggia platform, website, mobile applications, and associated services (collectively, the "Services"). We process personal data in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD).

2. What Personal Information We Collect and How We Collect It

We collect personal information you provide directly to us, including when you:

• Create an account or register on the platform
• Submit, upload, or contribute video or media content
• Contact us for support or sales inquiries
• Respond to surveys or participate in research
• Subscribe to communications or newsletters

Information we collect automatically when you use our Services includes:

• Device identifiers, operating system, and browser type
• IP address and approximate location data
• Usage data, page views, and interaction logs
• Cookies and similar tracking technologies (see Section 10)

We also receive information from third-party partners, including Google Analytics, the Google Play Store, the Apple App Store, payment processors, and marketing agencies.

3. How We Use Your Personal Information

We use the personal information we collect to:

• Provide, operate, and improve our Services
• Process transactions and distribute rewards
• Communicate with you about your account and our Services
• Send promotional communications (with your consent where required)
• Comply with legal obligations and enforce our terms
• Detect and prevent fraud, abuse, and security incidents
• Conduct analytics and research to improve our platform

4. Promotional Communications

We may send you promotional emails or messages about our products, services, and offers. We will only send such communications where we have a lawful basis for doing so, including your consent or our legitimate interests.

5. Opting Out of Communications

You may opt out of promotional communications at any time by clicking the "unsubscribe" link in any email, adjusting your notification settings in the app, or contacting us at privacy@pioggia.ai. Note that opting out of promotional communications does not affect transactional or account-related messages.

6. Legal Basis for Processing (GDPR)

Where the GDPR applies, we process your personal information on the following legal bases:

• Contract: Processing necessary to perform our agreement with you
• Legitimate interests: Improving our Services, preventing fraud, and marketing to existing customers
• Consent: Where you have given specific consent (e.g., marketing emails)
• Legal obligation: Where we are required to process data by law

7. How We Share Your Personal Information

We do not sell your personal information. We may share it with:

• Service providers who assist in operating our platform (hosting, analytics, payment processing)
• Business partners with your consent
• Law enforcement or regulatory authorities when required by law
• Successors in the event of a merger, acquisition, or sale of assets

8. International Transfers of Data

Pioggia is established in Spain and your data is processed within the European Economic Area wherever possible. Some of our service providers (for example Google LLC for analytics, and hosting or payment providers) are located in the United States or other countries outside the EEA. Where that is the case, we transfer data only to providers certified under the EU-US Data Privacy Framework or under the European Commission's Standard Contractual Clauses (Decision (EU) 2021/914), with additional safeguards where required. You may request a copy of the safeguards in place at privacy@pioggia.ai.

9. Data Security

We implement technical and organizational measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

10. Cookies

We use essential cookies needed for the site to work and, only with your prior consent, analytics cookies (Google Analytics 4 with IP anonymisation). You can accept or reject analytics cookies in the banner shown on your first visit and change your choice at any time. The full list of cookies, their purposes and durations is in our Cookie Policy.

11. Data Retention

We keep personal data only for as long as needed for the purpose it was collected, and then as required by law:

• Account and profile data: for the life of your account, then deleted or anonymised within 12 months of closure
• Contributor content, licences and reward records: 5 years after the relationship ends (Spanish Civil Code, art. 1964)
• Invoicing, tax and accounting records: 6 years (Spanish Commercial Code, art. 30) and 4 years for tax purposes (General Tax Law, art. 66)
• Marketing consent and communications: until you withdraw consent or object
• Support correspondence: 2 years after the matter is closed
• Server and security logs: 12 months
• Analytics data: as set out in the Cookie Policy

12. Children's Privacy

Our Services are not directed to children. In Spain, consent to the processing of personal data may be given from the age of 14 (LOPDGDD, art. 7); elsewhere in the EU the age is 16 unless national law sets it lower, and in the United States it is 13. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected such information, we will promptly delete it. If you believe we have collected information from a child, please contact us at privacy@pioggia.ai.

13. Your Legal Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information
• Request deletion of your personal information
• Object to or restrict our processing of your information
• Data portability (receive your data in a structured, machine-readable format)
• Withdraw consent at any time where processing is based on consent

To exercise any of these rights, contact us at privacy@pioggia.ai.

14. Information for California Consumers (CCPA)

California residents have the right to know what personal information we collect, disclose, or sell; the right to request deletion; and the right not to be discriminated against for exercising these rights. We do not sell personal information as defined under the CCPA. To submit a request, contact us at privacy@pioggia.ai.

15. How to Make a Complaint

If you have a concern about how we handle your personal information, please contact us first at privacy@pioggia.ai. If you are unsatisfied with our response, you have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, C/ Jorge Juan 6, 28001 Madrid, www.aepd.es) or with the supervisory authority of the EU member state where you live or work.

16. Governing Law

This Privacy Policy is governed by Spanish law and by the GDPR. Where you access the Services from outside the European Union, local data protection rules such as the CCPA (California) may also apply and we honour them.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by updating the "Last updated" date at the top of this page and, where appropriate, by sending you a notification. Your continued use of our Services after any changes constitutes your acceptance of the updated policy.

18. Contact

For any privacy-related questions, requests, or complaints: