* Last modified: 8 March 2019

Respect for your privacy is essential to us. That’s why we only collect the personal data we need to make the app and our services work, not one more.

In addition, we collect anonymous usage data, for statistical purposes, to measure the performance of the app and the server, in order to improve them.

3warnings provides this Privacy Policy to help you make an informed decision about whether to use or continue to use the 3warnings Site, 3warnings Software and/or the 3warnings Service. If you do not agree with our practices, please do not use the 3warnings Site, 3warnings Software or the 3warnings Service.

This Privacy Policy is incorporated into and subject to the 3warnings Terms of Service. Your use of the 3warnings Site, 3warnings Software and the 3warnings Service and any personal information you provide on the 3warnings Site or 3warnings Service is subject to the terms of this Privacy Policy and our Terms of Service.

Please note that any User Content or other content posted at the discretion of users of the 3warnings Service becomes posted content and is not considered personally identifiable information subject to this Privacy Policy.

What does this privacy policy cover?

This privacy policy forms part of the 3warnings Terms of Service and covers the treatment of user information, including personally identifiable information, obtained by 3warnings, including information obtained when you access the 3warnings website, and when using the 3warnings Service or any other software provided by 3warnings.

This privacy policy does not apply to the practices of companies that 3warnings does not own or control, nor to persons whom 3warnings does not employ or manage, including any of the third parties to whom 3warnings may disclose user information as set forth in this Privacy Policy.

The Information 3warnings Collects

3warnings may obtain the following types of information about you or your mobile device, which may include information that can be used to identify you as specified below (“Personally Identifiable Information”):

Personal Data

For the operation of the app and the web, we collect and use personal data from our users.

Protected by EU-RGPD and LOPD

3warnings complies with current Personal Data Protection legislation, both the European General Data Protection Regulation (EU RGPD) and the Spanish Organic Data Protection Law.

Responsible for data processing

The data controller is:

Daniel Muñoz Gil
NIF: 52332108R
ADDRESS: Calle Concejo de Degaña 2, 1C, 33204 Gijón - Asturias (España)
EMAIL:



Personal data we collect and its purpose

The user is informed that:

3warnings has a database that contains, among others, personal data of its users. This information is used exclusively to operate the instant messaging app and the web. 3warnings uses various Google services to operate, so these data are hosted in Google facilities.

These are the personal data that we collect, and its purpose

Personal data collected in the app

  • Your email address: You provide it to us when you install the app. This way we know where to send the messages your contacts send you. This information is indispensable, and without it, the app cannot work. It is also used to check your identity each time you send a message or file to a contact or group, to prevent impersonation of our users.
  • Emails from your contacts in your mobile phone address book: This list is uploaded securely and regularly to our servers, to check which of your contacts are also users of our app, and show them in your contact list in the app. We do not retain these data. Once the check is done on our servers, the data is deleted. You confirm that you are authorized to provide us with such emails. These data are indispensable, and without them, the app could not show you contacts to send messages to.
  • Your messages. We do not keep your messages. Your messages are encrypted on your device and delivered encrypted to Google Cloud Messaging, a service that takes care of getting the messages to your recipients. Once your messages are delivered (including your chats, photos, videos, voice messages, documents and location information), they are removed from our servers. Your messages are stored on your own device. If a message cannot be delivered immediately (for example, if you are offline), GCM may store it on their servers for up to 30 days while they try to deliver it. If a message has not been delivered after 30 days, it is deleted. We also offer end-to-end encryption automatically. End-to-end encryption means that your messages are encrypted to safeguard them and cannot be read by us or any third party.
  • Your files. The files you send to your contacts are uploaded by the app to your Google Drive account, and your recipients are granted access permissions. We do not encrypt your files, but we do encrypt the Google Drive link that reaches your contacts, using end-to-end encryption. This way, neither we nor third parties can find out which files you’ve shared, and only your recipients have access to them.
  • Your groups. You can create groups, give them names and images, and invite your contacts to join them. You can also accept invitations to groups of other people. We store on our servers the group names, their images, and the members who have agreed to be part of them. It is necessary for us to send your group messages to all its members, and to keep that information up to date for its members.
  • Your votes to Nonprofit Organizations. You can vote for your favorite Nonprofit Organizations to receive our donations. We store your votes on our servers to count them and show how many votes each Nonprofit Organization gets. But your votes are secret, we don’t publish which Nonprofit Organizations each user has voted for. We only add the votes of all our users and show the total results. Votes to Nonprofit Organizations are optional, they are not essential for the functioning of the app.
  • Your advertising preferences: The application displays advertising to generate revenue. The categories of the ads you clicked on are stored in your device. This information is only stored on your device, and is not shared with anyone, not even 3warnings. This information is used to show our users advertising that may be of interest to them. * These data are not yet processed, until 3warnings appoints a Data Protection Officer. But it will be treated in the future, and you accept it by using the app.
  • Your geolocation: The application uses your geolocation to show you ads available in your geographic area. It only uses your approximate location, about 30 square kilometers, and gets it only a few times a day. This information is only stored on your device, and is not shared with anyone, not even 3warnings.
  • Your subscriptions to Nonprofit Organization and Advertiser channels: The app allows you to subscribe to Nonprofit Organizations and Advertisers channels, in order to receive their messages and files. You can unsubscribe at any time. This information is stored in our backend to obtain the number of subscribers per channel. Nonprofit Organizations and Advertisers are informed of the number of subscribers they have, but nothing else.
  • Blocking users. You can block other users, to prevent their messages from reaching you. User blocking is stored locally on your phone, not on our servers, and the users you block are not informed by the app.
Automated decisions

We inform you that the system makes automated decisions: Depending on your geolocation and your advertising preferences, you will be shown one ad or another. It is important for 3warnings and its advertisers to show you advertising that may be of interest to you. There are no consequences beyond the display of some ads or others.

Personal data collected on the website

  • Forms. In our web there are several forms (contact, bugs reports…). They have been made with Google Forms. The data entered in these forms are subject to Google’s Privacy Policy. Through them, you can provide us with information related to your use of our Services, and how to contact you.

Personal data collected via email

  • Your email address: You give it to us when you send us an email. We use it to answer you. Without it, we would not be able to respond to you.

Personal data collected in the Nonprofit Organization registry

  • Your Google Account: Used to identify you and give you access to the control panel, where you can register your Organization, send messages to your subscribers, and more.
  • Your email address: We save it so that we can contact your Organization in case a problem arises. The donations we make to your NGO will be sent to this email, through Transferwise.
Not considered Nonprofit Organization personal data
  • Your registration data: The full name of the Nonprofit Organization, the short name, the country in which it is registered, and the website of the Official Institution in which it is registered. It is used so that our users can vote for your Nonprofit Organization. This data will be published (with the exception of the Google account and contact email) on our website and app, so that users can identify and vote for registered Nonprofit Organizations.

Personal data collected in the Advertisers registry

  • Your Google Account: Used to identify you and give you access to the control panel, where you can register, buy advertising credits, create and configure ads, send messages to your subscribers, and more.
  • Your email address: We save it so we can contact you if there is a problem.
  • Your registration data: Full name, tax identification code, VIES registration and address are used to issue your invoices when buying advertising credits.
Not considered personal data of Advertisers
  • The messages and files you send through our Control Panel to your subscribers. They are considered public, are not encrypted, and are available to anyone who is subscribed to your channel at the time of sending.

Data retention period

The data are necessary for the proper functioning of the instant messaging app, so they are retained as long as you continue to use the app, and do not request its removal.

The data collected in the registers of Nonprofit Organizations and Advertisers are necessary for the proper functioning of their respective control panels. Therefore, your data will be kept until you unsubscribe. In addition, they will be kept the necessary time required to comply with legal obligations.

Data that is not retained
  • Emails from your contacts on your device
  • Your messages and files sent in the app
Data that is immediately removed from your device when you uninstall the app
  • Your geolocation
  • Your advertising preferences
Data that is deleted immediately after Nonprofit Organization termination
  • Your Google Account
  • Your email address
Data that is deleted immediately after the termination in Advertisers
  • Your Google Account
  • Your email address
  • Your registration details: Full name, tax identification code, VIES registration and address
Data that is deleted within a few weeks of uninstalling the app

When you uninstall the app, your personal data is automatically deleted after a few weeks.

  • Your email address
  • Your group membership
  • Your votes to Nonprofit Organizations
  • Your subscriptions to Nonprofit Organizations and Advertisers

Conservation of data for historical and statistical purposes

The data you provide will also be used for historical and statistical purposes. We will publish on our website aggregated data, without personal information. For example, number of users in time, number of messages and files sent, number of Nonprofit Organizations, Advertisers, donations made to each Nonprofit Organization, etc.



Legitimation

Personal data is collected with the consent of the user. Legal basis: RGPD EU 2016/679 Article 6.1.a

If, due to any documentation error, any personal data not contemplated by the user’s consent is collected, its collection is carried out in the legitimate interest of the Responsible Party, for the correct functioning of the app, the backend and the control panels of Nonprofit Organizations and Advertisers. Legal basis: RGPD UE 2016/679 Article 6.1.f.



Recipients. Access to data on behalf of third parties

3warnings uses Google technology to run its app. Your personal data, provided by you to 3warnings, is hosted on Google servers.

You can see here the agreement between 3warnings and Google, which includes the privacy of your personal data: Terms of Security and Data Processing

Google also complies with the General European Regulation on the Protection of Personal Data (RGPD). The agreement between 3warnings and Google can be found here: EU Model Contract Clauses

Donations to Nonprofit Organizations

Our donations to Nonprofit Organizations are made through TransferWise. In order to do this, we must provide the IBAN and BIC/SWIFT codes of your Nonprofit Organization’s bank account, and the name of your Nonprofit Organization, to TransferWise. Your Nonprofit Organizations understands and accepts this transfer of data.



International Data Movement

3warnings’s app is designed to work globally: Users can send messages from different countries. To do this, Google maintains data centers around the world, and moves the data between them to bring them closer to their destination. Therefore, your personal data can be transferred to other countries.

The United States is included in the list of countries that the European Union considers to comply with an adequate level of personal data protection. It can be consulted at the Spanish Data Protection Agency .

Google is included in the list of companies certified under the EU-US Privacy Shield. It can be found at web of the EU-US Privacy Shield.

By installing the 3warnings app you understand that this international movement of data is necessary for the proper functioning of the 3warnings app, and you consent to it.

We only accept adults as users:

Our app displays third-party advertising to our users, and we have no control over the content of their ads. Although our policies for advertisers include a ban on ads unsuitable for minors, and we have an Artificial Intelligence system that helps us discard unwanted ads, we cannot ensure that the app only displays ads appropriate for minors. That is why we only accept adults as users.

Exercise of Personal Data Rights

You can consult and exercise your Personal Data rights at this link

Information collected automatically

  • For statistical purposes: We collect anonymously and publish daily on our website the number of registered users , the number of messages and files sent by our users, the total votes of our users obtained by each Nonprofit Organization , and other statistical data of interest to 3warnings, our users, Nonprofit Organizations and Advertisers.
  • Advertiser payment information: When purchasing advertising credits, we may receive information and confirmations, such as payment receipts, including those from third parties processing your payment.
  • Wifi Connection: When receiving a file, the app checks if your device is connected to a Wifi network or not, to download the file directly, or display a download button. We do this so that you can choose whether to consume part of your data plan to download the file, or whether to wait until later when you are connected to a Wi-Fi network. We do not collect this information on our servers.

Third-party information

  • Information others provide about you. We receive information that others provide to us, which may include information about you. For example, when other users you know use our Services, they may provide your email from their mobile phone’s contact list (as well as you can provide theirs), or they may send you a message or file, or send messages or files to the groups you belong to.
  • External providers. We work with the Google Play Store, which may provide us with information about you in certain circumstances; for example, they may send us reports that help us diagnose and troubleshoot problems with the service.

You can access our Cookie Policy by clicking on this link.

Log file

When you use the 3warnings Site, our servers automatically record certain information that your browser sends each time you visit any website. These server logs may include information such as your web request, Internet Protocol (“IP”), browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages visited and the order of pages, the amount of time spent on particular pages, the date and time of the request, one or more cookies that may uniquely identify your browser, your email address and various status information. When you use the 3warnings service, our servers record certain general information that our application sends each time a message is sent or received, or by automatically updating your contact list in the app, including the email accounts from which the messages were sent and received, as well as the date and time of sending.

The information 3warnings does not collect

3warnings does not collect names, phone numbers, addresses, or other mobile address contact information from contact lists of its users. It only collects email accounts from the user’s contacts, which 3warnings will associate with the name that the user has assigned to that email address in their address book or contact list on their mobile device - and this happens dynamically on the mobile device itself and not on 3warnings’s servers and is not transmitted to 3warnings. This means that if you have your friend’s email address associated with the name “Grijander” in your mobile address book, this is the name that will appear for that email address in your 3warnings contact list.

The content of messages that have been delivered by the 3warnings Service are not copied, maintained or archived by 3warnings in the normal course of business. The 3warnings Service is intended to be a replacement for SMS, using a user’s data service (either over the cellular network or Wi-Fi). Users write their messages, which are encrypted in their devices and then sent through the data service to our servers, and routed to their recipient (who must also be a 3warnings user), through the Google Cloud Messaging service. 3warnings does not save messages in any way, but they can be stored by Google, for the correct delivery of them to their recipients, or for other reasons. You can access the Google Privacy Policy at the following link https://www.google.com/intl/en/policies/privacy/. The content of delivered messages is not maintained or retained by 3warnings - records of the content of any message delivery reside directly on the sender’s and receiver’s mobile devices (which can be removed at the user’s option by uninstalling the app). Notwithstanding the foregoing, 3warnings may retain the date and time of the information associated with successfully delivered messages and the e-mail accounts involved in the messages, as well as any other information that 3warnings is legally obliged to collect. Files sent through the 3warnings Service are not stored on our servers. They are sent directly from your mobile device to your Google Drive account, and then shared with your recipient(s). In the event that your recipient shares those files, they will not be shared directly, but a copy of those files will be made in your contact’s Google Drive account, and those copies will be shared with your contact’s recipients.

The way 3warnings uses the information

If you submit personally identifiable information through the 3warnings Site or 3warnings Service, your personal information will be used to operate, maintain and provide you with the features and functionality of the 3warnings Site and Service. In particular, your email address is essential to your use of the 3warnings Service and will be retained. Any personally identifiable information you voluntarily disclose on the 3warnings Service is considered public and may be collected and used by other users of the 3warnings Service. Your name (as stored in another user’s mobile phone address book or contact list) may be displayed to other users through the 3warnings Service and other users may contact you through the 3warnings Service. We do not use your email address or other personally identifiable information to send commercial or advertising messages without your consent, except as part of a specific program or function for which you will be able to accept or unsubscribe. We may, however, use your mobile email address without your consent for non-marketing or administrative purposes (such as notifying you of changes to the 3warnings Website or 3warnings Service, or for customer service purposes). We may use both your personally identifiable and non-personally identifiable information (e.g., anonymous user usage data, cookies, IP addresses, browser type, navigational data, etc.) to improve the quality and design of the 3warnings Site and 3warnings Service and to create new tools, promotions, features and services by storing, tracking and analyzing user trends and preferences. We may use cookies and log information for: (a) remember the information so that you do not have to re-enter it during your visit or the next time you use the 3warnings Service or 3warnings website; (B) provide customized content and information; (C) monitor individual and aggregate statistics, such as the total number of visitors, pages viewed, etc.; and (d) track your entries, submissions, opinions and such.

We may collect, use, retain and share your information if we believe in good faith that it is reasonably necessary to: (a) respond in accordance with applicable laws or regulations, legal process or governmental requests; (b) enforce compliance with our Terms or any other applicable terms and policies, including for investigations of potential infringements; (c) detect, investigate, prevent and address fraud and other illegal activities or technical or security issues; or (d) protect the rights, property and safety of our users, us or others.

When 3warnings reveals information

Other users of the 3warnings Service may view you as contact within the app, consistent with your use of the 3warnings Service. In other words: If another user has their email address stored in their mobile phone address book or contact list, they will be able to see you as a contact in the app, and send you messages.

We do not sell or share your personally identifiable information (such as your email address) with other third party companies for their commercial or marketing use without your consent, except as part of a specific program or function for which you will have the ability to accept or unsubscribe. We may share your personally identifiable information with third party service providers to the extent reasonably necessary to carry out, improve or maintain the 3warnings Service. We may share non-personally identifiable information (e.g., anonymous user usage data, referring/exit pages and URLs, platform types, asset views, number of clicks, etc.) with interested third parties to help them understand usage patterns for certain content, services, advertisements, promotions, and/or functionality on the 3warnings site. We may collect and disclose personally identifiable and/or non-personally identifiable information if we do so by law or in the good faith belief that such action is necessary to comply with Spanish law, international law or to respond to a court order, subpoena or search warrant or equivalent, or when in our reasonable opinion, the physical safety of an individual may be endangered or threatened. 3warnings also reserves the right to disclose personally identifiable information and/or non-personally identifiable information that 3warnings believes, in good faith, is appropriate or necessary to fulfill our Terms of Service, to take precautions against legal liability, to investigate and defend against any third party claims or allegations, to assist government agencies, to protect the security or integrity of the 3warnings site or our servers, and to protect the rights, property, or personal safety of 3warnings, our users, or others.

Your Choices

It is possible, of course, to decline to submit personally identifiable information through the 3warnings Website or Service, in which case 3warnings may not be able to provide certain services. If you do not agree to our privacy policy or terms of service, please uninstall the 3warnings mobile application and stop using the 3warnings service; continued use of the 3warnings Service will signify your consent and acceptance of our Privacy Policy and Terms of Service. To protect your privacy and security, we take reasonable steps (such as authenticating your Google user on your mobile device) to verify your identity before registering your email address and allowing you access to the 3warnings Service. Please contact 3warnings through the forms available on our website with any questions or comments about this privacy policy, your personal data, your consent, or your opt-in or opt-out options.

Third party advertisements, links to other sites

3warnings’s app displays third-party advertising to generate revenue. These ads can link to third party websites. 3warnings has no control over such advertisements, and accepts no responsibility for any third party content. You understand that these ads are necessary for 3warnings’s business, and you agree that they may be displayed on 3warnings’s app.

Our commitment to data security

3warnings uses commercially reasonable physical, managerial and technical security measures to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to 3warnings and you do so at your own risk. We never recommend the use of unsecured wifi or other unprotected networks to send messages through the 3warnings service. Upon receipt of the transmission of information, 3warnings makes commercially reasonable efforts to ensure the security of our systems. Please note, however, that this is not a guarantee that such information will not be disclosed, altered or destroyed by the failure of any of our physical, technical or managerial security measures. If 3warnings discovers a breach of security systems, then we may attempt to notify you electronically so that you can take appropriate protective measures. 3warnings may post a notice on the 3warnings Site or through the 3warnings Service if a security breach occurs.

Our commitment to the confidentiality of your communications

User Content, i.e. messages and files that you send to other users or groups in the 3warnings app, will only be visible to their recipients. However, there are cases in which third parties may access the content of your communications: i) Due to a failure in the security systems, or external attack; ii) Due to legal or judicial requirements; ii) Communications are sent to their recipients through the Google Cloud Messaging service, and we are not responsible for their security or confidentiality. In other words: 3warnings tries to make your communications secure, confidential and private, but 3warnings does not guarantee the security, privacy or confidentiality of any communication or sending of information through its Service. We use end-to-end encryption by default in the app, which greatly increases the privacy, security and confidentiality of your communications through 3warnings.

Our Commitment to Children’s Privacy

Protecting the privacy of young children is especially important. For that reason, 3warnings does not collect or maintain personally identifiable information or non-personally identifiable information on the 3warnings Site or 3warnings Service from underage persons, and no part of the 3warnings Service is directed at, or is intended for use by, underage persons. If you are a minor, then please do not use the 3warnings Service or access the 3warnings Site at any time or in any form. If 3warnings finds that personally identifiable information of a minor has been collected on the 3warnings Website or Service, then 3warnings may deactivate the account and/or delete such information.

Special Note to Users from Other Countries

3warnings is located in Spain, and the 3warnings website and Service are intended for and directed to users in Spain. If you are a user accessing the 3warnings website and services from another country or any other region whose laws and regulations governing the collection of personal data, use and disclosure differ from the laws of Spain, you are communicating that, through your continued use of the 3warnings website and service, which is governed by Spanish law, this privacy policy and our Terms of Service, your personal information will be transferred to Spain and you expressly consent to such transfer and agree to be governed by Spanish law for these purposes.

Our Global Operations

You agree to our information practices, which include the collection, use, processing and sharing of your information as described in this Privacy Policy, as well as the transfer and processing of your data in Spain and other countries globally where we have or use facilities, service providers or partners, regardless of where you use our Services. You also authorize the transfer of data to countries outside the European Union. You acknowledge that the laws, regulations and standards of the country in which your information is stored or processed may differ from those in your own country.

In the case of merger, acquisition or bankruptcy

In the event that 3warnings is acquired by or merged with a third party, we reserve the right to transfer or assign the information we have collected from our users as part of such merger, acquisition, sale, or other change of control. In the (hopefully) unlikely event of bankruptcy, insolvency, reorganization, bankruptcy or assignment for the benefit of creditors, or the application of laws or fair principles that affect the rights of creditors generally, we may not be able to control how your personal information is treated, transferred or used.

Changes and Updates to This Privacy Notice

This privacy policy may be revised periodically and this is reflected in the “last modified” date at the beginning. Please revisit this page to be aware of any changes. Your continued use of the Site and 3warnings Service constitutes acceptance of this privacy policy and any amendments. If there is any inconsistency between the different language versions of this document, the Spanish version will be considered the correct one.