1.- Privacy, Security and Platform Use Policy of TripOnTrib

This Policy regulates, in an integrated and transparent manner, (i) the processing of personal data on TripOnTrib (a social platform aimed at connecting people with travel affinities to facilitate the creation of groups, interaction between users, trip organization and the use of community features) and (ii) the security measures, moderation and prevention of unlawful uses associated with the use of the service. Data processing is carried out in strict compliance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD).

2.- Identity of the Controller and Contact Channels

Controller: TripOnTrib, S.L. Tax ID (CIF): B19950666. Address: Calle Juan Bautista Monegro nº 7, 1º D, 28850, Torrejón de Ardoz (Madrid), Spain. Data protection contact email: admin@tripontrib.com. Scope: This policy applies to the use of our mobile applications, website and official social media profiles/networks (collectively, the «Services»). Data Protection Officer (DPO): Olha Yevchak  

3.- Personal Data Processed (Mandatory, Optional and Special Categories)

3.1. Mandatory data (to create an account and operate the service)

1. Identification and account data: username, email address, password (in non-reversible format), date of birth or confirmation of legal age, country/language.
2. Basic technical and security data: session identifiers, IP address, date/time of access, device/browser, activity logs essential for security, fraud prevention and operation.

3.2. Optional data (to enrich the social and travel experience)

1. Extended profile: profile photo, biography, travel interests, travel style, availability, group preferences, city/approximate area.
2. User-contributed content: posts, comments, ratings, incident reports, travel proposals, shared files.
3. Verification/security (if offered): phone number, enhanced email verification, additional authentication methods.
4. User support: communications with support, complaints, incident evidence.

3.3. Identity verification (required for advanced features)

  We work with an external provider that performs profile verification (you will be asked for a photo of your identity document and a selfie). TripOnTrib does not retain copies of your documents; the provider acts as a data processor and returns only the result to us (verified/not verified). Without verification, you may use basic features, but you will not be able to contact other users or participate in private groups. You will also be unable to create your own private group or a trip, nor join other private groups.

3.4. Special categories of data (general rule: not requested)

TripOnTrib does not, as a general rule, request data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data concerning health or sexual orientation/life. If a user voluntarily chooses to publish or share information that may fall within special categories, they do so at their own responsibility, and TripOnTrib will apply minimisation measures, access restrictions and moderation to reduce risks, and may remove content when it violates rules, is unnecessary for the purpose of the service, or poses a risk to the rights of third parties.

3.5. Payment data (Premium Service)

If you subscribe to the Premium Service, we will need payment data (e.g., credit/debit card) through a payment provider. Current situation: Premium is free and we do not request payment data. When billing is activated: we will notify you and request your payment details securely.

4.- Purposes of Processing and Legal Basis (treatment by treatment)

  TripOnTrib processes personal data for the following purposes, with the indicated legal bases:

4.1. Registration, account management and service provision (social features, groups, chats and trip organisation)

Purpose: create account, authenticate the user, enable the profile, allow creating/joining groups, participating in chats, publishing content, managing community tools and planning trips, and receiving travel recommendations and commercial communications within the platform. Legal basis: performance of a contract (GDPR art. 6.1.b) and, where applicable, pre-contractual measures requested by the user.

4.2. Security, service integrity, fraud prevention and prevention of unlawful uses, and moderation

Purpose: maintain platform security, prevent unauthorised access, detect spam, harassment, impersonation, scams, exploitation, unlawful content or content contrary to the rules; investigate and document incidents; apply measures of restriction, blocking, content removal and internal sanctions. Legal basis: legitimate interest in the security of the service and protection of the community; and compliance with a legal obligation. Information strictly necessary to monitor, analyse, investigate and document improper or unauthorised activities will be retained.

4.3. Management of internal/external reports and compliance (if a reporting channel or information system exists)

Purpose: handle communications concerning regulatory infringements, unlawful conduct or non-compliance. Legal basis: compliance with a legal obligation when the internal system is mandatory, and/or task carried out in the public interest where applicable under the regime governing the information system.

4.4. User support, assistance and incident management

Purpose: respond to requests, technical incidents, complaints, claims, requests for the exercise of rights and security-related enquiries. Legal basis: performance of a contract (service) and/or compliance with a legal obligation in the area of data protection when handling rights and obligations under GDPR/LOPDGDD.

4.5. Commercial communications and prospecting (newsletter, promotions, event/feature invitations)

Purpose: send commercial communications by electronic means, personalise basic promotional communications and manage advertising preferences. Legal basis: consent (GDPR art. 6.1.a), which may be withdrawn at any time through simple mechanisms. Unsolicited communications will be avoided and clear preference controls will be offered.

4.6. Usage analytics, service improvement and metrics

Purpose: understand the use of features (groups, chats, community tools), improve the experience and detect faults; compile internal or aggregated statistics. Legal basis: legitimate interest (service improvement and quality) and/or consent when non-essential tracking technologies are used (e.g., non-exempt analytical cookies). Minimisation and, where possible, aggregation/anonymisation will be applied.

4.7. Compliance with requirements and cooperation with authorities

Purpose: respond to legally binding requirements, claims, defence of rights, investigation of unlawful acts and regulatory compliance. Legal basis: compliance with a legal obligation (GDPR art. 6.1.c) and/or legitimate interest in the defence of claims.

5. Essential Operation of Profiles, Groups and Chats (Visibility and Limits)

5.1. Profiles

The user decides which optional data to include in their profile. The profile will display, at a minimum, the username and the elements the user configures as visible. TripOnTrib may offer «visibility controls» with options such as: public / registered users only / group members only / private, indicating in each configuration who can see each profile field.

5.2. Groups

TripOnTrib may offer groups with different levels:

1. Public groups: the name, description and main content may be visible to registered users (or, if so configured, to third parties).
2. Private groups: content (posts, lists, trip documents) is only visible to approved members.
3. «Hidden»/invite-only groups (if available): the group’s location may not be visible except by invitation.

5.3. Chats (1:1 and group)

1. Messages in 1:1 chats are visible to the participants.
2. Messages in group chats are visible to group members.
3. TripOnTrib does not access message content unless: (i) the user reports it, (ii) an automated/semi-automated moderation system is activated for spam or abuse detection in accordance with internal rules, or (iii) it is strictly necessary to investigate security incidents, fraud or serious rule violations.
4. Sharing personal data of third parties without a legitimate basis, publishing doxxing, threats, extortion, non-consensual pornography, impersonation or incitement to hatred is prohibited. TripOnTrib may remove content and restrict accounts.

6.- Enhanced Protection of Consumer Users and Especially Vulnerable Users

  TripOnTrib applies a preventive risk-reduction approach within the travel community environment, with enhanced protection measures for consumer users and especially vulnerable users (due to age, personal circumstances, exposure to risk of fraud or harassment, or other circumstances).

6.1. Enhanced user-controlled tools

1. Blocking and «muting» users.
2. Reporting messages, profiles, posts and groups (with reason category).
3. Restriction of invitations and messages: allow only verified users / group members only / contacts only.
4. Profile and content visibility controls.

6.2. Response and internal measures

1. Prioritisation of reports affecting physical safety, harassment, exploitation, scams, or disclosure of sensitive data.
2. Measures: warning, feature restriction, suspension, removal from groups, account blocking, preservation of evidence where necessary for claims or authorities.
3. Minimisation measures: limiting public exposure of data, internal de-indexing of removed content and redistribution controls.

6.3. Minors

TripOnTrib will define its access policy: users aged 16 and over only. In any case, restrictive default settings, adapted information and functional barriers will be applied where necessary to reduce risks.

7.- Moderation, Prevention of Unlawful Uses and Preservation of Evidence

7.1. Moderation

TripOnTrib has community rules and moderation measures to prevent: travel fraud, scams, identity theft, unlawful recruitment, harassment, threats, dissemination of personal data, content that violates third-party rights and any activity contrary to the law. Moderation may combine (i) human review, (ii) automated abuse pattern detection tools, and (iii) actions based on reports.

7.2. Activity logging and traceability for security

User activities will be logged with the information strictly necessary to identify actions, investigate incidents and document unauthorised accesses or actions, with unique user identification and permission controls.

7.3. Preservation of evidence

When a complaint, claim or security incident arises, TripOnTrib may retain data and evidence in a limited manner (e.g., identifiers, logs, reported content) for the time necessary to manage the case, determine liability and comply with legal obligations, applying restricted access measures.

8.- Recipients, Data Processors and Sub-processors (GDPR art. 28)

8.1. Data processors

TripOnTrib may engage providers who process data on its behalf (e.g., cloud hosting, transactional messaging, analytics, support, anti-fraud verification). In such cases, TripOnTrib will enter into the corresponding contract or legal instrument with the content required for the data processor: processing in accordance with documented instructions, confidentiality, technical and organisational measures, sub-processing conditions, assistance in the exercise of rights, support with security and breaches, return/deletion upon termination of the service, and provision of information for audits.

8.2. Sub-processors

Where a processor engages another processor, prior written authorisation (specific or general) will be required and the same obligations will be imposed on the sub-processor; the initial processor will remain fully responsible to TripOnTrib with regard to the sub-processor’s compliance.

8.3. Transfers to third parties and authorities

Data will not be communicated to third parties except: (i) when necessary for the provision of the service (e.g., features chosen by the user), (ii) under a legal obligation or valid request, or (iii) when the user expressly and informedly consents. When TripOnTrib engages a third-party entity to provide a service requiring access to personal data (for example, marketing, monitoring, analytics, support, verification or anti-fraud services), that entity will have the status of data processor and the service must be governed by a contract or other legal instrument binding the processor with respect to TripOnTrib, establishing the subject matter, duration, nature and purpose of the processing, the type of personal data and categories of data subjects, and the obligations and rights of TripOnTrib as controller. The contract with the processor must stipulate, at a minimum, that the processor:

• processes personal data only following documented instructions from TripOnTrib;

• ensures that persons authorised to process personal data are subject to a commitment of confidentiality;

• adopts the necessary technical and organisational measures to ensure an adequate level of security;

• does not engage sub-processors without prior written authorisation, specific or general, informing of changes so that TripOnTrib may object; and, where sub-processing exists, imposes the same obligations on the sub-processor, with the initial processor remaining fully responsible to TripOnTrib;

• assists TripOnTrib, through appropriate technical and organisational measures and to the extent possible, so that TripOnTrib can fulfil its obligation to respond to requests for the exercise of rights by data subjects;
• helps TripOnTrib ensure compliance with obligations regarding security and incident management;
• at TripOnTrib’s choice, deletes or returns personal data upon termination of the service, and deletes copies unless legally required to retain them; and makes available to TripOnTrib the information necessary to demonstrate compliance and to allow audits and inspections.

If TripOnTrib acts as an intermediary service provider hosting or storing user content in terms equivalent to social networks or information society services, and where applicable, TripOnTrib will respond to user requests to:  

• transmit the content provided by the user to TripOnTrib, without preventing its subsequent transfer to another provider, in a structured, commonly used and machine-readable format; and

• transmit such content directly to another provider designated by the user, where technically feasible.

To fulfil these obligations, TripOnTrib will apply the timeframes and conditions established for responding to data subject requests, ensuring that the transmission does not compromise the security of the service or the rights of third parties.

9.- International Data Transfers

If, due to the nature of providers or infrastructure, it becomes necessary to transfer data outside the European Economic Area, TripOnTrib will apply the safeguards and requirements set out in GDPR (Chapter V) and applicable national law.

10.- Retention Periods

TripOnTrib will retain data for the time necessary to:

1. maintain the account and provide the service;
2. respond to user requests;
3. comply with legal obligations;
4. manage claims, fraud or incidents;
5. apply security policies, with limited log retention in accordance with necessity and proportionality.

Upon requesting account deletion, erasure will be applied or, where appropriate, blocking/restriction of processing during limitation and liability periods.

11.- Information Security

TripOnTrib applies technical and organisational measures appropriate to the risk to protect the confidentiality, integrity and availability of data, including access controls, permission management, encryption where applicable, security monitoring, backup copies, and measures to prevent unauthorised access.

12.- Security Breaches

TripOnTrib has a response protocol for personal data security breaches, including analysis, containment, mitigation and, where required, notification to the supervisory authority and/or communication to those affected within the timeframes and conditions set out in the GDPR.

13.- Cookies and Similar Technologies

TripOnTrib uses cookies and similar technologies for: (i) technical operation of the site/app, (ii) security, (iii) preferences, (iv) analytics and, if enabled, (v) advertising/measurement.

1. A cookie policy will be provided with information on types and purposes, whether first-party or third-party, retention periods, and international transfers where applicable.
2. Where required, consent will be requested through a clear mechanism, with a genuine option to accept, reject or configure, avoiding deceptive patterns.

14.- Commercial Communications, Prospecting and Digital Advertising

Commercial communications by electronic means will be sent only when an appropriate legal basis exists, prioritising clear and informed consent. The user will have simple mechanisms to withdraw consent, unsubscribe or exercise the right to object, without prejudice to the management of communications essential to the service (transactional or security-related).

15.- Social Media as Official Channels

When TripOnTrib maintains profiles on social media (e.g., Instagram, X, Facebook, TikTok), those channels will be considered external media with their own rules and processing activities. TripOnTrib will process data derived from interactions on those channels in accordance with GDPR/LOPDGDD, and will only reuse third-party content or images for its own purposes when it has a legitimate basis, normally consent where applicable.

16.- Exercise of Rights (ARSOPOL), Withdrawal of Consent and Right to be Forgotten

16.1. Rights

The user may exercise the rights of access, rectification, erasure (right to be forgotten), objection, portability and restriction of processing, where applicable.  

16.2. How to exercise them

1. Via the privacy panel in the account: URL/menu (recommended).
2. Via email to: admin@tripontrib.com
3. Via postal address: address.

  The request must include: identity of the applicant (and means of verification), the right being exercised, and scope (e.g., specific posts, specific groups, chats). If TripOnTrib uses social media as an official customer service channel, it may receive via those channels requests related to ARSOPOL rights (access, rectification, erasure, objection, portability and restriction of processing). To ensure they are handled on time and in proper form, TripOnTrib will maintain an internal protocol for channelling these requests to the formal rights exercise channel, so that:

• the request is identified as an exercise of a data protection right;
• the identity of the applicant is verified by an appropriate means, avoiding requesting excessive data;
• the date of receipt and the channel through which it was received are recorded;
• the applicant is informed of the designated channel (privacy panel, specific rights email or other means provided in the Policy); and
• the response is managed in accordance with the applicable timeframes and requirements.

16.3. Withdrawal of consent

Where processing is based on consent (e.g., newsletter, certain cookies), the user may withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal.

16.4. Right to be forgotten on the platform

TripOnTrib will offer mechanisms to: (i) delete own posts, (ii) delete or anonymise certain profile elements, (iii) close the account with erasure/blocking as applicable, and (iv) manage requests concerning content replicated or cited by third parties within the platform, balancing the rights of third parties, legal obligations and prevention of abuse.

16.5. Complaint to the supervisory authority

The user may lodge a complaint with the Spanish Data Protection Agency.

17.- Policy Changes

TripOnTrib may update this Policy to adapt it to legal, technical or functional changes. The date of last update will be indicated: date and, when changes are material, communication will be provided through reasonable means within the platform.