Data Controller: RJ Digital HUB SLU (trading as ResidenceSafe), C/ de la Sardana 3, altell escala B, AD500 Andorra la Vella, Principat d'Andorra. Tax ID: L-713047-Z. hello@residencesafe.com / dpo@residencesafe.com.
Regulatory framework: Llei 29/2021 del Principat d'Andorra (Andorran Data Protection Act) and Regulation (EU) 2016/679 (GDPR).
1. What Data We Collect and Why
Account data
We collect your email address to create and manage your account, authenticate you, and communicate with you about the service. Legal basis: performance of a contract (Art. 6.1.b GDPR).
Identity verification
To activate certification of your check-ins, we process your full name, document number, nationality, date of birth, and document image. Without this processing, it is not possible to issue legally valid records. Legal basis: performance of a contract.
Biometric data
During verification, we perform a facial liveness analysis to confirm your identity. This data is deleted once verification is complete. Legal basis: your explicit consent (Art. 9.2.a GDPR).
Check-in data
Each check-in records the GPS coordinates of your device and a precise timestamp. These are the core of the service and are cryptographically sealed on the blockchain. Legal basis: performance of a contract.
Device and usage data
We collect technical information about your device (model, operating system, app version) and service usage data to ensure the service works correctly and to prevent fraud. Legal basis: legitimate interests (Art. 6.1.f GDPR).
Subscription and payment
All payment transactions are processed entirely through the Apple App Store or Google Play. We do not store card details or direct financial information. We do retain your subscription history and purchase receipts as required to manage the service.
2. Plans and Data Treatment
| Plan | Data processed | Blockchain certification |
|---|---|---|
| Free | Email, usage data | No |
| Basic | Email, verified identity, GPS, device | Yes |
| Pro | Email, verified identity, GPS, device, encrypted cloud backup | Yes |
3. Who We Share Data With
Apple / Google
In-app purchases are handled through the Apple App Store and Google Play platforms. Their privacy policies are independent of ours.
Cloud infrastructure
We use cloud infrastructure providers to host the service. These providers act as data processors under a data processing agreement in accordance with the GDPR and Llei 29/2021.
Identity verification provider
Document and identity verification is carried out through a specialist provider acting as a data processor. They receive only the data strictly necessary to complete the verification and do not use it for any other purpose.
We do not sell or share your data with third parties for commercial purposes.
4. How Long We Keep Your Data
| Category | Retention period |
|---|---|
| Account data | Duration of the contract + 30 days after deletion request |
| Check-in records | Duration of the contract + 5 additional years |
| Biometric data | Deleted upon completion of verification |
| Tax documents and reports | 7 years (Andorran regulations) |
| Device and usage data | 13 months from collection |
5. Your Rights
You have the right to access your data, correct it, request its deletion, restrict or object to its processing, and request portability in a structured format. To exercise any of these rights, write to dpo@residencesafe.com with your request and a copy of a document verifying your identity.
If you believe your data is being processed unlawfully, you have the right to lodge a complaint with the Andorran Data Protection Agency (APDA): www.apda.ad.
6. Security
All data in transit is encrypted via TLS. Data at rest is stored with AES-256 encryption. Access to production systems is restricted and protected with two-factor authentication. We conduct regular security audits. Presence records, once sealed on the blockchain, are immutable by design.
7. Changes to This Policy
Any material changes will be communicated to users at least 15 days in advance through the app. Continued use of the service after that date constitutes acceptance of the updated version. Previous versions are available on request at dpo@residencesafe.com.