Privacy policy
This translation is for information only. The Spanish text is the binding one: if the versions differ, the Spanish version prevails. Read the Spanish version
menumentos is a free audio guide for walking around Spanish towns and cities, with an app for iOS and Android and a website (menumentos.com). This policy explains what personal data we process, why, on what legal basis, who we share it with, how long we keep it and how you can exercise your rights, in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on the Protection of Personal Data and the guarantee of digital rights (LOPDGDD).
In short:
- You can use the app without an account. What you listen to and save stays on your phone.
- Your exact location never leaves your phone for our servers. The app uses it on the phone itself to let you know when you pass near a point with a story; we do not store any position or any route you walk.
- We ask for the minimum: if you create an account, your email, your language, your approximate country and your consents. We do not ask for your date of birth.
- Analytics and personalised ads only if you accept them, and you can change your mind whenever you like.
- You can download all your data and delete your account from the app or from menumentos.com/en/account.
1. Who the controller is
| Controller | CLAUDIA TECH, S.L. (trade name ClaudIA Tech) |
| Tax ID (NIF) | B93811149 |
| Address | Calle Gumersindo Azcárate, 8, 45200 Illescas (Toledo), Spain |
| Privacy email | info@menumentos.com |
| Data protection officer | Not appointed: we are not required to (Article 37 GDPR and Article 34 LOPDGDD). For any privacy matter, write to info@menumentos.com |
2. What data we process and where it comes from
You give us all the data, or it is generated when you use menumentos. We do not buy data or obtain it from other sources, except your identifier and email if you sign in with Apple or Google.
2.1. If you use the app without an account
- Progress, mementos and preferences: stored only on your phone.
- Anonymous session: only when needed (buying, redeeming a code, reporting an error, reporting content or syncing) an anonymous identifier is created on our server, without email or name. Your purchases, error reports and content reports are linked to that identifier.
- Technical data: app version, operating system and device model, needed for the service to work and to fix errors (see 2.4).
2.2. If you create an account
You can sign up with Apple, with Google, with a link sent to your email or with email and password.
| Data | Purpose |
|---|---|
| Email address (with Apple it may be a relay address) | Identify you, send you the sign-in link and service notices |
| Apple or Google identifier | Sign in |
| Language and approximate country | Show you content in your language and compile aggregate statistics. The country is a two-letter code taken from your device’s language and region settings or from what you choose; never from your location or your IP address |
| Consents | Remember what you have and have not accepted: personalised ads and marketing communications |
| What you have listened to and saved (mementos) and your progress on routes | So you can get it back on another phone or on the website. A memento says which point you listened to and when, never where you were |
| Route ratings and their comment | Improve the routes. Only the team and you read the comment; publicly only the average is shown, when there are three ratings or more |
| Passes, purchased routes and redeemed codes | Give you access to what you have bought or earned |
| Questions to «ask the guide» and their answers | Answer you; we keep them for 30 days |
| Error reports and content reports you send | Fix the content and handle the report |
| Who you have hidden | Not show you what that person publishes |
2.3. If you contribute content to the community
- Public name you choose (it can be a pseudonym), handle and whether you want your profile to be public.
- What you send: text, links, the location of the place that you mark on the map (not your own) and up to 3 of your own photos. Before uploading them we remove the photos’ metadata (including the GPS position stored by the camera). Photos are kept in private storage until they are published.
- Declarations: that you are 14 or older, and the version of the community terms you accepted, with its date.
- History of your contribution: statuses, messages from the team and reasons for rejection or removal.
- Points, level and badges, and any warnings or sanctions the team imposes on you for breaching the terms.
If we publish your contribution, your public name appears as a credit on screen (never in the audio) and, if you turn on your public profile, also on your profile page on menumentos.com and in the community leaderboard.
2.4. Usage data, errors and ads
- Analytics (PostHog, EU region): events such as «route started», «story completed» or «walk finished» (with its duration and number of points, never the route walked). They are only sent if you accept them. No session recording.
- Errors (Sentry): when the app fails, a technical report of the failure. We configure it not to store your IP address or user data and to strip any coordinates before sending it.
- Anonymous technical notices: if something fails (a download, an audio, a purchase, the website), the app and the website send us the type of failure, the platform, the versions and a code, with a random identifier used only to limit the number of notices (on the website it lives only while the tab is open). Never a position or an advertising identifier, and we do not store who sent it.
- Ads (Google AdMob): in the European Economic Area, Switzerland and the United Kingdom we ask for your consent with Google’s message (IAB TCF framework) before requesting ads and, on iOS, afterwards, for Apple’s tracking permission (ATT). If you accept, Google may use your device’s advertising identifier to show you personalised ads; if not, you will see non-personalised or limited ads. For our audio spots and sponsored stops we only keep daily counters (impressions, plays and clicks), without knowing who saw them.
- Notifications: if you turn them on, a device notification identifier.
2.5. Your location
With your permission, the app uses your phone’s location to let you know when you pass near a point and to guide you along a route, also in the background while a walk lasts. That calculation happens on the phone itself: we do not send your position or the routes you walk to our servers, and we do not store them in any database. We are responsible for how the app uses your location even though it does not leave your phone, and the basis for that use is your consent, which you give by granting the permission. You can withdraw it in your phone settings; the app will keep working without proximity alerts.
The app’s map is Google Maps. When it loads, Google receives the technical data inherent to downloading the map (such as your IP address). When the map shows your position, it is drawn by the Google Maps component installed in the app, and Google may process usage and location data from that component under its own privacy policy.
2.6. If you write to us, report content from the website or are a sponsor
- Report from the website without an account: your email, the reason and details of the report and, for 30 days, your IP address to limit abuse.
- Emails with us: what you tell us and your address.
- Sponsors: contact details of the person who manages the business account and billing details (payment data is processed by Stripe).
3. Purposes and legal bases
| Purpose | Legal basis (Article 6 GDPR) |
|---|---|
| Providing the service: account, sync, passes and purchases, codes, «ask the guide» | Performance of a contract (6.1.b): the terms of use |
| Receiving, reviewing, editing, translating, voicing and publishing your contributions, with their credit; giving you points and rewards | Performance of a contract (6.1.b): the community terms |
| Automated screening of contributions with artificial intelligence (spam, insults, third-party data, copied text, dangerous sites or duplicates). It never decides: a person from the team always decides | Legitimate interest (6.1.f) in keeping the service safe and lawful and in protecting people who may appear in contributions. You can object by writing to us |
| Handling reports, giving reasons for rejections and removals, and applying sanctions | Legal obligation (6.1.c): Regulation (EU) 2022/2065 on digital services; and performance of a contract |
| Security and fraud prevention: limits on attempts to redeem codes, on reports and on submissions; anonymous technical notices; log of the team’s activity | Legitimate interest (6.1.f) |
| Error reports (Sentry) | Legitimate interest (6.1.f) in the app working and being secure. Technical data only, without IP or user identifiers. You can object by writing to us |
| Usage analytics (PostHog) | Consent (6.1.a) |
| Personalised ads (AdMob) and tracking on iOS (ATT) | Consent (6.1.a) |
| Non-personalised ads | Consent (6.1.a) for Google’s use of device storage, collected in the same message. If you do not give it, Google only serves limited ads, without that use, based on our legitimate interest (6.1.f) in funding a free service |
| Marketing communications (news, offers) | Consent (6.1.a), and Article 21 LSSI |
| Service notices (status of your contributions, download finished) | Performance of a contract (6.1.b) |
| Billing sponsors and tax and accounting obligations | Legal obligation (6.1.c) |
Where the basis is legitimate interest, we have weighed that the processing is minimal and expected and does not override your rights. You can object at any time by writing to info@menumentos.com.
You can withdraw your consent at any time from the settings of the app or your account, without affecting processing carried out before.
Automated decisions: we do not take decisions based solely on automated processing that produce legal or similarly significant effects on you (Article 22 GDPR). AI screening only leaves notes for the team; accepting, rejecting or removing a contribution is always decided by a person. We do not profile users.
4. Who we share data with
We do not sell your data. It is processed with us only by the providers we need to deliver the service, as processors, under a contract requiring them to process it only on our instructions and with security measures (Article 28 GDPR).
| Provider | Purpose | Data |
|---|---|---|
| Supabase, Inc. | Database, accounts and storage of contribution photos | The data in sections 2.1 to 2.3 |
| Vercel, Inc. | Hosting of the website and server functions | Technical data of visits; contribution and report data passing through its functions |
| Cloudflare, Inc. (R2 and content delivery network) | City packs, audio and published photos | Published contribution photos; technical data of downloads |
| Anthropic, PBC (Claude API) | Screening and editing contributions, translation and «ask the guide» | Text of contributions and questions. Under its commercial terms, it does not use this data to train its models |
| ElevenLabs or Google Cloud (synthetic voice) | Voicing the stories | Only the final edited text, without personal data |
| PostHog (EU region) | Analytics, with your consent | Usage events and pseudonymous identifier |
| Functional Software, Inc. (Sentry) | Error reports | Technical data of the failure, without IP |
| RevenueCat, Inc. | Managing in-app purchases | User identifier, products purchased and store receipts |
| Don Dominio (Spain) and, if we use it, Resend (EU region) | Sending emails (sign-in and notices) and the info@menumentos.com mailbox | Email address and message content |
| Stripe Payments Europe, Ltd. (Ireland) | Payments from sponsors | Sponsors’ billing and payment data. Stripe acts as a processor to process the payment and as an independent controller for fraud prevention and its legal obligations |
| Expo (650 Industries, Inc.) | Sending notifications and app updates | Notification identifier |
Third parties acting as controllers in their own right, with their own policies:
- Apple and Google (App Store and Google Play): they sell and charge for in-app purchases. We never see your card details. Also if you sign in with Apple or Google.
- Google (AdMob): ads, according to your consent. Google acts as an independent controller of the data it processes to serve and measure ads. More information: how Google uses data.
- Google Maps: the app’s map (see 2.5).
- OpenFreeMap: the website’s map tiles; your browser downloads them directly from their servers, which receive your IP address.
- Civitatis, GetYourGuide, Tiqets and other ticket providers: if you open a ticket offer (on the website or in the app, always marked «Affiliate link»), you go to the provider’s website with our affiliate ID and a campaign tag for the place or route, nothing of yours. That website belongs to a third party: it sets its own cookies (including the one that credits us with the booking) and what you do there is governed by its terms and privacy policy. If you book through these links, menumentos earns a commission; it costs you nothing extra. On our side we only add one to that offer’s click count for the day, without storing who clicked, from where or with what device.
International transfers: several of these providers are US companies or may access data from there, even if they store it in Europe. We only transfer data with a safeguard under Chapter V of the GDPR: the provider’s participation in the EU-US Data Privacy Framework (European Commission adequacy decision of 10 July 2023) or, if it does not participate, the standard contractual clauses approved by the Commission, with any supplementary measures needed. You can ask us for the details of each provider and a copy of those safeguards at info@menumentos.com.
Authorities: we disclose data to judges, law enforcement or authorities when the law requires us to.
5. How long we keep it
| Data | Period |
|---|---|
| Account and everything linked to it (profile, mementos, progress, ratings, entitlements, points) | As long as you have the account. If you delete it, it is deleted immediately |
| Anonymous session without an account | Up to 12 months without use; then it is deleted together with what is linked to it. Purchases can always be recovered with «Restore purchases» |
| Unpublished contributions and their photos | Until you withdraw them or delete your account |
| Published contributions | As long as they are published. If you delete your account, the published text stays without your name and your photos are deleted (see the community terms) |
| Questions to «ask the guide» | 30 days |
| Reports and moderation decisions | 3 years from the decision |
| Sanctions | While in force and 3 more years |
| IP address of reports from the website and code redemption attempts | 30 days |
| Anonymous technical notices | 90 days |
| Analytics (PostHog) | 12 months. When you delete your account, your events are anonymised |
| Errors (Sentry) | 90 days |
| Emails you send us | As long as needed to deal with them and then up to 1 year |
| Sponsor billing | 6 years (Article 30 of the Spanish Commercial Code) and whatever tax law requires |
| Consents | While they remain valid and then 3 years so we can prove them |
When data is no longer needed but the law requires us to keep it, we block it (Article 32 LOPDGDD): it remains available only to judges and authorities during the limitation period for any liabilities, and is then deleted.
6. Your rights
You have the right to access your data, rectify it, erase it, object to its processing, restrict it, to portability, to withdraw your consent and not to be subject to automated decisions.
From your account, without writing to us:
- Download your data: in the account settings of the app or at menumentos.com/en/account, you get a JSON file with everything we hold linked to your account (access and portability, Articles 15 and 20 GDPR).
- Correct it: your public name, handle, language and consents can be changed in the settings.
- Delete your account: in the account settings of the app or at menumentos.com/en/account. Your profile, progress, mementos, entitlements, unpublished contributions and all your photos are deleted immediately; what was published stays without your name, which disappears from the website immediately and from the downloadable packs that same night. Your analytics events are anonymised.
- Withdraw consents: personalised ads, analytics and marketing communications, in the privacy settings of the app or your account. The location permission and the tracking permission (iOS), in your phone settings.
By email: write to info@menumentos.com from your account’s email or telling us how we can check it is you. We reply within one month at most (extendable by two more months in complex cases, letting you know). It is free.
Without an account: what the app stores without an account is on your phone and is deleted when you uninstall it. If you have an anonymous session (for example, because you bought without signing up), write to info@menumentos.com with the order number or the receipt of your App Store or Google Play purchase: it lets us find your session without asking you for other data.
If you believe we have not handled your rights properly, you can complain to the Spanish Data Protection Agency (www.aepd.es, C/ Jorge Juan 6, 28001 Madrid, Spain).
7. Minors
menumentos is a service for all audiences, but it is not aimed at children under 14. The app and the website do not ask for your date of birth. To create an account and to contribute content to the community you must be 14 or older (Article 7 LOPDGDD), and you declare so when you do.
Children under 14 can listen to the audio guides without an account, but should not accept analytics or personalised ads: if a child uses the phone, we ask parents or guardians to reject those options in the consent message or in the settings. If we learn that an account belongs to a child under 14, we delete it.
If you are a parent or guardian and believe that a child under 14 has given us data without your consent, write to info@menumentos.com and we will delete it.
8. Cookies and similar technologies
- On the website: we do not use analytics or advertising cookies, or third-party scripts. The user area stores your session in the browser’s storage, which is strictly necessary for you to sign in. More detail in the cookie policy.
- In the app: the AdMob component and, with your consent, the PostHog one access information on your device (such as the advertising identifier). We ask you first with the consent message and you can change your choice in the app’s privacy settings.
9. Security
We encrypt communications, limit access to data to the team members who need it (every access to a user’s record is logged) and each user can only read their own data. If we suffer a security breach that poses a risk to you, we will notify the AEPD within 72 hours and, if the risk is high, you too.
10. Changes to this policy
If we change anything important, we will let you know in the app or by email before it applies. The current version is always at menumentos.com/en/privacy, with its date.