Privacy Policy Turbo Energy App

Privacy Policy Turbo Energy App


  1. .Privacy Policy


    Who is responsible for the data?

    The person responsible for the personal data collected through the Mobile Application is UMBRELLA (hereinafter, the "RESPONSIBLE").

    This policy is a statement of the RESPONSIBLE PARTY's commitment to maintain and ensure secure business relationships by protecting the personal data of the users of the Mobile Application (the "Data Subjects" or the "Data Subject"), guaranteeing the right to their privacy.

    This policy sets out the various processing carried out by the RESPONSIBLE, affecting the personal data of the Data Subject in accordance with the provisions of the Organic Law 3/2018, of December 5, 2018, on the Protection of Personal Data and guarantee of digital rights ("LOPD") and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR").

    What is personal data?

    "Personal Data" means any information concerning an identified or identifiable natural person. Among others, this includes first name, last name, postal and e-mail address, as well as telephone number.

    How is data collected?

    The RESPONSIBLE may collect data when a Data Subject installs the Mobile Application on its devices, creates a user account and makes use of it.

    What is the territorial scope of data processing?

    The data processing will be carried out in Spain and there will be no international transfer of personal data to third countries.

    What data is collected?

    The data collected are user data, from the photovoltaic installation. These data are the user's name, email, telephone, address of the interested party and the geolocation of the photovoltaic installation registered in the mobile application.

    What are the treatments and purposes of the data collected?

    Any personal data provided by the Data Subject will be processed in accordance with Spanish and European data protection regulations and will only be collected, processed and used for lawful, legitimate and informed purposes. Therefore, all the purposes for which personal data is used by the RESPONSIBLE or any of the companies belonging to its commercial group are described below:

    Identification of the Stakeholder / user of the Mobile Application.
    Contact with the Stakeholder / user of the Mobile Application, in order to: i) Respond to requests, complaints and incidents transferred through our contact channels or forms, ii) Send commercial communications related to the products and services of the RESPONSIBLE or any of the companies that make up its commercial group, iii) Conduct quality surveys.
    Provision of the photovoltaic installation monitoring service. Includes notification service.
    Correct and adequate management and provision of the contracted service.
    Computer control of the mobile application to prevent any violation of data security.
    Administrative, accounting and fiscal management of the relationship established with the Stakeholders / Users of the Mobile Application when they have contracted it.
    Fulfillment of the legal obligations that are directly applicable and regulate its activity.
    Improvement of the services and experience in the navigation and use of the Mobile Application.
    Protection of your rights or response to claims of any kind.


    What is the legal basis for the processing of personal data?

    The legal basis for the processing of the Data Subject's Personal Data is the use of the Mobile Application by the Data Subject and the provision of data to answer queries and enter into contracts.

    How long will the data be kept?

    The data will be retained for as long as the Data Subject makes use of the Mobile Application and for the time necessary to respond to queries or to fulfill the purposes for which they were collected or to comply with the legal term provided for the fulfillment of certain legal obligations, in accordance with the following rules:

    The Civil Code, in case of contractual obligations, we will keep your data between 5 or 15 years depending on the case in accordance with the provisions of article 1964.2 of the aforementioned legal body.
    The Commercial Code, for commercial purposes, establishes in its article 30 the obligation to keep the information (invoices issued and received, tickets, rectifying invoices, bank documents, etc.) for a period of 6 years.
    The General Tax Law, in relation to tax obligations, establishes in its article 66 to 70 the obligation to keep any document with tax implications for a period of 4 years.

    Is there any communication of personal data to third parties?

    The RESPONSIBLE may share the personal data of the Data Subjects with companies of the same commercial group, as well as with its strategic allies only for the purposes and under the conditions of this policy.

    The RESPONSIBLE may contract with third parties for the storage of the data of the Stakeholders, ensuring the confidentiality and security of the information, and remaining responsible for it.

    What are the rights of Stakeholders?

    The RESPONSIBLE will ensure that Stakeholders can exercise the rights described below:

    Right of access: this refers to the possibility for the Data Subject to know whether or not the RESPONSIBLE is processing his or her personal data.

    Right of rectification: this refers to the possibility for the Data Subject to obtain the rectification of his or her personal data that are inaccurate, without undue delay. Taking into account the purposes of the processing, the Data Subject has the right to have incomplete personal data completed.

    Right of erasure: this refers to the right of the Data Subject to request the erasure of his or her personal data and the deletion of any links to such data, or copies or replicas of such data.

    Right to limitation of processing: refers to the possibility of the Data Subject to request the deletion of his or her data or the limitation of its use.

    Right to information: this refers to informing the Data Subject of the information contained in the Privacy Policy.

    Right to object: this refers to the possibility for the Data Subject to prevent the use of his or her data when they are subject to processing based on a public interest mission or legitimate interest, including profiling and when the purpose of the processing is direct marketing, also including profiling.

    Right not to be subject to automated individual decisions: this refers to the right not to be subject to decisions based solely on profiling.

    All users may exercise any of the rights by writing to the RESPONSIBLE at Plaza de América number 2, 4AB, 46004 - Valencia or by sending an email to

    However, when you receive any communication by email, you can also object from that email, by clicking on the link included in it and following the instructions provided.

    In case you feel that your rights regarding the protection of your personal data have been violated, especially when you have not obtained satisfaction in the exercise of your rights, you may file a complaint with the competent Data Protection Supervisory Authority in Spain, through its website:

    What are the obligations of the Data Subject?

    It is the obligation of the Data Subject to provide truthful data and keep them updated, so RESPONSABLE reserves the right to exclude from the services and proceed to the cancellation of the service to any user who has provided false data, without prejudice to other actions that may apply in law.

    What are the consequences of not providing the data?

    Failure to provide the data hinders the operation of the Mobile Application and the provision of the RESPONSIBLE's services, as well as the impossibility of responding to queries and requests from Stakeholders.

    7.Changes to the Privacy Policy

    This Privacy and Security Policy may be updated due to changes and legal requirements, as well as due to improvements and changes included in the way of offering and providing the services and utilities of the Mobile Application. Therefore, we recommend that you visit and access this Privacy and Security Policy periodically, in order to have access and know the latest changes that may have been incorporated. In the event that such changes relate to the consent provided by the Data Subject, a separate and independent notification will be sent to the Data Subject to collect it again.

    If you have any questions or concerns about this Privacy and Security Policy while reading it, please contact the RESPONSIBLE at the following e-mail address