Privacy Policy for the Breaks apps

Last updated: 5 October 2026

This privacy policy applies to every mobile application of the Breaks the App platform available on Google Play and the App Store (the “app”):

• Breaks Can Buch (com.breaks.canbuchapp)
• Breaks Puig Arnau - Pubilló / Breaks Puig Arnau-Pubilló (com.breaks.canalda)
• Breaks Mas Salagros (com.breaks.mas_salagros)
• Breaks basecamps / Breaks Basecamps (com.breaks.basecamps)
• Breaks Puigpinós Hotel Japonés / Breaks Hotel Japonès Puigpinós (com.breaks.hotel_japones)
• Breaks Cabanyes entre Valls (com.breaks.cabanyes_entre_valls)
• Breaks L'Avenc de Tavartet / Breaks L'Avenc (com.breaks.avenc)
• Breaks Camping Cala Pola / Breaks Cala Pola (com.breaks.cala_pola)
• Breaks Mas Pineda (com.breaks.mas_pineda)
• Breaks Parador de Arties (com.breaks.parador_arties)
• Breaks l'indret del Pedraforca / Breaks L'indret del Pedraforca (com.breaks.pedraforca)
• Breaks Hotel Can Xiquet / Breaks Can Xiquet (com.breaks.can_xiquet)

1. Who is the controller and who publishes the app

Data controller: SILVESTRE STUDIO SL, tax ID B44920254, Can Puig s/n, 08255 Castellfollit del Boix (Barcelona), Spain. Email: [email protected].

Developer and store publisher: the app is developed and published on Google Play (developer account “omitsis”) and on the App Store by OMITSIS CONSULTING SL, Calle Casp 162, 2nd floor, 08013 Barcelona, Spain, email [email protected], on behalf of SILVESTRE STUDIO SL. OMITSIS CONSULTING SL also runs the app's servers and processes data as a data processor.

For any privacy question you can write to either of the addresses above.

2. What data we process and why

The app does not require registration or a password. We only process the following data:

• Random installation identifier. When you first open the app, a random identifier is generated and stored on your device. It is not linked to your name, your email or any device or advertising identifier, and it is lost if you uninstall the app. We use it to group the usage data of a single installation.
• App usage data. Screens viewed, stations started and completed, time between itinerary points, position of taps on the screen, answers to activities and questionnaires, ratings and comments you write when closing a station, operating system, app version, and date and time. We send them to our servers together with the random identifier to produce statistics and improve the experience.
• Precise location, including in the background. With your permission, the app uses GPS to show your position on the map, guide you along the itinerary and detect when you reach each station, even with the screen off while you are on the route. Location is processed only on your device: it is not sent to our servers or shared with third parties. Only the stations you have reached are recorded, as usage data. You can withdraw the permission at any time in your device settings.
• IP address. Received by our servers and by the map server when they communicate with the app. Used to deliver content and for security. We do not use it to locate you.
• Camera, photos and notes. With your permission, the app uses the camera so you can take photos during the route. Photos and personal notes are stored only on your device and are not sent to our servers. They only leave your device if you choose to email or share your summary (see below).
• Name or nickname and email address (optional). If you enter them, they are stored on your device and used only to personalise and send you the summary of your experience. They are not sent to our servers.
• Summary by email (optional). If you request it, the app sends an email to the addresses you enter, with screenshots of your route summary, which may include your photos, notes and answers. The email is sent through the mail server of the establishment associated with the app, which delivers it to the recipient. The controller does not keep a copy.
• Sharing. If you use the share option, your operating system lets you choose the destination app. Whatever you share is subject to that app's policy.

The app shows no ads, uses no third-party advertising or analytics SDKs, and does not sell personal data.

3. Legal basis

• Consent (Art. 6(1)(a) GDPR): location, camera, name and email, and sending the summary. You can withdraw it at any time without affecting the lawfulness of prior processing.
• Legitimate interest (Art. 6(1)(f) GDPR): usage data linked to the random identifier, and IP address, to produce statistics, keep the service secure and improve the app.

4. Who we share data with

We do not disclose personal data to third parties unless required by law. The following providers are involved in delivering the service:

• OMITSIS CONSULTING SL: development, hosting and maintenance of the app's servers (data processor).
• Cloudflare, Inc.: content delivery and protection for the servers; receives the IP address and the traffic between the app and the server.
• Institut Cartogràfic i Geològic de Catalunya (ICGC): provides the map images; receives the IP address and the map areas downloaded, not your GPS position.
• The establishment's email provider: only if you request the summary by email.

5. International transfers

Data is processed mainly within the European Economic Area. Cloudflare, Inc. may process data outside the EEA; in that case the transfer relies on the EU-U.S. Data Privacy Framework and on the standard contractual clauses approved by the European Commission.

6. Retention and deletion

• Usage data linked to the random identifier is kept for up to 24 months from collection. After that it is deleted or irreversibly anonymised.
• Data stored on your device (identifier, photos, notes, name, email and progress) is deleted when you uninstall the app or clear its data in your device settings.
• Server technical logs, which include the IP address, are kept for up to 90 days.
• Summary emails are not stored on our servers.

To request deletion of the usage data sent from your installation, write to [email protected] stating the app name and the approximate date of use. We will delete it within 30 days.

7. Security

All communication between the app and our servers is encrypted with HTTPS (TLS). Server access is restricted to authorised staff and protected by credentials. Data that stays on the device is stored in the app's private storage. We apply technical and organisational measures appropriate to the risk, in line with the GDPR. Even so, no system connected to the Internet is completely invulnerable.

8. Your rights

You can exercise your rights of access, rectification, erasure, objection, restriction of processing and portability, and withdraw your consent, by writing to [email protected] or by post to SILVESTRE STUDIO SL, Can Puig s/n, 08255 Castellfollit del Boix (Barcelona), Spain. If you believe your request has not been handled properly, you can file a complaint with the Spanish Data Protection Agency (www.aepd.es).

9. Children

Children under 14 may only provide optional personal data (name or email) with the consent of their parents or guardians.

10. Changes to this policy

We may update this privacy policy. We will publish the new version at this same address with its update date and, if the changes are significant, we will let you know in the app.