Privacy policy
How PASEO LAB, SOCIEDAD LIMITADA handles the personal data of people who create routes on caminata.app and of people who walk them with the Caminata app.
Last updated: August 31, 2026
This is a courtesy translation. Only the Spanish version is legally binding.
1. Data controller
| Field | Value |
|---|---|
| Controller | PASEO LAB, SOCIEDAD LIMITADA |
| Spanish tax ID (NIF) | B93819027 |
| Address | C. Sant Pere Més Baix, 32, Piso 2, Puerta 3, 08003 Barcelona, Spain |
| Contact | privacy@caminata.app |
No data protection officer has been appointed: none of the cases in article 37 GDPR or article 34 of the Spanish Data Protection Act applies. Any question about this policy is answered at privacy@caminata.app.
2. What data we process
Route creators. When you sign in with Google we receive and store the email address and the name on your Google account. We also store the country and language you set in your preferences, your notification settings, the IP address and date of your last sign-in, and — if you enable payouts — your Stripe account identifier. We store no passwords: authentication is performed by Google.
Route content. The texts, point coordinates and route data are stored exactly as the creator writes them, translated automatically into the platform languages and illustrated with generated images. If a creator includes personal data about other people in a route text, it is the creator who decides to include it and who is accountable for it.
Route buyers. There is no user account, no registration, no password and no email address. For each purchase we keep the original transaction identifier assigned by Apple, the route and language bought, the date, the amount and the currency. That identifier is a pseudonym: it contains no name, email, device or location, and on its own it does not identify a person. We nevertheless treat it as pseudonymised personal data, in line with recital 26 GDPR.
Technical data. The web server logs the requests it receives (IP address, date, requested resource and user agent). When an error occurs, a technical report is sent to our monitoring service, which is explicitly configured to exclude personal data, IP addresses and cookies.
We use no web analytics, no profiling, no advertising and no social network integrations. We neither buy nor sell contact databases.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Creating and maintaining the creator account, publishing routes and settling creator earnings | Performance of a contract (art. 6(1)(b) GDPR) |
| Delivering the purchased route and allowing it to be restored on the device | Performance of a contract (art. 6(1)(b) GDPR) |
| Keeping accounting and tax records of sales and payouts | Legal obligation (art. 6(1)(c) GDPR; art. 30 Spanish Commercial Code; art. 66 General Tax Act) |
| Reviewing each route before it is published | Legitimate interest (art. 6(1)(f) GDPR): ensuring that what is offered for sale is lawful and of adequate quality |
| Recording the IP address and date of last sign-in, and keeping server logs | Legitimate interest (art. 6(1)(f) GDPR): service security and abuse prevention |
| Keeping the email address of a deleted account to prevent it from registering again | Legitimate interest (art. 6(1)(f) GDPR): preventing closed accounts from reappearing |
| Emailing creators when a route is approved or rejected | Performance of a contract (art. 6(1)(b) GDPR). Creators can switch these emails off in their settings |
4. Recipients and processors
We do not pass personal data to third parties for their own purposes. To run the service we use the following providers, acting as processors on the controller's behalf:
| Provider | Purpose | Location |
|---|---|---|
| Hetzner Online GmbH | PurposeServer, database and service files | LocationGermany; data centre in Finland (EU) |
| Cloudflare, Inc. | PurposeDomain registration, DNS and forwarding of incoming mail addressed to the caminata.app domain | LocationUnited States |
| Apple Distribution International Ltd. | PurposeApp distribution, in-app purchase payments and server notifications about transactions and refunds | LocationIreland (EU) |
| Stripe Payments Europe, Ltd. | PurposePaying creator earnings and the identity verification required by anti-money-laundering rules | LocationIreland (EU) |
| OpenAI Ireland Ltd. | PurposeAutomatic translation of route content and generation of illustrations | LocationIreland (EU) |
| Resend, Inc. | PurposeSending notification emails to creators | LocationUnited States |
| Functional Software, Inc. (Sentry) | PurposeTechnical error logging, configured without personal data | LocationUnited States, with storage in the service's European region |
| Backblaze, Inc. | PurposeStorage of database and media backups | LocationUnited States |
Where some data comes from. A creator's email address and name are provided to us by Google Ireland Limited when the creator authorises sign-in with their Google account; as regards that authentication, Google acts as an independent controller under its own privacy policy. The coordinates a creator enters are looked up against the OpenStreetMap Foundation's Nominatim service to determine the city and country; no personal data is sent in that lookup.
5. International transfers
Providers established outside the European Economic Area (Cloudflare, Resend, Sentry and Backblaze) process data under the standard contractual clauses approved by the European Commission and, where applicable, under the EU–US Data Privacy Framework. You may request a copy or details of these safeguards by writing to privacy@caminata.app.
6. Retention periods
| Data | Period |
|---|---|
| Creator account and draft content | For as long as the account is active |
| Email address of a deleted account | Kept without a time limit, for the sole purpose of preventing a new registration with the same address |
| Already published routes of a deleted account | Reassigned to the administrator account and kept available to people who already bought them |
| Purchase, earnings and payout records | Six years from the last entry (art. 30 Spanish Commercial Code); at least four years for tax purposes (art. 66 General Tax Act) |
| IP address and date of last sign-in | Overwritten at each new sign-in; no history is kept |
| Web server logs | The period set by system log rotation |
| Technical error reports | According to the monitoring provider's retention policy |
| Database backups | 60-day rotation; after that the copy is deleted |
A requested deletion is carried out immediately in the live system, but the data may remain in backups until those are rotated. During that interval it is not used for any other purpose.
7. Your rights
You may exercise your rights of access, rectification, erasure, restriction of processing, portability and objection by writing to privacy@caminata.app. There is no charge, and we respond within one month.
Creators. Most of these rights can be exercised directly from account settings: editing the profile, switching notifications off, signing out of all devices, or deleting the account.
Buyers. Because there is no account and no identifying data, to act on a request about a purchase we need the corresponding Apple transaction identifier. If it cannot be provided, we are not in a position to identify the data subject within our systems and article 11(2) GDPR applies.
If you believe the processing does not comply with the law, you may lodge a complaint with the Spanish Data Protection Agency (AEPD), C/ Jorge Juan 6, 28001 Madrid — https://www.aepd.es.
9. Minors and automated decisions
The creator panel is intended for adults, since it involves entering into a contract and receiving payments. The app is not directed at children under fourteen (art. 7 of the Spanish Data Protection Act).
We take no automated decisions producing legal effects on individuals or similarly significantly affecting them. Translation and illustration of content happen automatically, but they act on route content rather than on people, and every publication also passes through human review.
10. Changes to this policy
When the service changes — for example if a new provider or a new purpose is added — this policy is updated and the date at the top changes with it. Substantial changes are additionally communicated by email to registered creators.