Privacy Policy

PRIVACY POLICY

At the Puçol Town Hall we are committed to protecting privacy and the correct use of personal data.

This Privacy Policy aims to inform you about the processing of personal data carried out by the Puçol City Council on this website, its electronic headquarters and on any of its subdomains, microsites and associated mobile applications.

1. Who is responsible for processing your personal data?

The Puçol City Council is the Data Controller, and is advised and supervised for adequate protection by our Data Protection Officer.

Responsible: Puçol City Council

Postal address: Plaça Sant Joan de la Ribera, s/n — 46530 Puçol (Valencia)

Electronic headquarters: [CHECK: Official URL]

Data Protection Officer: dpo@pucol.es

2. What personal data do we process and for what purpose?

We only process personal data when you voluntarily provide it through the website's functionalities. Specifically:

a) Tourist mailbox / Complaints and suggestions mailbox. We collect your name, surname, email address, reason for the message, and message content. The purpose is to address and manage your communication and, if applicable, respond to you. Submitting the form requires express acceptance of this Privacy Policy by checking a box.

b) Participation in citizen surveys. We collect responses to the questions in each survey. The surveys do not collect direct personal identification unless the specific form explicitly requests it, in which case this is indicated in the survey itself. The purpose is to understand citizens' opinions on tourism and municipal management issues.

c) Generation of personalized tourist itineraries using artificial intelligence. If you use the itinerary recommender, the tourist preferences you voluntarily indicate (interests, duration, type of activity) are sent to a third-party artificial intelligence provider to generate the recommendation. These preferences are not stored on our servers. See Section 6 for information on international transfers.

d) Gamification "Explore Puçol". If you participate in the experience of discovering tourist landmarks using QR codes, the information about the landmarks visited is stored exclusively in your browser's local storage (LocalStorage). The City Council does not receive or store this information on its servers.

e) General browsing data. When you browse the website, we may collect anonymous technical information for statistical purposes using our own web analytics tools (see Section 4). This information does not allow us to personally identify you.

In your case, more specific purposes are indicated in the information clauses incorporated in each of the data collection methods (web forms, paper forms, voice messages or posters and information notes) for specific cases.

3. What is the legal basis that legitimizes the processing of your personal data?

The legal basis that legitimizes us to process your personal data depends on the specific flow:

Consent of the interested party (Art. 6.1.a of the General Data Protection Regulation): for voluntary forms, optional functionalities such as web analytics, AI-powered route generation or gamification.

Fulfillment of a mission carried out in the public interest or in the exercise of public powers (Art. 6.1.e GDPR): for citizen services (Mailbox) and the provision of municipal services.

Compliance with a legal obligation (Art. 6.1.c GDPR): when legislation obliges us to collect or retain certain data.

Protection of vital interests and execution of a contract in the legally provided cases.

Providing the requested data is mandatory when it is essential to fulfill your request or provide the requested service; if you do not provide it, we will not be able to carry it out or provide it.

When the processing is based on your consent, this will be understood to be given unequivocally through a clear affirmative act (checking the box on the form, accepting analytics in the cookie banner, etc.) and you may withdraw it at any time without retroactive effect.

4. What cookies and technical tools do we use?

The website uses a minimal number of technical tools. We do not use advertising cookies, third-party tracking for marketing purposes, or user profiling for data sale.

4.1. Strictly necessary cookies

They are essential for the website to function (navigation, security, language preference, accessibility). They do not require prior consent in accordance with Article 22.2 of the Law on Information Society Services and Electronic Commerce (LSSI-CE).

They include:

- Language selector cookie to remember the chosen language (es / va / en).

- Local storage of accessibility preferences (font size, high contrast).

- Anti-bot validation token generated by Cloudflare Turnstile during form submission.

4.2. Web analytics using self-hosted Umami

To understand which tourism content is most useful and improve the visitor experience, we use Umami, a web analytics tool self-hosted by the City Council on its own infrastructure. Its privacy features are as follows:

It does not use persistent cookies or unique device identifiers. It generates temporary identifiers that rotate every 24 hours using a cryptographic hash with salt, making it impossible to track a visitor over time.

It does not store the visitor's IP address. The IP address is used only to determine the country of origin of the visit and is immediately discarded. It is not recorded in any database.

It does not share data with third parties. All information is processed and stored on the City Council's own servers within the European Union.

It does not perform device fingerprinting (it does not build unique profiles from the visitor's browser characteristics).

It is auditable free software (MIT license).

The statistical information collected is anonymous and aggregated: pages visited and approximate time spent on each, language chosen, country of origin of the visit, type of device and generic browser, and non-personal tourist interactions (milestones added to itineraries, searches performed, 360º scenes viewed, generation of itineraries with AI, language change).

The legal basis for this analysis is [REVIEW: we propose] the legitimate interest of the City Council (Art. 6.1.f GDPR) in improving the public tourism service, duly balanced against the visitor's right to privacy. Since the tool is technically equivalent in terms of privacy to tools with formal exemption from the French data protection authority (CNIL) in its privacy mode, the balance is favorable.

You can object to this analytics at any time from the website's cookie preferences banner, which is permanently accessible from the footer.

4.3. Embedded third-party technologies

The website incorporates the following technologies from third-party providers, which are essential for its functionality:

Google Maps Platform and OpenStreetMap are used for map display and geolocation of tourist landmarks. No personal visitor data is transmitted.

Cloudflare Turnstile, for anti-bot validation on public forms. It collects technical browser information without direct personal identification.

OpenAI is used for the AI-powered generation of personalized tourist itineraries. User preferences are sent to this provider to generate the recommendation. See Section 6 regarding international transfers.

Google Cloud Translation is used internally for the automatic translation of editorial content between the site's official languages. It does not process visitors' personal data.

5. How long do we keep your personal data?

In general, we will retain the personal data you provide to maintain a care record and manage our services efficiently. Specifically:

Tourist Mailbox Messages: 3 years from its closure or last update, except for legal obligations or exercise of rights.

Citizen survey responses: 5 years from the date of the survey, for statistical use and longitudinal analysis.

Analytical browsing data (Umami): 12 months, after which it is added or deleted.

General data: as long as the status of citizen of Puçol is maintained and the interested person does not request its deletion.

Even after a request for deletion, the data will remain blocked for the necessary time, limiting its processing only for one of these cases: complying with legal or contractual obligations of any kind to which we are subject, during the legal periods provided for the statute of limitations of any liability on our part, and the exercise or defense of claims arising from the relationship maintained with the citizen or interested party.

6. Who can be recipients of your personal data and where is it processed?

6.1. Recipients within the Administration

The data you provide may be communicated to:

- Other Public Administrations when there is a legal obligation to communicate.

- Municipal services and entities dependent on the City Council involved in the provision of the requested service.

- Security Forces and Corps and Judges or Courts in compliance with legal obligation.

- Public or private entities or organizations with which we reach agreements to develop social, cultural or sporting projects, or collaboration agreements, always with an appropriate legal basis.

6.2. Data Processors

For some technical services, we use providers who act as Data Processors, bound by contract in accordance with Article 28 of the GDPR:

Peninsula Corporate Innovation: development and technical maintenance of the website and content management system. Processing within the territory of the European Union [REVIEW: specific country].

OpenAI L.L.C.: processing of the text sent to the tourist itinerary recommender. Processing in the United States.

Google LLC: Map services and internal translation of editorial content. Processing in the United States and other regions.

Cloudflare, Inc.: Anti-bot validation on forms. Processing on their European infrastructure.

6.3. International data transfers

Some of the listed providers process data in countries outside the European Economic Area, primarily the United States. These transfers are carried out under the following safeguards:

- The Adequacy Decision between the European Union and the United States (Data Privacy Framework) of July 10, 2023, when the provider is certified under this framework. OpenAI, Google, and Cloudflare adhere to the Data Privacy Framework.

- Standard Contractual Clauses approved by the European Commission, where the above decision does not apply.

- Additional technical measures: encryption in transit and at rest, restrictive access controls.

In the AI-powered route generation functionality, we recommend that users do not include personally identifiable information in the preference fields, as the entered text is sent to the external provider for processing.

6.4. Sovereignty of analytical data

The web analytics tool described in Section 4.2 (Umami) operates exclusively on infrastructure belonging to the Puçol City Council located within the European Union. The analytical data does not leave the municipal servers and is not shared with any external provider. Therefore, there is no international data transfer for this purpose.

7. What security measures do we apply to protect your data?

The City Council applies the technical and organizational measures required by the GDPR and the National Security Scheme to protect personal data against unauthorized access, accidental loss, alteration or disclosure.

These measures include, among others: encryption in transit using HTTPS/TLS, encryption at rest of databases containing personal data, role-based access control for authorized personnel, periodic logging and auditing of access, encrypted backups with a continuity plan, and pseudonymization or anonymization of data whenever technically possible.

8. What are your data protection rights and how can you exercise them?

As an interested party, you have the right to:

Access: to know what data we process about you.

Rectification: correcting inaccurate or incomplete data.

Erasure (also known as the right to be forgotten): requesting the deletion of your data when it is no longer necessary for the purposes for which it was collected.

Limitation of treatment: request that we limit the processing while a dispute is being verified.

Objection: to object to processing based on legitimate interest, such as web analytics.

Portability: receiving your data in a structured and reusable format.

Not to be subject to automated decisions with significant effects without human review.

Withdraw previously given consent, without retroactive effect.

To exercise any of these rights, you may submit a written request to:

- The Entry Registry of the Town Hall: Plaça Sant Joan de la Ribera, s/n — 46530 Puçol (Valencia).

- The Electronic Headquarters of the City Council: https://www.pucol.es/

- Our Data Protection Officer: dpo@pucol.es.

In your written request, you must specify which of these rights you wish to exercise and, in addition, provide a copy of your National Identity Document (NIF) or equivalent identification document, or, if submitted by mail, include a photocopy of it. If you are acting through a legal or voluntary representative, you must also provide a document proving the representation and the representative's identification document.

We will respond to your request within a maximum of one month from receipt, extendable to two additional months in complex cases, after informing you.

9. Where can I file complaints?

If you believe that the processing of your data does not comply with the regulations, or that we have not adequately addressed the exercise of your rights, you may file complaints with:

- Our Data Protection Officer: dpo@pucol.es.

- The Spanish Data Protection Agency (AEPD): https://www.aepd.es/

10. Duration and modification of this Policy

The City Council may modify the content of this Privacy Policy, in whole or in part, to adapt it to regulatory, technical or organizational changes.

When changes significantly affect the processing of your data (new purposes, new recipients, new legal bases), we will proactively inform you by posting a prominent notice on the website's homepage for at least thirty calendar days. If you have given consent for any of the affected purposes, we will ask you to renew your consent on your next visit.

The validity of this Privacy Policy coincides with the time of its exposure, until it is modified in whole or in part, at which time the modified Privacy Policy will become valid with the new update date at the beginning of the document.