Privacy Policy · Sfera Civitas

How we process your data on the website, the web app and the iOS/Android apps. · Español

Version v3.0 · 21 October 2026. The Spanish version (privacidad.html) prevails in case of discrepancy.

In short. The controller is LA GARRIDA EMOTIONS S.L. To take part you create an account with your email. What you do on the platform (supports, arguments, proposals and votes) may reveal your political opinions, so we only process it with your explicit consent, which you can withdraw at any time. Encrypted, secret ballot: we record that you voted, not how. Data is stored on servers in the EU. We do not sell your data. You can download your data or delete your account from the app at any time.

Contents

1. Data controller

2. What data we process and why

2.1 Account

To create your account and sign in we process your email address and your password. The password is never stored in plain text: it is stored transformed with scrypt, an algorithm that does not allow it to be recovered. We also keep an internal user ID and a record of what you accepted when signing up (terms, consent and age declaration) with its date. Purpose: to give you access and provide the service.

2.2 Participation (data that may reveal political opinions)

When you take part in an issue we process your supports, arguments, proposals, the documents or links you upload and your vote. This information may reveal your political opinions, a special category of data (Art. 9 GDPR). We therefore only process it with your explicit consent (Art. 9(2)(a) GDPR), which you give when signing up by ticking a specific box.

2.3 Identity verification with a digital certificate or Spanish eID (DNIe)

If you choose to verify your identity with a digital certificate or DNIe, we check the certificate and keep only an encrypted fingerprint (HMAC) of your NIF, used to prevent duplicate accounts. We do not store your NIF, your name or the certificate. Verification is optional and based on your explicit consent.

2.4 Organisations and invitations

An organisation (association, residents' community, school, etc.) can create a private space and invite people. For this we process the invited person's email, provided by the organisation, and their membership and role in that space. If you were invited and do not accept, the invitation is deleted 30 days after it expires.

2.5 Payments

If an organisation buys a private space, payment is handled by a payment provider acting as seller (merchant of record: Lemon Squeezy or Paddle), which is an independent controller of that payment. We receive the transaction data (amount, date, description and payment identifiers) and keep it to meet commercial and tax obligations. We do not see or store your card details.

2.6 Support

If you write to hola@sferacivitas.org or open a request from the app, we process your email and what you tell us in order to reply.

2.7 Moderation and reports

If you report content or block a user, we process the report (who reports, which content and why) and the moderation decisions taken. Purpose: keeping the platform free of illegal or abusive content and complying with the Digital Services Act (DSA).

2.8 Public expert profiles

If you appear as a verified expert on a subject, we process your expert profile data: display name, specialty, credentials and organisation and, if provided, a contact email. The name, specialty, credentials and organisation are published with a verified-expert badge, because their purpose is precisely to inform the public debate. You can ask us to correct or remove your profile by writing to hola@sferacivitas.org.

2.9 Notifications

We send you notices inside the app and, where relevant, by email (for example verification codes or notices about your account).

2.10 Technical data and security

When you use the service, our hosting providers log technical data such as your IP address and the time of the request. We use it for security, rate-limiting sign-in attempts and preventing abuse.

2.11 Website analytics (only with your consent)

On sferacivitas.org we use Google Analytics 4 and Metricool to measure visits in aggregate, only if you accept them in the cookie notice. If you do not, they are not loaded. You can change your mind in Cookie preferences. More detail in the Cookie Policy.

What we don't do: we do not sell your data, use it for advertising, collect your precise location or build commercial profiles.

Do you have to give us your data? Email and password are needed to have an account. Consent to process your participation is needed to take part. Certificate verification and website analytics are optional.

3. Legal bases

ProcessingLegal basis
Account and use of the servicePerformance of the contract: the Terms of Use (Art. 6(1)(b) GDPR)
Participation (supports, arguments, proposals, votes), which may reveal political opinionsExplicit consent (Art. 9(2)(a) GDPR), collected at sign-up with a specific box and withdrawable at any time
Identity verification with a digital certificate or DNIeExplicit consent (Art. 6(1)(a) and, where applicable, 9(2)(a) GDPR)
Security, abuse prevention, moderation and rate limitsLegitimate interest (Art. 6(1)(f) GDPR) and Digital Services Act (DSA) obligations
Payments and invoicingPerformance of the contract and legal obligation (Art. 6(1)(b) and 6(1)(c) GDPR)
SupportLegitimate interest in assisting you and performance of the contract
Website analytics (Google Analytics 4, Metricool)Consent (Art. 6(1)(a) GDPR and Art. 22.2 of the Spanish LSSI), withdrawable in «Cookie preferences»

4. Recipients and processors

We do not disclose your data to third parties except where required by law (for example, a court order). To provide the service we use these providers, under a data processing agreement (DPA) or acting as independent controllers:

ProviderRoleData locationSafeguards
SupabaseDatabaseEU (Ireland)Supabase Inc. (USA): DPA + Standard Contractual Clauses (SCC) / EU-US Data Privacy Framework (DPF)
RenderAPI serverEU (Frankfurt)Render Services Inc. (USA): DPA + SCC / DPF
NetlifyWeb hosting and forwarding requests to the API (sees your IP)Global network (CDN)Netlify Inc. (USA): DPA + SCC / DPF
Zoho Corporation (Zoho Mail EU)Account and support emailEU (Zoho EU data centres)Zoho Corp. B.V. / India: DPA + SCC
Google (Google Analytics 4)Website analytics, only with consentUSA / EUGoogle Ireland Ltd. / Google LLC: DPF
MetricoolWebsite measurement, only with consentEU (Spain)Metricool Software S.L.
Lemon Squeezy / PaddlePayment for private spaces (if purchased)USA / United KingdomIndependent controller of the payment; SCC / DPF
Apple / GoogleApp stores—Independent controllers of their stores

The list of municipalities is served from our own domain, without third-party networks. What you publish in an issue (arguments, proposals, documents) is visible to other participants; your vote is not.

5. International transfers

Platform data is stored in the EU. However, some providers have their parent company outside the European Economic Area (USA, India or United Kingdom) and might access data in specific cases (for example technical support), and Netlify and Google may process data outside the EU. In those cases the transfer relies on the EU-US Data Privacy Framework (DPF), where the company is certified, or on the Standard Contractual Clauses (SCC) approved by the European Commission. You can ask us for more information at hola@sferacivitas.org.

6. How long we keep data

DataPeriod
Account and contributionsWhile the account is active. When you delete it, your identity is erased and the content becomes anonymous (immediately).
Encrypted ballots and voting bulletin boardPermanent, without identity: needed so anyone can verify the result.
Record that you votedUntil the vote closes + 90 days; then aggregated or anonymised.
Notifications180 days
Verification codes and certificate challenges24 hours
Unaccepted invitations30 days after expiry
Support requests12 months after closing
Payments6 years (commercial and tax obligation, Art. 30 Spanish Commercial Code). The full data sent by the payment provider is minimised after 30 days.
Moderation reports12 months after resolution
Provider backupsPurged within 90 days at most
Platform technical logs (IP)Those of the provider, 30 days at most
Website analyticsAccording to Google Analytics and Metricool settings; only exists if you accepted it

7. Your rights and how to exercise them

You have the right of access, rectification, erasure, objection, restriction of processing and portability, and to withdraw your consent at any time without affecting prior processing.

Please note we cannot give you or delete «your vote», because the ballot is not linked to your identity: we do not know which one it is.

8. Complaints to the AEPD

If you think we have not handled your data properly, you can lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD), C/ Jorge Juan 6, 28001 Madrid, www.aepd.es. We would appreciate it if you wrote to us first so we can try to solve it.

9. Minors

To create an account you must be at least 14 years old (Art. 7 of the Spanish LOPDGDD), and you declare this at sign-up. If you are younger, you cannot use the platform. If we learn that someone under 14 has registered, we will delete the account.

10. Security and ballot secrecy

Voting. Your vote is secret. Your ballot is encrypted on your device and sent without your identity; the system records that you voted, not how you voted. The result is obtained by adding up the encrypted ballots without opening them one by one, and anyone can check on the public bulletin board that their ballot is included. Today the tally keys are held by the service operator; we are distributing them among independent custodians.

11. Automated decisions and artificial intelligence

We do not take decisions based solely on automated processing that produce legal effects on you or similarly affect you, and we do not profile you. The only automatic rule is a safety one: content reported by several people is temporarily hidden until a human moderator reviews it.

Sfera Civitas does not use artificial intelligence systems to process your data or within the platform.

12. Cookies and local storage

The app stores on your device what it needs to work (your session, language, theme and your vote receipts). On the website we only use analytics cookies if you accept them. Full detail in the Cookie Policy.

13. Changes to this policy

If we change this policy, we will publish the new version on this page with its number and date. If the change is significant (for example a new use of your data or a relevant new provider), we will tell you in the app or by email and, if needed, ask for your consent again.

Version v3.0 · 21 October 2026.