Privacy Policy
At Thril. (“we”, “us”, “our” or the “app”) we respect your privacy. This policy describes how we collect and process personal data when you use our website or the Thril. app (including the web and mobile versions), join the waitlist or interact with us.
1. Data controller
The controller of your personal data is the entity that operates Thril. and the thril.app domain. To exercise your rights or for any privacy enquiry you can write to hola@thril.app.
2. Data we may process
Depending on how you interact with us, we may process, among others:
- Waitlist data: email address and, if you tell us, city or another preference we request in the form.
- Account and profile in the app: if you create an account, we may process user identifier, email address, profile data you complete (for example name, city, preferences or bio), profile images you upload, as well as plans or collections you save in the app.
- App usage: interactions with activities (for example saves or attendances), visits or places detected or recorded, and samples of location or areas visited when you enable location-based features on the mobile device, as described in the app itself.
- Usage analytics data: if you give your consent, we collect usage data in an aggregated and pseudonymised form (for example, pages or screens viewed, navigation events, device and browser type) through an analytics provider hosted on servers in the European Union. We do not use this analytics until you accept it (on the website, via the cookie banner; in the app, via the “Usage analytics” setting), and we do not sell this data. You can withdraw consent at any time.
- Contact data: information you voluntarily send us by email or other channels.
- Technical data: information that the servers or providers necessary for the secure operation of the site and the app may generate (for example, technical or security logs), where strictly necessary.
- Profile data in the app: if you create an account, we may process the information you voluntarily enter (preferences, optional demographic data or data about your household, such as approximate ages of minors when you choose to indicate them to personalise recommendations). That information is always provided by the account holder, who must act with legal capacity and, where applicable, with the corresponding parental authorisation.
3. Purposes and legal bases
We process your data to:
- Manage the waitlist and inform you about Thril.’s launch and news, on the basis of your consent or, where applicable, the legitimate interest in keeping in contact with people who have requested information.
- Provide the app service (account, profile, recommendations and features you choose, including location-based ones when you enable them), on the basis of performance of the service-use contract or, where applicable, your consent for optional processing.
- Respond to your requests and provide support, on the basis of the pre-contractual or contractual relationship or legitimate interest.
- Measure in aggregate and improve the use of the website and the app through analytics, solely on the basis of your consent, which you can withdraw at any time without affecting the rest of the service.
- Comply with legal obligations and protect the security of the service, on the basis of legal compliance or legitimate interest.
4. Retention
We keep data for as long as necessary for the stated purposes and, where applicable, the applicable legal periods. If we no longer need your data for those purposes, we will delete or anonymise it unless a retention obligation applies. Usage analytics data is kept in an aggregated or pseudonymised form according to our analytics provider’s retention settings and stops being collected as soon as you withdraw consent.
5. Recipients and processors
We may use trusted providers that supply us with hosting, infrastructure, authentication and database services (for example Supabase), email or product analytics (an analytics provider with cloud processing in the European Union), acting as processors under our instructions and with appropriate contractual safeguards. Analytics is processed in the EU and is only activated with your consent. If any processing involves international transfers, we will adopt the safeguards provided for in the applicable regulations.
6. Your rights
Under Regulation (EU) 2016/679 (GDPR) and Spanish law, you can exercise the rights of access, rectification, erasure, restriction, portability and objection, as well as withdraw consent at any time where processing is based on it. You can also lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).
If you have an account in the app, you can download a structured copy in JSON format of the personal data linked to your account from the profile section (“Export my data”). For any other exercise of rights, or if you prefer not to use the app, write to hola@thril.app stating your request and a reliable means of identification where necessary.
7. Minors
In Spain, a minor’s own consent in the area of online information is usually set from the age of 14 (article 7 of Organic Law 3/2018 on the Protection of Personal Data and the guarantee of digital rights, consistent with the GDPR). Therefore, the Thril. website and app are not intended for children under 14 to use on their own or to provide us with data directly.
If you are between 14 and 17 years old, you should only use the service and sign up with the agreement of whoever holds parental authority or guardianship, where the law requires it.
The profile sections that allow you to indicate information about minors (for example, children’s ages) exist so that an adult account holder can improve recommendations; they should not be used for a minor to register data on their own. The discovery categories (for example, activities aimed at families or children) are editorial and search content about places and plans; they do not imply that the service is aimed at minors as autonomous users.
If you become aware that we have collected a minor’s data without the appropriate legal basis, write to hola@thril.app so that we can review it and take appropriate measures.
8. Changes to this policy
We may update this policy to reflect legal or service changes. We will publish the current version on this page with the “last updated” date. We recommend reviewing it periodically.