Android App Id: com.passholder.passholder

*Disclaimer: The English version is a translation of the original in Spanish for information purposes only. In case of a discrepancy, the Spanish original will prevail. Read the original in Spanish

Date updated: Oct. 1, 2020

In accordance with Regulation (EU) 2016/679, of the European Parliament and the Council, of 27 April 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation - GDPR), Julián Rocabruna Puig (hereinafter, Pass-Holder), informs users of the application: PASSHOLDER (from now on, the Application), about the treatment of the personal data, which they have voluntarily provided during the process of registration, access and use of the service.


Julián Rocabruna Puig, with CIF/NIF nº: 43200262Y and address for notification purposes at C/ Don Ramón De La Cruz, 95, C.P. 28006 - Madrid (Madrid), (from now on, the Responsible for the Treatment), is the entity responsible for the treatment of the data provided by the clients of the Application (from now on, the User/s).


In order to proceed with the registration, access and subsequent use of the Application, the User must provide - on a voluntary basis -, personal data (essentially, identification and contact data), which will be incorporated into automated supports owned by Pass-Holder.

The collection, storage, modification, structuring and, if applicable, elimination of the data provided by the Users will constitute processing operations carried out by the Responsible for the Treatment, with the aim of guaranteeing the correct functioning of the Application, maintaining the service provision and/or commercial relationship with the User, and for the management, administration, information, provision and improvement of the service.

The personal data provided by the User -especially the electronic mail or e-mail- may also be used to send bulletins (newsletters), as well as commercial communications of promotions and/or advertising of the Application, provided that the User has previously given his express consent to receive these communications by electronic means.


The treatment of the User's data is carried out with the following legal bases that legitimize it:

In case the User does not provide Pass-Holder with his data, or does so in an erroneous or incomplete manner, it will not be possible to proceed with the use of the Application.


The personal data provided by the User shall be kept in the systems and databases of the Person Responsible for the Treatment, as long as he continues to make use of the Application, and provided that he does not request its deletion.

In order to refine the possible responsibilities derived from the treatment, the data will be kept for a minimum period of five years.


The data will not be communicated to any third party outside of Pass-Holder, unless legally obliged to do so or in any case, upon request of the User's consent.

On the other hand, Pass-Holder may give access or transmit the personal data provided by the User to third party service providers, with whom it has signed agreements for data processing, and who only access this information to provide a service for and on behalf of the Responsible for the Treatment


Pass-Holder, informs the User that, as a data hosting service provider and by virtue of the provisions of Law 34/2002 of 11 July on Information Society Services and Electronic Commerce (LSSI), retains for a maximum period of 12 months the information necessary to identify the origin of the data hosted and the time when the service began.

The retention of these data does not affect the secrecy of the communications and they can only be used in the framework of a criminal investigation or for the safeguard of public security, being made available to the judges and/or courts or to the Ministry that requires them.

The communication of data to the State Security Forces and Corps shall be made in accordance with the provisions of the regulations on the protection of personal data, and with the utmost respect for such regulations.


The Data Controller adopts the necessary measures to guarantee the security, integrity and confidentiality of the data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

While the Responsible for the Treatment, makes backups of the contents hosted on its servers, however not responsible for the loss or accidental deletion of data by users. Likewise, it does not guarantee the total replacement of the data deleted by the Users, since the aforementioned data could have been deleted and/or modified during the period of time that has elapsed since the last backup copy.

The services provided or rendered through the Application, except for specific backup services, do not include the replacement of the contents kept in the backup copies made by the Data Controller, when this loss is attributable to the user; in this case, a fee will be determined according to the complexity and volume of the recovery, always with the user's prior acceptance. The replacement of deleted data is only included in the price of the service when the loss of the content is due to causes attributable to the Controller.


Pass-Holder, informs the User that he has the rights of access, rectification, limitation, deletion, opposition and portability, which may be exercised by request addressed to the email:

Likewise, the User has the right to revoke the consent initially given, and to file claims for rights with the Spanish Data Protection Agency (AEPD).


In application of the LSSI (Law of Services of the Society of the Information), Pass-Holder, will not send advertising or promotional communications by e-mail or another equivalent means of electronic communication that previously had not been requested or expressly authorized by the addressees of the same ones.

In the case of users with whom there is a previous contractual, legal or service relationship, the Data Controller is authorized to send commercial communications concerning products or services of the Data Controller that are similar to those initially contracted with the customer.

In case the User wants to unsubscribe at the moment of receiving the mentioned communications, he will be able to do it sending his will by e-mail to: