Goin is a technological application, completely free of charge, that allows its users to achieve any objective they have set themselves in the app through automatic savings and investment. We want to be transparent with you and that you clearly know what we do with your personal data when you register and use the services of the Goin app.

Access to and use of the Goin app is regulated in General T&C and in this Privacy Policy in compliance with the General Data Protection Regulation 679/2016 (RGPD) and Organic Law 3/2018 on the Protection of Personal Data and the Guarantee of Digital Rights (LOPDGDD). We inform you that the use of the Goin application requires the acceptance of this company's Privacy Policy and if you do not agree with the content of these legal texts, you should not use the Goin app.

Responsible for the treatment

Prakma Innovation, S.L.U. (hereinafter,”Prakma” or the”Responsible”), with address at Calle Aribau 230-240 5th Floor, Office M-N, 08006, Barcelona. You can contact us via email gdpr@goin.app.

Purposes and characteristics of the treatment

You have the right to know what personal data we have about you, why we collect it, how long we keep it and what we use it for. To do this, we explain step by step the process of collecting your information, subsequent treatments we carry out on it and the applicable conservation periods for each of our purposes.

Registration in the Goin App

You need to have a personal account in the Goin app to access the services it offers, among other reasons, on the legal basis of the execution of the contractual relationship you have with Prakma for the access and use of the Goin app. In addition, this information is necessary to comply with our regulatory obligations and ensure the security of your information, as we inform you later. Therefore, during the registration process, we will ask you to provide us with:

1. Mobile phone number to which you link your personal user account and to which we will send a verification code during your registration.
2. First and last name.
3. Contact email to which to link your personal user account.
4. Date of birth.
5. Invitation code, in case you received an invitation to join the Goin app.
6. Access PIN which you must enter in the registry and which will be linked to your user account for greater security in your access to the Goin app.

This information is necessary for (a) generate your personal Goin user account based on the contractual relationship between you and Prakma for the use of the Goin app, in accordance with our General Terms and Conditions; (b) ensure the security of your future access and prevent any misuse of your personal account and the services of the Goin app, based on our legitimate interest in guaranteeing our users a safe and quality service; (c) verify your identity to comply with our regulatory obligations regarding the prevention of money laundering and terrorist financing; (d) to communicate with you when necessary for the execution of the contracted services, including by electronic means (limited to service communications, not commercial, unless you give your express consent to do so).

Use of the Goin app services

In order to use the savings and investment systems offered by the Goin app, as well as to provide you with advantages in your purchases, discounts or other promotions that we make available to users through the Goin app, based on the execution of the contractual relationship you have with Prakma and to comply with our regulatory obligations, we will need you to add your bank and card details so that they are synchronized to your personal account and to be able to provide you with the services you request from us through the Goin app.

1. Card number, expiration date and CVV. This information is necessary for (a) create your savings goals; (b) transfer your savings from your bank account to your Goin account, which you can withdraw back to your bank account whenever you want; (c) add money to invest with a direct charge to your card. Therefore, if we do not have this information, we will not be able to execute the savings and investment services you contract through the use of the Goin app.

2. Personal identification document (i.e. ID, NIE, Passport, driving license). When you enter your first €, we will ask you to provide us with a photograph of your ID, NIE, passport or driving license to verify your identity and to comply with the regulations on the prevention of money laundering and terrorist financing. At the same time, we will ask you to provide us with access to your mobile phone camera or device that you are using to take a video-selfie. We will also ask you for your ID or similar document that identifies you to verify your identity when you request a withdrawal of money to your bank account.

3. Banking institution and credentials for accessing online banking. This information is necessary to execute the savings services you contract through the use of the Goin app and to provide you with the best advantages and commercial discounts on your purchases, such as (a) reading the movements of your bank account so that you can automatically apply discounts and refunds to your purchases, as well as the automatic savings methods of retention and/or rounding that you configure yourself from the Goin app thanks to the linking of your card; (b) verify your identity when you want to withdraw the money saved in your personal account, to comply with our legal obligations and ensure the security of your money.
   
   With these credentials, we can ask your bank for access to your bank account in accordance with the PSD2 regulation. The access credentials you provide us are read-only, so no operations can be carried out on your account that you have not ordered from us beforehand.

4. Information about your banking operations. This information is necessary (a) in order to apply savings and investment methods, it is necessary to monitor your banking movements, since they are based on your expenses, income, risk profile for investment operations, etc.; (b) we apply “cashback” programs in which you will receive refunds for a percentage of the price you paid when you make purchases at one of our partners' establishments, so we need to know the details of the transaction for validation and to offer you the benefits of the offer (visit our General Terms and Conditions to know the “Cashback” method); (c) We also help you monitor your expenses so that we can offer you insights or advice so that you can acquire your objectives in an optimal way.
   

5. Contact details for the referral program. The referral code, in Goin's General Terms and Conditions, you can share it with third parties and thus obtain different benefits, as long as you meet the requirements defined in those General Terms and Conditions. To do this, we need to access the contacts on your device to make it easier for you to send the code. When you open the Goin app on your device for the first time, we'll ask you to give us access to your contacts. If you accept, we inform you that such access serves only the purposes detailed here and that this information is not stored or shared with third parties.

6. Data on your use of the Goin app and its services. In accordance with the above points, in order to improve the execution of the services we offer you through the Goin app, and in accordance with applicable laws, we need to collect information from your bank accounts and payment cards, savings objectives linked to your Goin account, the position relative to the financial and investment products you have contracted through the Goin app. We may use this information (a) to send you alerts about movements, annotations, accumulated savings and/or liquidity needs as part of the execution of the Goin app services; (b) develop a financial behavior profile according to your level of income and expenses. We will not use your profile for automated decision-making that may affect you legally or in any other significant way, unless you have given us your express consent for a specific purpose (i.e. contracting an automated investment service). However, you will always be informed of the status of the services you contract through the Goin app, being able to take control at any time (c) to inspire other Goin users by making certain actions visible in the social feed, as also indicated in the General Terms and Conditions.

Treatments for advertising purposes

Whenever you give us your consent, we can keep you informed, including through electronic means, of the new products and services we offer in the Goin app, present you with offers from our partners for the purchase of products and services that you incorporate as savings objectives, as well as provide you with regular information through our Newsletter service. You can withdraw your consent at any time and we will remove you from our mailing list.

In addition, if you are a customer, Law 34/2002, of July 11, on information society services and electronic commerce allows us to send you information related to the services you have previously contracted with the Goin app. In any case, we will only send you information about our services when it is clearly interesting and truly beneficial to you, offering you the possibility to object to it in each communication or by communicating with Prakma through the means of contact indicated in this Policy, in accordance with information society services regulations.

Other compatible purposes

Based on our legitimate interest, we can anonymize personal data to obtain information on what products and services work best in the Goin app and are most interesting to our users, in order to enhance or improve them, as well as to carry out statistical and research studies on the consumer and financial sector, directly or through our partners.

For these purposes, we have implemented protection measures that guarantee the confidentiality of your information and the privacy of your identity, such as the selection of relevant and strictly necessary information for each of the studies we are going to carry out, the processing of aggregated data, as well as the irreversible anonymization of data through the encryption and unlinking of any information with your identification data and the blurring of exact data by applying rounding techniques, avoiding any form of re-identification and linking such data to your identity. This treatment is based on Prakma's legitimate interest in improving the services provided to its customers and does not harm the data protection rights of the interested parties. If you would like to object to such processing or to know more details about the legitimate interest weighting test carried out by Prakma, you can request it by sending an email to: gdpr@goin.app.

In cases where we have to share such information with third-party Parkma collaborators for these purposes, we will reinforce the implementation of these measures, with the objective of ensuring that no third party can access your personal information, preventing us from knowing details about your consumption habits, banking or card information, or any form of identification or linking of information to your person. We are aware of the technical difficulty of ensuring long-term anonymization, so in any case, as a sign of our commitment to providing you with transparent information and respecting your data protection rights, we regularly review the anonymization processes to identify risks, apply measures to mitigate them and in this way constantly reinforce your privacy.

Recipients of your personal data

Your personal data may be communicated to the following third parties, with whom we have signed collaboration agreements to be able to offer the services of the Goin app. In addition, we have contracts that regulate the communication and processing of personal data of Goin users, in order to ensure an adequate level of protection, even when these partners are located outside the European Economic Area (EEA), by signing the Standard Contractual Clauses approved by the European Commission to legitimate international data transfers. In particular, we will communicate your data with the following entities:

Easy Payment and Finance S.P. S.A.U., as a payment institution authorized by the Bank of Spain (No. 6849) to provide virtual bank account management services where we keep your money associated with your personal account. Easy Payment and Finance S.P. S.A.U. acts as the person responsible for the processing of your personal data for the bank account and money deposit services associated with the use of the Goin app, so they have access to all the data necessary for identity verification (Know your client), banking and operational data, whose processing is necessary to comply with obligations to prevent money laundering and terrorist financing.

1. Kernel Labs, Ltd. as a provider of payment gateway technology services. Kernel Labs, S.L., is an entity linked to the same Prakma business group that has developed a technology that allows Prakma to manage the movement of money between your bank account and the accounts of the Goin app.
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2. Prakma Finance, S.L., operates as a provider of Fintech, technology and brokerage services. Prakma Finance, S.L is an entity linked to the same business group as Prakma and plays a role in facilitating various activities within the application, such as the exchange of cryptocurrencies, SEPA instant transfer fees, inactivity and subscription.
   
   
3. Bitstamp Europe S.A. , authorized and regulated company in Luxembourg that offers the cryptocurrency exchange platform services used by the Goin app for cryptocurrency investment services. Prakma will execute your purchase and sale orders that you place from your Goin account through Bitstamp, which will be able to use your data to comply with its legal obligations in terms of financial regulation, prevention of money laundering and terrorist financing and, in particular, to execute the service related to your cryptocurrency purchase and sale order. You can find more information in the Bitstamp's Terms and Conditions and its Privacy Policy.
   
   
4. Paylead, SAS. , Partner of the Cashback program, it consists of receiving remuneration for purchases you make in stores that publish their offers within the Cashback program. In this case, Paylead will be able to securely process your bank details (previously pseudonymized by Prakma) as a data controller in relation to the management services of the Cashback program and for carrying out aggregated statistical studies from different business sectors in order to provide the user with personalized Cashback offers (based on consumer habits), identify transactions eligible for cashback and generate and pay the user's cashback amounts. For more information, you can consult the Paylead's Privacy Policy.
   
   
5. Triple Technologies LTD, Partner of the Cashback program, it consists of receiving remuneration for purchases you make in stores that publish their offers within the Cashback program. In this case, Triple may process your data (previously pseudonymized by Prakma) as a data controller in relation to the management services of the Cashback program and for carrying out aggregated statistical studies of different business sectors. For more information, you can consult Triple's Terms and Conditions and its Privacy Policy.
   
   
6. Shoppiday Digital Ltd., Partner of the Cashback program, it consists of receiving remuneration for purchases you make in stores that publish their offers within the Cashback program. In this case, Shoppiday may process your data (previously pseudonymized by Prakma) as a data controller in relation to the management services of the Cashback program and for carrying out aggregated statistical studies of different business sectors. For more information, you can consult Shoppiday's Terms and Conditions and its Privacy Policy.
   
   
7. OpenAI, an artificial intelligence research platform, provides an advanced language model technology, ChatGPT, to drive the personal assistant chatbot within the application in order to provide personalized assistance and answer queries requested by users. In this case, OpenAI may treat your data (previously pseudonymized by Prakma) as a data controller in connection with the analysis of issues related to your account, such as transaction history, to detect your preferences and financial patterns. Prakma reinforces its use of encryption techniques In-house and breaking any connection between the encrypted data and your identification data, with the aim of achieving irreversible anonymization of your personal data. For more information, you can check out the OpenAI's Terms and Conditions and its Privacy Policy.
   
   
8. Google, a multinational technology company, provides an advanced language model technology, Bard, to promote the personal assistant chatbot within the application in order to provide personalized assistance and answer the queries requested by users. In this case, Google may process your data (previously pseudonymized by Prakma) as a data controller in connection with the analysis of issues related to your account, such as transaction history, to detect your preferences and financial patterns. Prakma reinforces its use of applying in-house encryption techniques and breaking any connection between the encrypted data and your identification data, with the aim of achieving irreversible anonymization of your personal data. For more information, you can check out the Google's Terms and Conditions and its Privacy Policy.
   
   
9. Profielectra S.L., hereinafter Selectra, partner for advising on electricity, gas, internet and mobile rates. In this case, Selectra may process your data (previously pseudonymized by Prakma) as a data controller in relation to tariff advisory services and for carrying out aggregated statistical studies of different business sectors. For more information, you can consult the Selectra's Terms and Conditions and its Privacy Policy or you will be provided with all the information on the processing of your personal data when Selectra contacts you.
   
   
10. Make Opinion GmbH, hereinafter referred to as CPX Research, is a collaborator that provides paid surveys of renowned brands within the Goin application. In this case, Goin acts as an intermediate platform between the user and CPX Research, where the user deliberately signs up to answer surveys in exchange for rewards for the application. To use this service, the user must first accept the CPX's Terms and Conditions and its Privacy Policy. Throughout the survey response process, the user will provide information to answer questions that will be kept and stored by CPX Research. Even if the user deletes their Goin account, they should always contact directly CPX Research to manage the processing of your data. Goin does not and will never share any personal user data with CPX Research.
    
    
11. Adjoe GmbH, hereinafter referred to as Adjoe, a partner providing rewarded microtasks through different games and goals. In this case, Goin acts as an intermediate platform between the user and Adjoe where the user deliberately signs up to play and complete microtasks in exchange for in-app rewards. In order to use this service, the user must activate 'Application Tracking' in their mobile device and then accept Adjoe's Terms and Conditions and their Privacy Policy. If throughout the playing process Adjoe requests information, it will be the user who will insert it which will be kept and stored by Adjoe. Even if the user deletes their Goin account, they should always contact Adjoe directly to manage the processing of their data. Goin does not and will never share any user personal data with Adjoe.
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12. REWARDWAVE, S.L, hereinafter referred to Roiward, a travel agency partner authorized by lastminute.com that acts as an intermediary to provide real time travel offers and travel services. In this case, Goin acts as an intermediary platform between the user and Roiward where the user deliberately can quote and make purchases for flights, and/or hotels, and/or flight and hotel packages, and other travel services. The travel services offered by Roiward will be subject to the availability and Lastminute.com's Terms and Conditions and their Privacy Policy, in its capacity as a service provider, which are beyond the control of ROIWARD and whose compliance is the sole responsibility of lastminute.com. Any subsequent communication related to the travel services purchased will be managed by LastMinute directly with the user, who must contact LastMinute for any assistance, clarification, or post-sale needs. If throughout the purchasing process Roiward requests information, it will be the user who will insert it which will be kept and stored by Roiward. In this case, Roiward may process your data (previously pseudonymized by Prakma) as a data controller in relation to the travel services acquired.
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13. Analytical Partners with whom we collaborate to carry out statistical studies and market research in order to generate internal knowledge in Prakma by applying R&D processes. Our collaborations for these purposes are based on data aggregation and the application of encryption techniques In-house and breaking any connection between the encrypted data and your identification data, with the aim of achieving irreversible anonymization of your personal data.
    
    
14. Bank aggregation partners who will be responsible for safeguarding your banking credentials and acting as a technological channel in the interaction with your bank for the connection of your account and the recurring reading of bank transactions. See Morpheus Aiolos's Terms and Conditions and Tink's Terms and Conditions.
    
    
15. Other service providers, such as cloud hosting and storage services (Google cloud servers in Belgium), email services, user validation service providers (Alice Biometrics, Twilio, etc.), gift card providers (Tillo), providers of business management tools, such as ERP solutions, CRM, analytical tools, email marketing and contact, as well as Prakma auditing companies or potential investors in the context of due diligence prior to investment processes or business structuring.
    
    
16. Public authorities, fraud prevention agencies, credit reference agencies, Security Forces and Bodies, Judges and Courts, Bank of Spain or any other entity to which we are required to provide your data by legal requirement.

Prakma reserves the right to change suppliers and collaborators when it deems appropriate, and to use any other collaborations or third-party services available on the market at any time for the provision of the Goin app services.

Data retention periods

We will keep your data as long as your personal account in the Goin app is active. In any case, if you want to cancel your personal account, once you have withdrawn your funds deposited in your Goin account, both for savings and investment, we will proceed to block your data by means of encryption and, in accordance with data protection regulations, limiting any access to the minimum necessary for the case in which they are required by public authorities, judges and courts, as well as regulatory control and data protection authorities such as the Spanish Data Protection Agency for the prescriptive period of legal responsibilities for the data processing reported here.

In particular, these conservation periods will be:

In any case, these periods for storing data in a state of blockade will be subject to the 10-year conservation period established in art. 25 of Law 10/2010, of April 28, on the prevention of money laundering and the financing of terrorism.

Your data protection rights

In any case, Prakma guarantees the exercise of your rights of access, rectification, deletion, opposition, limitation of processing and data portability, as well as not to be subject to automated decisions, by providing you with an email address (gdpr@goin.app) to which you can send your requests for the exercise of rights, indicating in the subject”ARCOPOL” (Access, Rectification, Deletion (Forgetting), Limitation of Treatment, Portability and Opposition).

In accordance with applicable data protection regulations, this request must contain the following information about the applicant: name and surname, address for notification purposes, and a photocopy of the National Identity Document or any other valid document that proves your identity, as well as a description of the request in which your request is made. A request that does not include the data mentioned above will not be processed by Prakma.

Prakma may request additional information from you to verify your identity before proceeding to respond to your request.

You can withdraw your consent at any time for those treatments and purposes indicated above that have their legal basis in consent. This withdrawal of consent will stop any future processing for that purpose, but it will not make the previous treatments carried out while your consent was in force illegitimate.

You also have the right to complain to the Spanish Data Protection Agency if you consider that the processing of your personal data carried out by Prakma has not been adequate or does not comply with applicable regulations.