Privacy Policy

Last updated: 23/09/2025

This Privacy Policy describes how Closca (the "Site", "we", "us", or "our") collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from closca.com (the "Site") or otherwise communicate with us (collectively, the "Services"). For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

PRIVACY POLICY

1.- GENERALITIES
In compliance with the provisions of current legislation, the company CLOSCA DESIGN, S.L., with N.I.F. B-98532310, with registered office at 46021 – Valencia (Spain), Av del Puerto, 49, registered in the Mercantile Registry of Valencia, Volume 9,619, Book 6,901, Folio 68, Page V-153,591, as the sole party responsible for the file, informs Users that the personal data that may be required as a result of the use of the Web and/or the App will be subject to automated collection and processing and incorporated into the corresponding files, with the necessary security levels, owned by this company in order to adapt our commercial offers to the requests of Users, and to offer a more personalized and efficient service.

If you are a Sanitas employee, we inform you that the party responsible for processing your personal data, within the framework of the space of the application dedicated exclusively to Sanitas employees, is Sanitas Sociedad Anónima de Seguros (Sanitas). Your personal data will be processed with the main purpose of providing you with the services offered through this corporate space. We invite you to consult the additional privacy information of Sanitas at the following link. Remember that you can contact Sanitas if you have any questions or doubts about the processing of your personal data, as well as if you wish to exercise your data protection rights, through the email address lopdempleados@sanitas.es.

This Privacy and Data Protection Policy is configured in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data and in accordance with the provisions of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.

Please read this document carefully in order to understand its content.

2.- INFORMATION COLLECTED
The delivery of all the information provided by the Users is voluntary, their refusal has as its only consequence the non-perception of the benefits of the Web and/or the App.

The Company does not collect or request personal data from minors under 18 years of age, so if despite what is established in these Terms and Conditions, a minor accesses the Web and/or the App, they should not continue with the registration. If the Company becomes aware that information has been collected from a minor User, it will immediately delete the account of said User.

The Company collects and processes the specific information necessary to register on the Website and/or the App or to access other services provided by the Company, including:

  • Your first and last name and/or username.
  • Your registration email address.
  • A mobile phone number.
  • Transactions are recorded through the Website/App.
  • The indicated delivery addresses of the merchandise where the user wishes to receive the products. 
  • The indicated billing address of the transaction made.
  • Your responses to surveys or questionnaires that may be used for research purposes.
  • Details of contacts made, including messages and clicks to the phone made through the Website and/or the App or through any other means.

Information on the activity carried out using the resources available in the App. This information is as follows:

  • The number of map reloads made.
  • The number of hydration refills carried out and when they were carried out, specifically the date and time.
  • At which source(s) (exact location) and at what time (date and time) a refill was carried out.
  • The sources registered in the App.
  • The ratings of sources sent.
  • The bottles registered in the App.
  • The number of coin refills.
  • The rewards redeemed and/or won.
  • The name of the corporation to which they belong.
  • Their avatar.

Users who are subscribed to a challenge available in the App, the Company will collect the following additional information:

  • The date of joining the challenge.
  • The status in which they are within the challenge.
  • The user's own activity in the challenge (refill, rated sources, etc.).
  • Their position in the challenge ranking.

If, in addition, the Users belong to a Corporation, the Company will collect the following additional information:

  • The corporation to which they belong.
  • The user's own activity in the corporate challenges he/she has joined (refill, valued sources, position in the ranking, status within the challenge, etc.).

In this sense, the Corporate Administrator will only have access to view the following data, with the ownership of the data collected remaining in favor of the Company:

  • Username.
  • Email.
  • Specific information on the User's activity within the challenge:
  • Date of joining the corporate challenge.
  • The status of the user in the corporate challenge.
  • The number of refills carried out.
  • The number of hydration refills carried out.
  • Their position in the challenge ranking.
  • The sources registered in the App.
  • The ratings of sources submitted.

This Corporate Administrator access is carried out in order to (i) monitor the situation of the Users in the challenge and, thereby, carry out the corresponding delivery of prizes; and (ii) carry out global metrics of interest to the Corporation in relation solely and exclusively to the challenge.

Information regarding the devices used by the Users and the Networks to which they connect when using the Web or the App, including, among others, the IP address, connection information, browser type and version, browser add-ons (plugins), etc.

Information that the Company may request when reporting a problem on the Website and/or the App.

The Company only collects information when Users choose to provide it. Credit card, debit card or bank account details will not be recorded on any platform.

The information is collected through various technologies and methods such as Internet Protocol (IP) addresses and cookies. These methods do not collect or store personal information. We use the IP address to diagnose problems with our server and work on improving access to our website.

3.- USE OF THE DATA COLLECTED
The information provided may be used for the following purposes, as a non-exclusive list:

  • The maintenance, development, control and execution of the contractual relationship established between the Company and the Users from the acceptance of these Terms and Conditions of Use.
  • The correct and orderly management, treatment and maintenance of the proper functioning of the Web and/or the App.
  • The realization of commercial, advertising and promotional campaigns and discounts on Services that may be of interest to the Users, based on a study of the personal information provided that is in the files.
  • The sending of electronic communications related to the products.
  • The notification of any change in the Products.
  • The maintenance of the security of the Web and/or the App.
  • The compliance with the legal or regulatory regulations that may be applicable to the Products.
  • The delivery of prizes at the end of the challenges.
  • Obtaining global metrics related to the interventions of the Users in the challenges.

Users have the right to withdraw their consent at any time regarding the aforementioned processing, exercising their rights of access, rectification, deletion, limitation, opposition and portability.

To exercise the rights of access, rectification, deletion, limitation, opposition and portability, send a contact to the following email: support@closca.com

4.- DISCLOSURE OF COLLECTED DATA


The data collected about Users will be processed in accordance with current legislation and, for this purpose, they will be kept within the territory of the European Union. Notwithstanding the foregoing, some of the third-party service providers maintain their servers outside the territory of the European Union, and European regulations on data protection are not applicable to them.

If you have any questions, please contact us at the following email: support@closca.com.

5.- MODIFICATION


The Company reserves the right, at its sole discretion, to modify this privacy policy at any time, in order to adapt it to the legal or regulatory provisions in force or in the process of adoption, to any resolution issued by a Court, consumer agency or any other competent authority.

6.- LEGAL BASES FOR DATA PROCESSING


The processing of your data is carried out on the following legal bases:

  • The execution of the contractual relationship with the Users and the provision of the requested Services.
  • The consent freely given by the User, which may be withdrawn at any time.
  • Compliance with legal obligations applicable to the Company.
  • The legitimate interest of the Company in maintaining the security of the Website and/or the App, preventing fraud, and improving the quality of the Services.

7.- DATA RETENTION PERIOD


The personal data provided will be retained for the time strictly necessary to fulfill the purposes for which they were collected and, subsequently, for the periods required to comply with legal obligations or for the exercise or defense of possible claims. When such periods end, the data will be deleted or, where appropriate, anonymized.

8.- INTERNATIONAL DATA TRANSFERS


The Company informs Users that, in cases where the services of third-party providers involve international data transfers outside the European Economic Area, the necessary safeguards are adopted in accordance with applicable regulations, such as the use of Standard Contractual Clauses approved by the European Commission.

9.- RIGHTS OF USERS


Users may exercise their rights of access, rectification, deletion, limitation of processing, opposition and portability, as indicated in Section 3 of this Policy. Likewise, Users are informed that, if they consider that the processing of their personal data infringes the applicable regulations, they may file a claim before the Agencia Española de Protección de Datos (AEPD), at www.aepd.es.

10.- COOKIES AND SIMILAR TECHNOLOGIES


The Website uses cookies and similar technologies to facilitate browsing, personalize the user experience, and obtain statistical data on usage. Users may configure or reject cookies through the cookie settings panel available on the Website, as well as obtain more detailed information in the Cookies Policy.

Legitimacy 

The data is processed on the basis of the contractual relationship between the parties. 

Data recipients (assignments or transfers) 

The data may be transferred or communicated, where appropriate, to banks for collections or payments, as well as at the request of the Tax Agency, Courts or Tribunals. Rights You may exercise your rights to access, rectify, delete and of portability, limit or, where applicable, oppose. 

To exercise your rights, you must submit a written request to the above address or sending the following form. You must specify which of these rights you are requesting to be met and, in turn, a photocopy of your ID card or equivalent identification document must be attached. In the event of acting through a representative, legal or voluntary, a document accrediting the representation and an identification document of them must also be provided. If you also believe that your right to personal data protection has been violated, you may file a complaint with the Spanish Data Protection Agency (www.agpd.es)