Privacy policy: Throughput+

Revised: May 2024

Index

  1. What categories of information we may process
  2. Use and disclosure of location data
  3. Data controller
  4. Data Protection Officer (DPO) and contact information
  5. Legal basis for processing
  6. Recipients
  7. Children's Privacy
  8. User rights
  9. Analytics

Privacy Policy Overview

This Policy explains how we may Process your information through this app (Throughput+). This Policy may be amended or updated from time to time, so please check it regularly for updates.

Throughput+ is a free, independent application for smartphones. The Company is neutral with respect to any information or of any third party interest. Services are interpreted by each User at their own risk with the understanding that it has been provided to optimize the cost of the services the user receives from others, which may not be accurate and requires knowledge and analysis on the User´s part to make a decision.

1) What Categories of Information We May Process

Cumberland Solutions S.L. (Weplan Analytics) is a crowdsourcing mobile data and analytics company focused on the telecommunications industry. We collaborate with mobile operators, TowerCos and Telecommunications Regulatory Agencies in order to improve their network coverage through Business Intelligence Reports and a Network Quality of Experience Dashboards.

To do so, we collect specific network and quality measurements using crowdsourcing techniques.

We do not collect any personal information that directly identifies individuals. We do not collect any identifiers from consumer devices such as the IMEI or the IMSI. Our products and services do not require user identification. In order to measure the quality of mobile network coverage, we may measure depending on the user’s permissions the follow items:

  • Type of network coverage: Null, limited, 2G, 3G or 4G.
  • Type of Wi-Fi coverage and Wi-Fi provider.
  • Signal strength, RSRQ, CQI and TA.
  • Location of the measurements.
  • Voice services network quality during the calls.

2) Use and disclosure of location data

We may use and store information about your location if you give us permission to do so in Throughput+. We use this data to provide features of our Service, and to improve and customize our Service.

You can enable or disable location services when you use our Service at any time, through your device settings.

We may share anonymous location data to Telcos and TowersCo to plot network performance on a map to convey coverage.

3) Data controller

Weplan Analytics (CUMBERLAND SOLUTIONS S.L with CIF B86458833) is the Data Controller for the processing of your personal data (Data Controller). You can contact your registered office located at Foronda Street 6, second floor Center or by calling 91 728 34 41 or through the email address [email protected].

4) Data Protection Officer (DPO) and contact information

CUMBERLAND SOLUTIONS S.L. has designated a data protection officer (DPO) to which you can send an e-mail to [email protected].

The data protection officer is the person responsible for ensuring the protection of their fundamental right to the protection of personal data.

In this way, CUMBERLAND SOLUTIONS S.L. continues to guarantee the security and confidentiality of your personal data and gives you more control over your personal data, to be able to decide who accesses your data, in what conditions and for what Purpose.

5) Consent (legal basis for the processing)

The use of this app is based in your free and express consent.

If you download it and wish to obtain the service, we will need some minimum personal data to provide the service. The legal basis is the user license agreement.

We will only keep the necessary information until and unless you advise otherwise and thereafter for such time as may be necessary to guarantee compliance with statutory requirements.

Therefore, acceptance of these TERMS will express the acceptance of the data processing by the Company along commercial or obtained through the use of our services relationship with the purposes described above. Also, the acceptance of these conditions also implies the knowledge and acceptance of non personal data communications to telecommunications operators (see recipients).

If you are providing third party data, you will be responsible, against any claims in this regard; ensuring that Throughput+ propriate consent and other legal requirements that may be necessary in compliance with applicable legislation on data protection and labor law, therefore able to transfer the data to Throughput+, carry out the provision of the Services Agreement and the corresponding object that Throughput+ can use for these purposes. Also, the acceptance of these conditions also implies the knowledge and acceptance to the above-mentioned data communications to telecommunications operators.

6) Recipients

Due to the services provided, we will need to communicate (non-personal) data to telecommunications operators in order to provide Throughput+ service.

Weplan may send aggregated information or completely anonymous statistics regarding consumer consumption to telecommunications operators and other companies; in this communication there will be no user identification data, neither your cell phone number nor the phone numbers of people with whom you have calls or SMS. The purpose of processing this information is to provide operators and other companies with a better knowledge of the market. Therefore, under no circumstances will your user or personal data be communicated to third parties.

7) Children's Privacy

Our Service does not address anyone under the age of 16 ('Children').

We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

8) User Rights

We expressly manifest that the User can revoke the consent and exercise their rights of access, rectification, cancellation, opposition, limitation and portability in legal terms, at any time, by email sent to [email protected] or by ordinary mail sent to Calle Foronda 6, second floor center, postal code 28034 Madrid (SPAIN). That communication must include the name and surname, the concrete request, address for correspondence, date, signature and in some circumstances would be requested to be able to check the applicant identity.

If you consider that your personal information is not being processed in accordance with the data protection laws in force, you are entitled to file a complaint with the regulatory authority. However, because of our privacy commitment, we will make every attempt and use our very best efforts to settle any issue in connection with your information. Please therefore contact us [email protected].

9) Analytics

Firebase Analytics Firebase is analytics service provided by Google Inc.: https://www.google.com/intl/en/policies/privacy/

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://support.google.com/analytics/answer/6004245.

We also encourage you to review the Google's policy for safeguarding your data.: https://www.google.com/intl/en/policies/privacy/