> For the complete documentation index, see [llms.txt](https://docs.komunitin.org/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.komunitin.org/project/privacy.md).

# Privacy policy

Last updated: 18 September 2026.

This policy covers personal data processed through [komunitin.org](https://komunitin.org), its application and associated APIs. It does not apply to CES or other instances of the Komunitin platform.

## Who is responsible for your data?

**Your community is the controller of its member data.** It decides membership, required information, profile visibility and the use of exchange records. Its privacy notice must identify the responsible entity or representatives, contact details, purposes and legal bases. Your community administrator can provide that notice.

The platform operator is the processor for community data and follows the community's instructions. The [Terms of use](/project/terms-of-use.md#data-protection-responsibilities) summarise the responsibilities of the community and the platform operator. Detailed processing terms will be set out in a separate data processing agreement between them.

The platform operator is the controller for community requests, its own support, hosting administration, service security, legal compliance and analytics.

Platform operator identification and contact details:

* **Name:** Associació Ecoxarxa del Bages.
* **Email:** <info@komunitin.org>.
* **Postal address:** plaça Catalunya, 9, entresol, porta 1, 08242 Manresa (Barcelona), Spain.
* **NIF:** G26619171.

Use these contact details for privacy enquiries. Registration details appear in the [Legal notice](/project/terms-of-use.md).

## Data stored and visibility

Community administrators and the platform operator can access all data held for your community membership. Access by other members through the application is described below.

| Data stored                                                                                                            | Visibility                                                                                                                                                                                                                        |
| ---------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Name, email, authentication details, account identifiers, membership and roles                                         | Login and authentication details are private. Profile and account-number visibility is described below.                                                                                                                           |
| Profile name, avatar, description, contact methods and location                                                        | Visible to other members of your community.                                                                                                                                                                                       |
| Offers and wants, including images, categories, location, value and availability                                       | Visible to other members of your community.                                                                                                                                                                                       |
| Balances and account limits                                                                                            | Balances are also visible to other community members when enabled in the community settings.                                                                                                                                      |
| Transfer participants, amounts, descriptions, dates and statuses                                                       | Individual transfers are visible only to the two participants, the relevant community administrators and platform operator, not to other members of either community. Public ledger data is described in the Stellar entry below. |
| Language, notification choices, push subscriptions and delivery, click and dismissal events                            | Private to your account.                                                                                                                                                                                                          |
| IP address, browser/device details, timestamps, requested resources, diagnostic logs, page views and usage information | Not visible to other members. Used for troubleshooting, security and usage analytics.                                                                                                                                             |
| Community applications, support requests, reports and correspondence                                                   | Not visible to other members.                                                                                                                                                                                                     |

Depending on community and account settings, your profile name, avatar and account number, together with your offers and wants, may also be shared with members of other communities. Your full profile is not shared with those members. Public community information is visible without signing in.

## Providers and subprocessors

| Provider or recipient                                        | Service and data received                                                                                                                                                                                                                                                                  |
| ------------------------------------------------------------ | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
| **OVHcloud**                                                 | Hosting, databases, S3-compatible object storage and backups in Gravelines, France. Stores the application data listed above.                                                                                                                                                              |
| **Amazon Web Services (AWS)**                                | Email delivery in `eu-west-1`, Ireland. Receives recipient addresses, message contents and delivery information.                                                                                                                                                                           |
| **Google Analytics**                                         | Audience measurement. Receives page addresses, usage information, browser/device details, pseudonymous identifiers and your IP address through the connection. See the [Cookie policy](/project/cookies.md).                                                                               |
| **OpenStreetMap Foundation and its tile delivery providers** | Map display. Receive your IP address, browser request details and the requested map area. See the [OpenStreetMap privacy policy](https://osmfoundation.org/wiki/Privacy_Policy).                                                                                                           |
| **Your browser or device's push provider**                   | Push notification delivery, when enabled. Receives the subscription endpoint, encrypted notification contents and delivery metadata.                                                                                                                                                       |
| **Mollie**                                                   | Payment processing, where enabled. Receives the amount, currency, description and return/notification URLs. Payment details are collected directly by Mollie under its [Privacy policy](https://www.mollie.com/legal/privacy).                                                             |
| **Stellar network**                                          | Public accounting ledger. Receive transfer amounts, the participants' public account addresses, currency identifiers and account operations, including balances and limits. Profile information and transfer descriptions are stored in the service databases and are not sent to Stellar. |

## Notifications and automated features

Account notifications report exchange and security events. Optional digests and newsletters are managed through notification settings or unsubscribe links.

Newsletter selection uses location, recency, images and previously featured content. Account reminders use balances, activity and profile or listing completeness. Transfer validation applies the limits and permissions set by the community. Ask the community administrator to review an incorrect result. These features provide suggestions and validation rather than decisions with legal or similarly significant effects under Article 22 GDPR.

## Retention

Personal data is kept while needed for the service or membership. After closure, retention is limited to outstanding exchanges, legal duties and claims. Support and security records are retained for the issue concerned; backups are removed through rotation. Public ledger records persist as described above. See the [Cookie policy](/project/cookies.md) for storage on your device.

## Your rights

Under the conditions set by the GDPR, you can:

* Access your data and obtain information about its use.
* Correct inaccurate or incomplete data.
* Request erasure or restriction of processing.
* Receive data you supplied in a portable format where processing is automated and based on consent or a contract.
* Object to processing based on legitimate interests for reasons relating to your situation, and object to direct marketing at any time.
* Withdraw consent, while earlier lawful processing remains valid.
* Exercise the safeguards for solely automated decisions where Article 22 applies.

Contact your community for data it controls, or <info@komunitin.org> for platform processing or help directing your request. State your community and request. Additional identification is requested only when needed to verify identity.

Requests are normally free and answered within one month. A legally permitted extension of up to two further months must be explained within the first month. A refusal must include reasons and information about remedies.

You can complain to the [Agencia Española de Protección de Datos (AEPD)](https://www.aepd.es), through its [electronic office](https://sedeagpd.gob.es), or to the competent authority where you live, work or where the alleged infringement occurred.

## Changes

The platform operator will communicate material changes and explain new processing purposes before using data for them. New uses requiring consent need a separate choice.
