DATA CONTROLLER
PURPOSES AND LEGAL BASIS FOR PROCESSING
Personal data will be processed for the following purposes and on the following legal bases:
| Purpose of Processing | Data Processed | Legal Basis (GDPR) |
|---|---|---|
| Training and improvement of the identification platform: Optimization, training, and refinement of the automated reading algorithm when the system fails or encounters different formats of the European Parking Card for Persons with Disabilities (PRM Card). | Front and back photographs of the PRM Card and a photograph of the National Identity Document (ID) (only if the PRM Card does not include a photograph). | Explicit consent of the data subject (Art. 6.1.a), expressly granted by the user when enabling or authorizing the upload of the image for the review of the system failure. |
RETENTION PERIOD
Verification Documentation (PRM Card/ID): Images collected for optimization and algorithm training purposes will be retained for a maximum period of thirty (30) days from the date of receipt. After this period, the images will be permanently and securely deleted or destroyed from all systems and infrastructures, preventing any further processing.
DATA RECIPIENTS
The personal data processed for this specific purpose will not be sold, transferred, or generally shared with third parties. However, in order to fulfill the stated purpose, the data will be accessible exclusively by the following Data Processor:
Cyberneid SRL (Data Processor): A specialized technology provider acting under AsoPMR's strict confidential instructions. Access to PRM Card and ID images by Cyberneid SRL is carried out solely for the purpose of training, correcting, and improving the algorithms of the identification platform, contractually guaranteeing the implementation of appropriate technical and organizational security measures.
EXERCISE OF THE DATA SUBJECT'S RIGHTS
Once you, as a user of the App, have provided us with your personal data, the applicable legislation grants you the following rights as a data subject:
To exercise any of the rights described above, the data subject must provide sufficient identification or, where applicable, that of their legal representative before AsoPMR. To do so, the request should be sent to the following email address:asopmr@asopmr.org
Data subjects may also lodge a complaint with the Spanish Data Protection Agency.
CHANGES TO THE PRIVACY POLICY
The platform reserves the right to modify this Privacy Policy in order to adapt it to legislative or case law developments. In such cases, the Provider will announce the changes introduced on this page with reasonable notice before they come into effect.
Last updated: June 2026