PUFFPAL PRIVACY POLICY

1. Introduction

This Privacy Policy explains how PuffPal (“the App”) collects, uses, and protects your personal data when you use our mobile application, website, or contact us through any communication channel.

PuffPal is owned and operated by Nefos Solutions, a company registered in Ireland. Nefos Solutions acts as the data controller responsible for ensuring that your personal information is handled in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and other applicable data protection laws.

By using the PuffPal App or visiting our website, you agree to the terms of this Privacy Policy.

2. Data Controller Information

IDENTIFICATION AND CONTACT DATA OF THE RESPONSIBLE FOR THE TREATMENT

  • Company name: NEFOS SOLUTIONS
  • Company number: 575093 – N0073291G.
  • Address: 20 Harcourt St, Saint Kevin’s. Dublin 2, D02 PF99 Ireland.
  • Contact email: info@nefosolutions.com
  • Phone: +34 644 441 092

3. What Data We Collect and Why

When you use PuffPal, we may collect and process personal data that you provide directly or that is automatically collected during use. This may include:

  • Account information: such as your name, username, email address, and password.
  • Usage data: including interactions within the app, device information, and preferences.
  • Communication data: if you contact us through forms, email, or support channels.

We process your data for the following purposes:

  • To provide and manage PuffPal’s services and features.
  • To respond to inquiries or support requests.
  • To manage our commercial and administrative relationship with you.
  • To comply with legal obligations and ensure service security.

Providing certain personal data is necessary to access specific features of the App. If you do not provide the requested data, some services or functionalities may not be available.

4. Legal Basis for Processing

The processing of your personal data is based on one or more of the following legal grounds:

  • Your consent: when you voluntarily provide your information or agree to data collection through forms or settings within the App.
  • Performance of a contract: when data processing is necessary to provide PuffPal’s services to you.
  • Compliance with legal obligations: when we are required to retain or process certain data under applicable laws.
  • Legitimate interests: such as improving our services, ensuring security, and preventing fraud, provided these do not override your rights and freedoms.

5. Sharing of Personal Data

We do not sell or rent your personal data to third parties. We may share data only in the following circumstances:

  • With trusted service providers who help us operate the App (e.g., hosting, analytics, or communication tools), under strict data protection agreements.
  • When required by law, court order, or regulatory authority.
  • To protect our legal rights or prevent fraud or abuse of the App.

If any transfer of your data occurs outside the European Economic Area (EEA), it will be done in compliance with GDPR requirements using appropriate safeguards such as Standard Contractual Clauses.

6. Your Data Protection Rights

As a user of PuffPal, you have the following rights under the GDPR:

  • Right of access – to know what data we hold about you.
  • Right to rectification – to correct inaccurate or incomplete information.
  • Right to erasure (“right to be forgotten”) – to request the deletion of your personal data.
  • Right to restrict processing – to limit how your data is used in certain cases.
  • Right to data portability – to obtain a copy of your data in a portable format.
  • Right to object – to object to processing based on legitimate interests or direct marketing.
  • Right to withdraw consent – at any time, without affecting the lawfulness of prior processing.

7. How to Request Data Deletion or Exercise Your Rights

If you wish to delete your PuffPal account and personal data, or to exercise any of your other data rights, please email us at app@puffpal.app.

To verify your identity and protect your information, your request must include:

  • Your full name
  • The email address linked to your PuffPal account
  • Your username (if applicable)
  • A copy of a valid government-issued identification document (such as a passport, national ID card, or driver’s license) — used solely for identity verification

Once we verify your identity, we will process your request and delete your personal data within the legally required timeframe. Your ID document will be securely deleted immediately after verification.

After deletion, your PuffPal account and all associated personal data will be permanently removed, except where retention is required by law or necessary for legitimate legal purposes. You will receive confirmation once the process is complete.

If you believe your data is not being processed in accordance with applicable laws, you have the right to file a complaint with the Data Protection Commission of Ireland (www.dataprotection.ie) or with your local supervisory authority.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. When data is no longer required, it will be securely deleted or anonymized.

9. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements, industry practices, or service improvements.
Any updates will be published on our website and, where appropriate, communicated via the App.

By continuing to use PuffPal after any updates take effect, you acknowledge and accept the revised terms.