Privacy Policy for Personal Data APP

In compliance with current legislation on data protection, i.e. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), Organic Law on Data Protection and Guarantee of Digital Rights (LOPDGDD, Law 3/2018 of December 5), we inform you of our Personal Data Privacy Policy, regarding the processing of personal data herein.

Personal data controller

The data controller is the legal entity that determines the purposes and means of the processing of personal data. In other words, the controller decides how and for what purposes personal data is processed.

For the purposes of this Data Protection Policy, the person responsible for the processing of personal data is:

  • Identity of the company: NETUN SOLUTIONS S.L. (NIF number B27830512)
  • Registered office: Calle Colon, Nr. 12, 3º. Zip Code 36201. Vigo (Pontevedra)
  • Contact phone: 919 912 366
  • Data Protection Officer: Clarke Modet. Data Protection contact
  • Contact email:

What personal data do we process and how do we protect these?

A personal data is any information about an identified or identifiable natural person.

For the purposes established in this Privacy Policy, the person in charge collects and processes the personal data that is explained in each type of processing, and that will depend on the different services requested or the contractual relationship that he or she maintains with our company.

Our organization is committed to treating your data with total confidentiality and applying the appropriate physical, technical and organizational security measures for the protection of your personal data.

You guarantee and are responsible, in any case, for the veracity, accuracy, validity and authenticity of the personal data provided and are committed to keeping them duly updated.

Data processing of the IncidenceApp mobile application

 What kind of personal data do we process?

  • Identification data: name and surname, mobile phone, email address, ID, license plate and vehicle insurance.
  • Geolocation data in the event of an accident and roadside assistance.

 Why do we process your personal data?

The personal data you provide when registering and the geolocation data processed in the IncidenceApp mobile application will be used to inform your insurance company, in the event that there is a relationship between NETUN SOLUTIONS and the company, and/or the emergency services of a failure or accident suffered by your vehicle, as well as its geolocation for the dispatch of roadside assistance.

Your personal data may also be processed to send you communications related to the activity of NETUN SOLUTIONS, focused at all times on keeping your app up to date or because NETUN SOLUTIONS considered it interesting for you to learn about other types of services provided by NETUN SOLUTIONS and, in any case, always related to the services of NETUN SOLUTIONS and the IncidenceApp application.

When opening the app, depending on what you indicate:


Your personal data, including geolocation data, will be communicated to your insurance company provided that it is affiliated with the Incidence app service, in order to provide you with the appropriate roadside assistance. Your insurance company may require additional information in order to provide you with roadside assistance


Your personal data, including geolocation data, will be communicated to a specialized company, which will act as data processor of our services, in order to put you in contact with the public emergency services of the place in which you are located (112).

For more information about the recipients of the data, click here.

Our organization is committed to treating your data with complete confidentiality and implementing appropriate physical, technical and organizational security measures for the protection of your personal data. Specifically, your data is encrypted both at storage and at communication, in order to preserve confidentiality.

Personal data will be kept for as long as the interested party does not request cancellation. If you decide to cancel your personal data, they will be deleted from our database and you will not be able to use our application.

The necessary communications made by NETUN SOLUTIONS for the correct provision of the services that imply a treatment of your data by a third party, will be supported by the corresponding treatment manager contract that NETUN SOLUTIONS will sign with said companies.

 What is the legal basis for processing your data?

  • The legal basis for processing your data is the express consent that you gave when installing the app on your mobile device (Android or iOS), as well as the authorization for geolocation that you have accepted in the corresponding notice that has appeared on your mobile.
  • In addition, the execution of your car insurance contract with your insurance company also legitimises the communication of your personal data, including geolocation data to it in the event of a breakdown, to provide you with roadside assistance.

 Who will receive your data?

  • Your personal data will not be shared with third parties unless you notify us through the mobile application of the occurrence of a failure or road accident.
  • Likewise, the previous data will be communicated through a specialized company in order to request corresponding emergency services through the 112 emergency number throughout the national territory.
  • Your personal data will also be communicated to data processors who are technology service providers for the app maintenance and development of the app.
  • Your personal data will not be transferred to other entities, unless required by law. Please note that international data transfers will not be carried out either.
  • Your data will be communicated anonymously to the Dirección General de Tráfico (DGT) through the beacon only, not through IncidenceApp. Only the data related to the incident will be communicated, in compliance with the current road safety regulations.

How long will we retain your data once you unsubscribe from the IncidenceApp mobile application?

NETUN SOLUTIONS, S.L. will keep your data for a period of 2 years if you have requested any roadside assistance service, starting from the date of the service, in accordance with the applicable period for the limitation of legal action derived from the insurance contract regulations. All this without prejudice that said period may be extended, when you expressly authorize it or if there are particular processes derived from the contractual relationship that remain in force after said period.

Rights of data owners

In accordance with the applicable regulations on data protection, you have a number of rights in relation to the processing of your personal data. The exercise of these rights will be free for you, except in cases where manifestly unfounded or where excessive requests are made, especially repetitive ones.

We will attend to the exercise of your rights as soon as possible, and in any case, within a period of one month.

These rights are as follows:

Right to information

You have the right to be informed in a concise, transparent, intelligible and easily accessible manner about the use and treatment of your personal data in clear and simple language.

Right of access

You have the right to ask us at any time to confirm whether we are processing your personal data, to provide you with access to it and to the information about its processing and to obtain a copy of said data. Copies of your personal information provided to you will be free of charge, although requests for additional copies may be subject to a reasonable charge based on administrative costs. For our part, we may ask you to confirm your identity or provide further information that is necessary to the processing of your request.

Right of rectification

You have the right to request the rectification of inaccurate, outdated or incomplete personal data concerning you. You may also request that incomplete personal data be completed, including by means of an additional declaration.

Right of deletion

You have the right to request the deletion of your personal data when, among other reasons, the data is no longer necessary for the purposes for which it was collected. However, this right is not absolute: our organization may continue to keep it duly blocked in the cases provided for by the applicable legislation.

Right to restrict processing

You have the right to request that we limit the processing of your personal data, which means that we can continue to store it, but not continue to process it if any of the following conditions are met:

  • That you challenge the accuracy of the data during a period that allows the data controller to verify the accuracy
  • The processing is illegal and you oppose the deletion of the data and request limitation of its use instead
  • Our entity no longer needs the data for processing purposes, but you need it for formulation, exercise or defense of claims
  • You have objected to the processing whilst it will be determined whether the lawful reasons of our entity prevail over yours

Right to data transfer

You have the right to have your data transmitted to another data controller in a structured, commonly used and machine-readable format. This right applies when the processing of your personal data is based on consent or the execution of a contract and such processing is carried out by automated means.

Right to object

This right allows you to object to the processing of your personal data, including profiling. We will not be able to comply with your right only when we process your data if we can demonstrate legitimate grounds for the processing or for the formulation, exercise or defense of claims.

Right not to be subject to automated decisions, including profiling

This right allows you not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects or similarly affects you; unless such a decision is necessary for the conclusion or performance of a contract, is authorized by a law or is based on consent.

Right to withdraw your consent

Where we have obtained your consent to the processing of your personal data in connection with certain activities (for example, for the purpose of sending you marketing communications), you may withdraw your consent at any time. In this way, we will stop carrying out that specific activity for which you had previously consented, unless there is another reason that justifies the continuity of the processing of your data for these purposes, in which case, we will notify you hereof.

Right to file a claim with a supervisory authority

You have the right to file a claim with the Spanish Data Protection Agency, C/Jorge Juan, 6, 28001 Madrid, 901 100 099 – 912 663 517, or at the email address in this link.

You can exercise the rights indicated above, by sending us a communication to the physical or to the electronic address indicated above, accompanying a document proving your identity and providing the necessary details to process your request.

Interested parties can obtain additional information about their rights on the website of the Spanish Agency for Data Protection.

Likewise, you can contact our Data Protection Officer, if you deem it appropriate, at

General terms of use and service level agreement (SLA) for IncidenceApp mobile device applications (app)

Data controller for the provision of the IncidenceApp service

This agreement establishes the terms and conditions to which NETUN SOLUTIONS S.L., with NIF number B27830512, and registered office in Vigo, calle Colón, N.º 12, 3º. postal code 36201, is subject in the scope of the provision of the service as owner of the mobile application Incidence (hereinafter app or application)

Incidence is a registered trademark of NETUN SOLUTIONS S.L. You can contact us at the email address: or at our contact telephone number: 919 912 366.

Conditions of use of the IncidenceApp

All users of the IncidenceApp must read, understand and do expressly agree to the following terms of use.

If you do not agree to the terms of use of the app set forth in this document, which is legal by nature, you must not continue to use the mobile application, nor browse or access the contents of the mobile application.

In any case, the fact of accessing this application developed for use on mobile devices implies acceptance of the conditions of use set forth herein.

Description of the service provided by the APP

The IncidenceApp allows the user, once registered, to send their identification data: name and surname, cell phone, email address; as well as the data of their vehicle, such as license plate number and geolocation data, to inform their insurance company and/or the emergency service of a breakdown or accident suffered in their vehicle.

By opening the IncidenceApp, you will be able to report the following:


Your personal data, including geolocation data, will be communicated to your insurance company, provided it is a member of the Incidence service, in order to provide you with the appropriate roadside assistance. Your insurance company may require additional information in order to provide you with roadside assistance.


Your personal data, including geolocation data, will be communicated to the emergency services, in order to provide you with the appropriate roadside assistance. Your personal data, including geolocation data, will be communicated to your insurance company, provided that it is a member of the Incidence service, for the management of the assistance. It is possible that your insurance company may ask for more information in order to provide you with the claim processing.

For more information about the recipients of the data, click here.

Cost of the service

The use of this app is free of charge, without any additional charge for its use, notwithstanding the fact that the cost for accessing Internet in order to use the app and thus connect with the servers must be paid for by the user of the app, who will be charged by his Internet service provider (ISP) for the data consumed as a result of the use of the telecommunications network when sending his data.

In any case, NETUN SOLUTIONS; S.L. reserves the right to establish fees for the use of the application whose acceptance will be voluntary and which will be notified prior to its implementation. Also these rates will not affect customers of those companies with which membership agreements are currently in force.

For more information about the recipients of the data, click here.


The Incidence app will be available 365 days a year, 24 hours a day.

Without prejudice to the above, NETUN SOLUTIONS S.L., does not guarantee any degree of availability, and therefore it is possible that the service may not be provided temporarily, without any liability for NETUN SOLUTIONS S.L.

We are also not responsible for the configuration that you can make in your mobile terminal for Internet access, nor for the incompatibilities that may arise with other apps.


NETUN SOLUTIONS S.L. guarantees its users the restoration of services as soon as possible in the event that they stop working, without in any case guaranteeing a specific deadline for solving the incidence.

In any case, NETUN SOLUTIONS S.L., will proceed, to the extent of its possibilities, to communicate to the users the possible peaks related to the use of resources that may involve a malfunctioning of the service.

The service provided by the IncidenceApp is free of charge and, consequently, there is no commitment on the part of NETUN SOLUTIONS S.L. in the continued maintenance of the service, reserving the right to suspend or terminate it, partially or totally, as well as to modify its contents at any time, without giving rise to any type of compensation for any damages that may be incurred, since it is not a professional service and is not suitable for industrial use.

Service level and incident management

The provision of the service may be subject to incidents that may compromise the maintenance of adequate service levels.

In this regard, and in order to have these incidents from impacting as little as possible on the provision of the service, incident prioritization criteria are established to provide the correct response and resolution times. These prioritization criteria are divided into 2 types: Normal and Critical.

  • Normal: Incidents that do not imply the total stop of the service or that do not compromise the security of the service in any of its parameters. These we will try to resolve within 72 hours.
  • Critical: Incidents that involve the total shutdown of the service or that may compromise the security of the service. These we will try to resolve within 48 hours.

In any case, a maximum resolution time cannot be guaranteed.

You may contact the service manager at any time at the address indicated at the beginning of this SLA.

In no case does the IncidenceApp guarantee a minimum service level, nor can you claim any compensation for the lack of the use of the app, since its continuous service is not guaranteed.

Service monitoring

All the tasks described in this agreement will involve a monitoring that allows real-time monitoring by the company of the degree of compliance with the service levels. In no case will NETUN SOLUTIONS S.L. be obliged to provide this information to the user.

Legality and compliance

Users of the Incidence app agree not to accept or encourage practices that violate Spanish or European Union legislation.

On the other hand, they agree to comply with all regulations on intellectual property, data protection, cybersecurity and other on the protection of the fundamental rights of individuals. The user recognizes that NETUN SOLUTIONS S.L. is the sole owner of the intellectual and industrial property rights over the graphics, texts, plans, buttons and, in general, all the information contained in the pages or website which he/she accesses and that the reproduction, loading, presentation, execution, transmission, storage, translation, adaptation, arrangement or distribution, whether total or partial, carried out without the consent and express authorization of NETUN SOLUTIONS S.L., constitutes an infringement of the intellectual and industrial property rights.

The user agrees to use the service in good faith, in a diligent and appropriate way, without engaging in activities that may be considered illicit or illegal, that infringe the rights of NETUN SOLUTIONS S.L., or of third parties, complying at all times with the rules of good behavior on the network and with the acceptable use policies of the networks visited, not to make fraudulent use of the information or of the contents therein. Likewise, the User expressly agrees not to carry out any conduct that tends to deteriorate or overload the service and, especially to avoid:

  • To destroy, alter, disable or, in any other way, damage the data, programs or electronic documents of the service provider or third parties. To obstruct the access of other Users to the Internet, as well as to carry out actions that damage, interrupt or generate errors in the access system.
  • The massive sending of commercial communications by email or other equivalent electronic means of communication to recipients who have not expressly requested this.
  • To attempt to access, delete, copy or modify the email messages of other users.
  • To introduce programs, malware or any other device that causes or is likely to cause any type of alteration or damage in the computer systems of the service provider or third parties, without prejudice to any criminal liability that may arise from said behavior.

Related to security

 The user agrees not to share his/her account with any other person. The identification and authentication of each account are confidential and non-transferable, with all responsibility resting with the account holder.

The user agrees not to violate existing security measures, as well as not to access resources, systems or information to which they are not authorized to access. Specifically, they shall refrain from attacking (malware, ransomware, etc.) or attempting to modify the IncidenceApp.

The user shall inform the IncidenceApp support services of any event involving a breach of security of the systems or any other potential risk, in accordance with the provisions of the General Data Protection Regulation regarding the notification of security breaches (arts. 33 and 34).

The user must provide NETUN SOLUTIONS S.L. with the identification of the terminal or terminals from which he/she accesses the service, as well as her/his mobile phone number, which may be used by NETUN SOLUTIONS S.L. to ensure the identity of the user.

Relative to its use

The user agrees to use the Incidence app only for the purpose for which it has been designed, that is, to notify his insurance company, as well as, where appropriate, the emergency services or assistance in case of accident or failure, respectively. Under no circumstances may the Incidence app be used for purposes other than those authorized, or for activities that are contrary to law or public order, in particular those that may constitute an administrative or criminal offense.

The Incidence app shall not be used in any way that may offend other users, or cause damage to the property or rights of other persons, be they natural or legal, or of the company.


The user expressly agrees to hold Incidence, a product of the company NETUN SOLUTIONS S.L., and its personnel harmless in the event they may suffer any loss as a result of using the app, specifically any loss that may affect the confidentiality, integrity or availability of the data.

The user agrees to allow the operators of the app access to the information generated in the app and the monitoring of the activities they perform in order to maintain the performance of the resources used, and detect improvements that can be implemented.

The user accepts that the app will not always be available for my use in the expected way and waives any liability on the company that owns the app in case of being affected by the availability or any other aspect that reduces the functionality of the app; he/she is fully aware that it is a free app and therefore no claims can be issued.

The user expressly accepts that Incidence is not responsible for damages of any nature that may be due to the presence of malware or the presence of other harmful elements in the contents of the app that may cause alterations in the user’s terminal or third parties or in their files and electronic documents.

It shall be the user’s responsibility to keep the app updated at all times, always installing the latest software version available as well as the latest version of the operating system of the terminal, as well as other patches or security updates that are recommended to be installed.

Responsibility and penalties

When incorrect or unacceptable use is shown with respect to what is specified in this document, Incidence will proceed to the interruption of the service provided, depending on the severity and recurrence of the incident, or the temporary suspension of the service (or the indefinite withdrawal of the same).

Any responsibility that may derive from the incorrect use of the resources by the user will be assumed by the user himself.

The User will be liable for all damages that may be caused to NETUN SOLUTIONS S.L. for the non-compliance and non-observance of the present conditions of use of the service in case of fraud, fault or negligence.

NETUN SOLUTIONS S.L. will provide the necessary means to allow easy consultation of these rules.

Applicable law and competent jurisdiction

For any dispute or question that may arise from the application, execution and interpretation of these terms of service, the parties will apply the principles of good faith and will be governed by Spanish law.

In case of judicial resolution of conflicts, the Court in which the user has his domicile will be competent, as long as the user is a consumer and this in Spanish territory.