Privacy policy

01Data controllerLink to this section: Data controller

Pending legal review: To be completed by legal counsel: confirm whether a data protection officer (DPO) must or should be appointed and, if so, their contact details

02Who this policy applies toLink to this section: Who this policy applies to

This policy explains how we handle personal data when you:

• visit the public website or write to us through the contact form;
• create an account and work in the dashboard as an admin or editor of a venue;
• listen to an audio guide in the player as a visitor;
• apply for a job at Muvo.

An important distinction. Muvo is the controller of account data, billing data, contact form data and data needed to run the platform. However, for personal data that a venue includes in its own content (for example, names in a text or the recorded voice of a teacher or student), the venue is the controller and Muvo acts as a processor under the data processing agreement. If you have questions about that content, please contact the venue first.

03What data we process and whyLink to this section: What data we process and why

We do not use your data for automated decision-making that affects you, for profiling or for advertising. We will not send you marketing emails without your consent.

04Visitors using the playerLink to this section: Visitors using the player

Listening to an audio guide does not require an account, an email address or any personal data. To make the player work well and to let each venue see how its audio guides are used, the following happens:

• Preferences in your browser. The player keeps your language, text size, playback speed and contrast settings in your browser’s local storage (localStorage). They never leave your phone.
• Anonymous visitor ID. The player creates a random ID and stores it in your browser. It is used to count distinct visitors per venue each month. Our server never stores that ID: only a salted hash, different for each venue and period (month or day), which cannot tell us who you are or follow you from one venue to another.
• Anonymous statistics. We record events such as opening a stop, starting to listen, how far you listen and in which language, with no personal data and without storing your IP address.
• Code-protected audio guides. If a venue asks for an access code, redeeming it stores a technical cookie in your browser holding an opaque pass for as long as the pass lasts. See the cookie policy.
• Location. If you use “Venues near me”, your browser will ask for permission to use your location. Your position is sent to our server only at that moment to find nearby venues, and we do not store it. Pending legal review: confirm it does not remain in the hosting provider’s technical logs

Visitors currently pay Muvo nothing and do not give us their email address. See the visitor purchase terms.

Pending legal review: To be reviewed by legal counsel: confirm that the salted hash per venue and period and the statistics events qualify as anonymous data and, if not, the applicable legal basis (legitimate interest) and the allocation of roles with the venue

05AI voice and translationLink to this section: AI voice and translation

When a venue generates a voice or translates a paragraph, Muvo sends the text of that paragraph to Google (Gemini API, for speech synthesis) or to Anthropic (Claude API, for translation). That text is the venue’s content, not visitor data.

We advise venues not to put unnecessary personal data in their texts. Where they do, the venue is the controller of that data and Muvo processes it as a processor.

Pending legal review: To be confirmed by legal counsel: Google’s and Anthropic’s data processing terms, and that data sent to their APIs is not used to train models or retained beyond each provider’s stated period

06Who we share data withLink to this section: Who we share data with

We do not sell or hand over personal data to third parties. It is shared only with the providers we need to run the service, who act as processors under a contract that requires them to protect it:

When the dashboard map loads, your browser fetches the map tiles directly from OpenStreetMap’s servers, which receive your IP address under their own privacy policy.

We may also disclose data to public authorities where the law requires it (for example, to the Spanish tax agency).

Pending legal review: To be confirmed by legal counsel: that a data processing agreement is signed or accepted with each provider

07International transfersLink to this section: International transfers

Our main database is in the European Union. Some providers are US companies or may process data outside the European Economic Area. In those cases, the transfer relies on the EU-US Data Privacy Framework adequacy decision (where the provider is certified) or on the standard contractual clauses approved by the European Commission, with supplementary measures where needed.

Pending legal review: To be completed by legal counsel: the specific safeguard for each provider (Vercel, Stripe, Inngest, Google, Anthropic) and how to obtain a copy

08How long we keep dataLink to this section: How long we keep data

After these periods, data is deleted or anonymised. Where the law requires us to keep it longer, we keep it locked, available only to courts and public authorities.

09Your rightsLink to this section: Your rights

You can exercise the following rights at any time:

• access: find out what data we hold about you;
• rectification: correct any inaccurate data;
• erasure: ask us to delete it;
• objection to and restriction of processing;
• portability: receive your data in a structured format;
• withdrawal of consent where processing is based on it, without affecting anything done before.

From your profile in the dashboard you can change your name, photo and language, sign out of your sessions and delete your account (unless you are the last admin of a venue). For anything else, email us at hola@muvo.es saying which right you want to exercise. We will reply within one month, and may ask you for information to verify your identity.

If the data is part of a venue’s content, we will pass your request on to the venue, as it is the controller.

If you feel we have not handled your request properly, you can lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) or with the supervisory authority in your country.

10SecurityLink to this section: Security

We apply technical and organisational measures to protect data, including:

• passwordless sign-in, by magic link or with Google, Microsoft or LinkedIn, and two-factor authentication for the superadmin;
• isolation of each venue’s data enforced by the database itself, not just by the code;
• encryption in transit (HTTPS/TLS) and encryption at rest provided by our providers;
• least-privilege permissions, checked on the server for every action;
• an activity log and daily backups.

No measure is foolproof. If a security breach affects your data, we will notify the supervisory authority and, where appropriate, you, as required by the GDPR.

11ChildrenLink to this section: Children

Dashboard accounts are for people acting on behalf of a venue. Children under 14 may not create an account. Visitors using the player, whatever their age, do not provide any personal data.

Schools and other venues that include children’s voices, images or names in their audio guides are responsible for obtaining consent from their parents or guardians, as set out in the data processing agreement.

Pending legal review: To be confirmed by legal counsel: whether underage students may hold an editor account in their school’s venue, and on what conditions

12Changes to this policyLink to this section: Changes to this policy

We may update this policy when the service or the law changes. The date of the latest update is shown at the top. For significant changes, we will let dashboard users know by email or with a notice in the dashboard before they take effect.