Privacy policy

Privacy Policy of Balance Phone

Last Updated: 3th of August 2026

 

1. Who is responsible for processing your data?

The controller of your personal data is The Balance Phone, S.L. (hereinafter, "THE BALANCE PHONE"), with NIF B56716897 and registered office at Carrer de la Llacuna, 162, Sant Martí, 08018 Barcelona, Catalonia, (Spain).

We inform you that the website www.thebalancephone.com and the Balance OS App (hereinafter, together, "the Platform") are owned by THE BALANCE PHONE.

This Privacy Policy governs access to and use of the Platform that THE BALANCE PHONE makes available to users (hereinafter, the "Users") interested in the contents (hereinafter, the "Contents"), as well as to users of the services (hereinafter, the "Services") offered by THE BALANCE PHONE. For the purposes of this Policy, Users also include persons who subscribe to our communications or who complete forms, questionnaires or surveys available on the Platform or in our campaigns, even if they have not purchased any product or subscribed to any service.

In the specific case of our Balance Phone product, this includes a Samsung device managed through Samsung Knox with Balance OS. You can access Samsung's privacy policy here: Samsung Privacy Policy. You can access the Samsung Knox privacy policy here: Samsung Knox Privacy Policy.

Users may contact THE BALANCE PHONE at the following email address: rgpd@thebalancephone.com

2. Recommendations

Please read and carefully follow these recommendations:

Keep your device equipped with duly updated antivirus software against malware and spyware applications that may compromise your internet browsing and the information stored on your device.

Read and review this Privacy Policy and all legal texts made available by THE BALANCE PHONE on the Platform, including the Cookie Policy.

3. Information about the data THE BALANCE PHONE collects through the Platform

For the correct operation of the Platform, THE BALANCE PHONE may have access to the following data provided, where applicable, by the User:

User identification and account data: name, email address, date of birth, user type and, where applicable, data necessary for account authentication.

Technical and device data: IP address, device identifiers (IMEI, UUID or other technical or installation identifiers), model, technical configuration, network status and permission status. THE BALANCE PHONE may also access certain device information derived from the permissions required for Balance OS to function, including data relating to application usage, notifications, system accessibility and background execution, strictly to the extent necessary to ensure the security, support, maintenance and correct operation of the service.

Usage and behavioural data: information about the use of Balance OS and the device, including usage events, interaction with features, screen-time metrics, session duration, blocking events and content or application categories. This data may be processed in aggregated or pseudonymised form where possible.

Screen content data for safety analysis: where the content safety feature is enabled, Balance OS may capture images of the content displayed on the device screen and analyse them locally, on the device itself, using an integrated model, in order to detect potentially unsafe visual content (including nude or sexual imagery). Given its purpose, this analysis may involve the processing of special categories of personal data within the meaning of Article 9 GDPR. Screenshots are processed transiently on the device solely for the purpose of this analysis and are not stored, retained or transmitted off the device. The result of the analysis (that is, whether or not unsafe content was detected) may be recorded and, where applicable, synchronised with THE BALANCE PHONE's servers linked to the User's account.

Data provided through forms, questionnaires and surveys: responses and information the User provides voluntarily in subscription forms, questionnaires, quizzes or surveys available on the Platform or in our marketing campaigns. This data may include information about family context, device usage habits in the household, product preferences and the concerns or needs expressed by the User. THE BALANCE PHONE collects only the responses necessary for the purposes indicated at the point of collection and does not request special category data within the meaning of Article 9 GDPR through these forms.

Data relating to children provided by a parent or legal guardian: where a form or questionnaire is addressed to parents or legal guardians, responses may include information relating to the child in their care, such as their age band or their device usage habits. This information is provided by the parent or legal guardian in the exercise of parental responsibility or guardianship, and is processed exclusively for the purposes indicated at the point of collection. THE BALANCE PHONE does not request the child's name or other direct identifying data through these forms and applies the principle of minimisation, retaining, where sufficient for the purpose, only banded rather than exact values.

Consent records: where processing is based on the User's consent, THE BALANCE PHONE records the data necessary to demonstrate that consent was obtained in accordance with Article 7(1) GDPR, including the date and time, the IP address from which it was given, the form identifier and the version of the consent wording accepted.

Derived data, metrics and recommendations: results, scores, metrics, reports or recommendations generated from the use of the Balance OS App and the device, including the Balance Score and usage metrics that may be shown to the User or, where applicable, communicated to authorised supervisors. This also includes the results, scores and segments derived from responses provided in forms and questionnaires.

In certain cases, this data may be processed using tools from external technology providers for analytics, monitoring and service improvement purposes.

4. On what basis is THE BALANCE PHONE entitled to process your data?

The lawful basis for processing Users' personal data through the Platform may rest on different legal grounds, depending on the purpose of the processing:

• Performance of a contract: where processing is necessary to manage the purchase, subscription, activation, operation, support, warranty or maintenance of Balance OS and, where applicable, the Balance Phone device.
• User consent: where the User has given consent to specific processing requiring this legal basis, including, where applicable, certain optional Balance OS features, the receipt of commercial communications and the segmentation of those communications. This consent is requested specifically, separately and through a clear affirmative action, and is not made conditional on access to any content or the provision of any service. Where processing is based on consent and the User is under 14 years of age, or under the minimum age applicable under the data protection rules of the relevant country, that consent must be given by their parents or legal guardians. For Users who have reached that minimum age, consent may be given by the User themselves, without prejudice to any applicable parental supervision features.
• Consent of a parent or legal guardian in respect of children's data: where a parent or legal guardian provides, through forms or questionnaires, information relating to a child in their care, THE BALANCE PHONE processes that data on the basis of the consent given by them in the exercise of parental responsibility or guardianship, and solely for the purposes indicated at the point of collection.
• Explicit consent for special categories of data: where processing may involve special categories of personal data within the meaning of Article 9 GDPR — in particular the content safety analysis aimed at detecting nude or sexual imagery — THE BALANCE PHONE relies on the explicit consent of the User or, where the User is below the applicable minimum age, of their parents or legal guardians (Article 9(2)(a) GDPR). This consent is specific to that feature and is separate from and additional to the other legal bases set out in this Policy. It may be withdrawn at any time, and withdrawal will disable the feature.
• Compliance with legal obligations: where processing is necessary to meet tax, accounting, consumer, warranty or security obligations, or requests from competent authorities.
• Legitimate interest: where processing is necessary to ensure the security of the Platform, prevent misuse, improve the operation of the service, resolve technical incidents, respond to express requests made by the User — such as delivering the result of a questionnaire they have completed — and analyse aggregated metrics strictly necessary for the technical improvement of the service, provided this does not involve individualised monitoring of the User.

THE BALANCE PHONE takes the protection of Users' privacy and personal data very seriously. Data is therefore stored securely and processed with the utmost care, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("General Data Protection Regulation" or "GDPR").

Users may withdraw their consent at any time by sending a message to the following email address: rgpd@thebalancephone.com, or, in the case of commercial communications, via the unsubscribe link included in each of them, without this affecting the lawfulness of processing based on consent given prior to its withdrawal.

For processing that involves analysing User behaviour for product improvement, advanced analytics or metric development, THE BALANCE PHONE will request the User's prior consent through specific mechanisms.

5. What are the purposes of processing your personal data?

THE BALANCE PHONE will process its Users' personal data lawfully, fairly and transparently. The purposes of processing include:

1. Account management and communication with the User: we process identification and account data to create, verify and manage the User's account, enable access to Balance OS and, where applicable, manage the relationship with authorised supervisors. What is the legal basis? The User's consent and performance of the contract or the application of pre-contractual measures.
2. Provision of device blocking and control features: we process technical, device, permission and usage data so that Balance OS can detect applications, domains or content categories, limit or block access to certain content or features, and display blocking screens. What is the legal basis? Performance of the contract and THE BALANCE PHONE's legitimate interest in ensuring the operation and security of the service.
3. On-device content safety analysis: where the feature is enabled, we analyse screen content locally on the device to detect potentially unsafe visual content (including nude or sexual imagery) and, where detected, display a warning or blocking screen inviting the User to return to safe content; the result of the analysis may be recorded and synchronised with our servers linked to the User's account. What is the legal basis? The explicit consent of the User or, for Users below the applicable minimum age, of their parents or legal guardians (Article 9(2)(a) GDPR).
4. Usage analysis, metrics and service improvement: we process usage and behavioural data to analyse how Balance OS performs, measure its performance, improve the User experience and optimise Platform features. What is the legal basis? The User's consent.
5. Generation of metrics, reports, recommendations and the Balance Score: we process usage, behavioural and derived data to generate results, metrics, trends, reports, recommendations and scores that may be shown to the User or, where applicable, communicated to authorised supervisors. What is the legal basis? Performance of the contract for essential features, and the User's consent where it involves advanced behavioural analysis or profiling.
6. Technical support and incident management: we process technical and device identification data to keep Balance OS operational, resolve incidents and detect and correct errors. What is the legal basis? Performance of the contract and THE BALANCE PHONE's legitimate interest.
7. Management of purchases, subscriptions, payments, refunds and warranty: we process the data necessary to manage the purchase of the Balance Phone device, the Balance OS subscription, payments, invoicing, refunds, warranty, support and associated incidents. What is the legal basis? Performance of the contract and compliance with legal obligations.
8. Sending commercial communications: we process Users' and subscribers' email addresses to send informational and commercial communications from THE BALANCE PHONE. What is the legal basis? The User's consent, given specifically and separately from any other acceptance. Users may withdraw it at any time via the unsubscribe link included in each communication or by writing to rgpd@thebalancephone.com.
9. Producing and delivering questionnaire results: where a User completes a questionnaire or quiz available on the Platform and provides their email address in order to receive their result, we process their responses to calculate and deliver that result. What is the legal basis? The express request made by the User in submitting the form, and THE BALANCE PHONE's legitimate interest in responding to it (Article 6(1)(f) GDPR). Delivery of the result is not conditional on giving consent to receive commercial communications.
10. Segmentation and personalisation of commercial communications: we process the responses provided in forms, questionnaires and surveys, together with interaction data from our communications (opens and clicks) and, where applicable, information obtained through previously consented analytics and advertising cookies, in order to group Users and subscribers into segments and send them more relevant content and commercial communications based on their interests and their responses. What is the legal basis? The User's consent.

The results, scores, segments and recommendations derived from the Platform's questionnaires and forms are purely informative and indicative and do not constitute clinical, psychological, educational or professional advice of any kind. This processing does not produce legal effects concerning the User, nor does it similarly significantly affect them within the meaning of Article 22 GDPR.

Further information about the processing of data through cookies and similar technologies is available in our Cookie Policy.

6. Accuracy of the data provided by Users

Users warrant the accuracy of the personal data provided and undertake to notify THE BALANCE PHONE of any changes to it. Users shall in all cases be responsible for the accuracy of the data provided, and THE BALANCE PHONE reserves the right to exclude from the services any User who has provided false data, without prejudice to any other action available at law.

Users are advised to protect their data with the utmost diligence using appropriate security tools. THE BALANCE PHONE shall not be liable for any theft, unlawful alteration or loss of data. Any modification or update of data must be notified to THE BALANCE PHONE through the means of communication set out in this Privacy Policy.

7. Data retention

The protection of Users' privacy and personal data is very important to THE BALANCE PHONE. THE BALANCE PHONE therefore does everything possible to prevent Users' data from being used improperly. Only authorised personnel have access to User data.

• User identification and account data: retained while the User's account remains active and for up to 12 months after its deletion, unless otherwise requested. Thereafter, for the periods necessary to address any potential legal or contractual liability.
• Technical and device data: retained for as long as necessary to ensure the security, support, maintenance and correct operation of Balance OS, and for the duration of the warranty period. In particular, data linked to support, error diagnosis or technical monitoring may be retained for the period necessary to resolve incidents or improve service stability.
• Usage and behavioural data: retained for as long as necessary to provide Balance OS features, analyse its operation and improve the User experience. In particular, this data will preferably be retained in aggregated or anonymised form for a maximum period of 24 months before being anonymised or permanently deleted.
• Screen content data for safety analysis: the screenshots used for on-device analysis are not retained; they are processed transiently and discarded immediately after the analysis is performed. The result of the analysis (whether or not unsafe content was detected) is retained on the same terms as usage and behavioural data.
• Individual responses to forms, questionnaires and surveys: retained for a maximum period of 90 days from collection. After that period, individual responses will be deleted and only the resulting outcome, score or segment will be retained.
• Segments, interest tags and results derived from forms: retained until the User withdraws consent and, at most, for 24 months from their last interaction with our communications, at which point they will be deleted.
• Consent records: retained while the consent remains in force and, once withdrawn, for the applicable statutory limitation periods, for the sole purpose of demonstrating that consent was obtained in accordance with Article 7(1) GDPR.
• Derived data, metrics and recommendations: retained for as long as necessary to show Users their metrics, progress, reports, recommendations or Balance Score and, where applicable, for as long as an active relationship with authorised supervisors exists.

Thereafter, where necessary, THE BALANCE PHONE will keep the information blocked for the periods established by law.

THE BALANCE PHONE undertakes to comply with its obligation of secrecy and confidentiality regarding personal data in accordance with applicable law.

8. User rights

Users have the right to:

1. Access their personal data;
2. Request rectification of inaccurate data;
3. Request erasure of their data;
4. Request restriction of the processing of their data;
5. Object to the processing of their data;
6. Request the portability of their data;

Users also have the right not to be subject to decisions based solely on automated processing of data.

Objection to direct marketing. Users may object at any time to the processing of their data for direct marketing purposes, including profiling and segmentation connected with those purposes, under Article 21(2) GDPR. They may do so via the unsubscribe link included in each commercial communication or by writing to rgpd@thebalancephone.com, without needing to justify the request.

In particular, the display of a warning or blocking screen following the content safety analysis is an automated function forming part of the essential protective purpose of Balance OS, expressly enabled and consented to by the User or by their parents or legal guardians. The analysis produces only a determination of whether unsafe content is present and is not used to build profiles of the User; no screenshot image is stored or used for any other purpose. Users or their guardians may disable this feature at any time and may contact rgpd@thebalancephone.com in relation to any such decision.

Users may exercise all these rights at the following email address: rgpd@thebalancephone.com, stating the reason for their request.

Users may also send their request by post to the following address: Carrer de la Llacuna, 162, Sant Martí, 08018 Barcelona, Catalonia, (Spain).

Communications addressed to THE BALANCE PHONE must contain the following information:

• The User's full name.
• A request specifying what is being sought.

Without prejudice to any other administrative remedy or judicial action, Users have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement, where they consider that the processing of their personal data does not comply with the applicable rules, or where the exercise of their rights has not been satisfied. The supervisory authority with which the complaint is lodged will inform the complainant of the progress and outcome of the complaint.

Users also have the right to withdraw at any time the consent given for processing based on that legal basis, and to object to the processing of their data for usage analysis or metric development purposes.

9. Data security

The protection of Users' privacy and personal data is very important to THE BALANCE PHONE. THE BALANCE PHONE has therefore adopted all measures available to it to prevent your data from being used improperly, allowing access to it only by authorised personnel.

THE BALANCE PHONE maintains security appropriate to the protection of personal data in accordance with applicable law and has put in place all technical means available to it to prevent the loss, misuse, alteration, unauthorised access and theft of the data provided by Users through the Platform, while informing you that security measures on the internet are not impenetrable.

THE BALANCE PHONE undertakes to comply with its duty of secrecy and confidentiality regarding personal data in accordance with applicable law.

THE BALANCE PHONE shall not be liable for damages that may arise from a User's breach of this obligation.

10. Disclosures to third parties

THE BALANCE PHONE informs Users that it does not sell, share or disclose their personal data to third parties.

However, for the correct operation, maintenance, security, analytics, support, communications, payments and improvement of the Platform, certain personal data may be processed by external providers that provide services to THE BALANCE PHONE acting as processors.

THE BALANCE PHONE may use technology and service providers necessary for the operation of the Platform, including providers of analytics, error monitoring, remote configuration, device security, content classification, e-commerce, payments, document storage, and email communications and marketing. These providers may include, among others, Amplitude, Firebase, Sentry, Samsung Knox, Shopify, Klaviyo, Google Workspace, Mailchimp, Waitlist, Thor API, Google Play, OpenAI, Jina Reader, Google Translate and Slack, depending on the features in use at any given time.

In particular, the management of subscriber lists, the sending of commercial communications and their segmentation are carried out using Klaviyo, Inc., which acts as a processor and stores data in the United States of America. Internal storage of certain form and questionnaire responses may be carried out using Google Workspace services.

The on-device content safety analysis is performed locally on the device itself; the images analysed are not transmitted to any third party. Only the result of the analysis may be synchronised with THE BALANCE PHONE's own servers.

Some of the service providers mentioned may process personal data outside the European Economic Area, in particular in the United States. In such cases, THE BALANCE PHONE will ensure that those transfers are carried out with the appropriate safeguards required by Chapter V GDPR, including, depending on the provider, the adequacy decision relating to the EU–U.S. Data Privacy Framework, the Standard Contractual Clauses approved by the European Commission, or other legally valid mechanisms, supplemented where appropriate by additional security measures, in order to ensure an adequate level of protection for Users' personal data.

Users may request further information about these transfers, and a copy of the safeguards applied, by writing to rgpd@thebalancephone.com.

In particular, some of these providers may process data relating to device use, technical identifiers or information necessary for the provision of the service, always under THE BALANCE PHONE's instructions and with the contractual safeguards required by applicable law.

11. Changes

THE BALANCE PHONE reserves the right to revise its Privacy Policy whenever it considers appropriate. We therefore ask you to consult this Privacy Policy regularly to read the most recent version.

In any event, any change to this Privacy Policy will be communicated to Users.

12. Links to websites

THE BALANCE PHONE's Platform may include links to third-party websites or applications. THE BALANCE PHONE is not responsible for how those entities handle privacy and the processing of Users' personal data.

We therefore recommend that Users carefully review the privacy policies and terms of use of any external website accessed through links on the Platform, as their terms may differ from those established by THE BALANCE PHONE.

The inclusion of such links on the Platform does not necessarily imply approval, supervision or responsibility on the part of THE BALANCE PHONE for the content, services or privacy policies of the linked pages.

13. Questions

If you have any questions about our Privacy Policy, please contact us by email at: rgpd@thebalancephone.com

Likewise, if you consider that your rights have not been properly safeguarded, you have the right to lodge a complaint with the Spanish Data Protection Agency, whose contact details are: telephone 900 293 183; postal address C/Jorge Juan 6, 28001 Madrid; electronic office https://sedeaepd.gob.es/sede-electronica-web/ and website https://www.aepd.es.