Last updated: July 2026
This Privacy Policy applies to the personal data processed through the Atrivity mobile application (hereinafter, the "Application"), downloaded from or accessed through any store or distribution platform where it is available.
APE SOFTWARE COMPONENTS, S.L., trading as Compettia, tax identification number (NIF) B60516291, registered office at Avda. Alcalde Barnils, 72, 1.º A, 08174 Sant Cugat del Vallès (Barcelona), Spain, registered with the Commercial Registry of Barcelona, sheet B-109267, volume 42960, folio 89.
Privacy contact: privacy@compettia.com.
Where the Application is used as part of a programme contracted by a company or organisation (the "Client"), the Client determines the purposes and the essential means of the processing and acts as controller. Compettia processes the data on behalf of the Client as processor.
The identity and contact details of the Client acting as controller will be provided in the contract, the access invitation, the login screen, an internal communication or the specific information relating to the programme.
Compettia acts as an independent controller in respect of the data of its commercial representatives, contractual contacts, invoicing, regulatory compliance and the security of its own systems, where applicable.
Data may be provided by the Client, by the user, generated during the use of Atrivity, or obtained from the Client's systems through an authorised integration, such as a corporate directory or a single sign-on system.
Within each environment, other users may see the alias, the optional profile picture, the assigned team, results and ranking position, where this is necessary for the dynamics that have been configured. First name, surname and email address are not shown to other users in the Application and are accessible only to the administrators authorised by the Client.
Users may not use that information outside Atrivity or for purposes other than those authorised by the Client.
Atrivity may use diagnostic and telemetry tools, such as Application Insights from Azure Monitor, in order to detect errors, crashes and technical events. These tools are configured in accordance with the data minimisation principle and, wherever possible, with anonymous or aggregated data.
Data will not be disclosed to third parties for their own purposes, except where required by law or on the valid instruction of the Client. Compettia may engage technology providers acting as sub-processors for hosting, infrastructure, monitoring, communications, support or security, subject to contracts compliant with Article 28 of Regulation (EU) 2016/679 ("GDPR").
The up-to-date list of sub-processors may be consulted on Compettia's website, contractual portal or security documentation.
The main hosting is located within the European Economic Area, with infrastructure in Dublin (Ireland). Should it become necessary to process data from a third country, an adequacy decision, standard contractual clauses, binding corporate rules or another valid mechanism under Chapter V of the GDPR will be applied, together with any supplementary measures required.
Where the Client authorises access for users located outside the European Economic Area, those users access their own environment through the Application without the data being hosted outside the European Union, and the information visible to them about other users is limited to that set out in section 6. It is for the Client, as controller, to determine the authorised users and, where necessary, the mechanism under Chapter V of the GDPR applicable to such access.
Individuals may exercise their rights of access, rectification, erasure, objection, restriction and portability, as well as their rights in relation to automated decision-making where applicable, and may withdraw consent where consent is the basis of the processing.
Requests relating to a specific programme should preferably be addressed to the Client acting as controller through the channels it has indicated. Where Compettia receives a request concerning data processed on behalf of the Client, it will forward the request to the Client or assist the Client in accordance with the data processing agreement. For matters relating to Compettia's own processing activities, please write to privacy@compettia.com.
A complaint may also be lodged with the Spanish Data Protection Agency, Agencia Española de Protección de Datos (www.aepd.es), or with the competent supervisory authority.
Compettia applies appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including access controls, encryption of communications, logical segregation, backups, monitoring, vulnerability management and incident response procedures.
Atrivity is not directed by default at minors without the involvement of a responsible organisation. Where the Client authorises use by minors, it must determine the legal basis, provide the necessary information and obtain, where applicable, the authorisation of those holding parental responsibility or guardianship.
The version in force will be published through the corresponding link, stating the date on which it was last updated. Where changes are substantial, users or the Client will be informed by appropriate means.