SDK Activity Tracking Policy | ABANCA

Activity Tracking Policy

Use of SDKs in the ABANCA Mobile Banking App

In the “Mobile Banking” app of ABANCA Corporación Bancaria, S.A. (hereinafter, “ABANCA”), we use our own and third-party software development kits (hereinafter, “SDKs”) to ensure the proper functioning of the App and, if you give us your permission, to understand how you use the App and show you personalized ads, as explained below in this “Activity Tracking Policy.”

This Policy may be updated for various reasons, including, for example, new legal requirements, instructions issued by the competent supervisory authority, or changes in the operation of the SDKs used by the application. For this reason, we invite you to review this Policy regularly.

1. What are SDKs?

SDKs are data storage and retrieval devices from ABANCA and provided by third-party partners that are integrated into Mobile Banking to enable certain functionalities and to understand how you interact with the application.

Since these SDKs may affect your privacy, we want to provide you with all the necessary information about the different types we use in Mobile Banking, so you can make informed decisions about their use. To this end, in the section “What types of SDKs exist and which do we use in our application?” we provide you with a direct access button to the configuration panel, where you can find details about the types of SDKs we use and their corresponding purposes.

These tools, along with other tracking technologies such as pixels, are often grouped under the general term “cookies,” although, strictly speaking, cookies are small files that are downloaded to the user's device when accessing certain web pages. Therefore, this policy complements any other policies published at any time regarding the use of other data storage and retrieval devices (such as cookies, for example).

2. What types of SDKs exist and which do we use in our application?

There are different categories of SDKs depending on various factors:

Depending on who developed the SDKs:

Own SDKs: those developed or integrated by the app publisher.
Third-party SDKs: those developed and provided by third-party partners, even if their integration is carried out by the publisher.

Depending on their duration:

Session SDKs: store data only during the active use of the application. Once the session is closed or ended, this information is automatically deleted.
Persistent SDKs: store data that remains on the user's device even after closing the application, allowing retrieval in subsequent accesses.

Depending on their purpose:

Technical SDKs: these enable the basic operation of the application and access to its essential features and services. For example, they allow you to log in to your Client Area, fix technical errors, control possible fraud, or remember the process of contracting a product or service. Without these SDKs, the application cannot operate correctly, which is why they are necessary and cannot be disabled.
Analytics or measurement SDKs: these allow the tracking and analysis of your behavior to measure the activity of the application and introduce improvements. They can be used to count your visits and usage of the application, as well as to measure the impact of advertising during your navigation. In certain cases, and always when certain requirements are met and appropriate safeguards are adopted, the activation of these SDKs may be exempt from consent.
Preference or personalization SDKs: these allow information to be remembered so you can access the application and its essential features and services under personalized conditions, such as language. The activation of these SDKs does not require consent when you freely select those personalized features. From ABANCA, your consent will be requested.
Behavioral advertising SDKs: these collect and store information about your behavior through continuous observation of your browsing habits and use of the application to develop a specific profile and show you personalized advertising. The activation of these SDKs is subject to your consent.

According to the classifications described above, we may find multipurpose SDKs, that is, those that combine purposes from two or more different categories. When a single SDK integrates both purposes exempt from consent and purposes that require it, the former may be activated by default, while the latter will only be deployed once you have expressly given your consent.

In the application, we provide you with a configuration console through which you can easily manage your preferences regarding the use or non-use of SDKs, as well as obtain detailed information about the types and categories of each SDK.

The Activity Tracking console is shown by default on your first visit to Mobile Banking; however, you can also access it from the App menu, within the “Privacy” → Activity Tracking section.

3. Who uses the SDKs?

The information collected through the SDKs integrated into Mobile Banking may be used both by ABANCA, as the owner of the application, and by third parties providing services to it.

Some of these third parties providing services to ABANCA are located outside the European Union, which involves the carrying out of International Data Transfers. In this regard, ABANCA guarantees the application of technical, organizational, and legal security measures that are appropriate to the level of risk of the processing, regardless of the territory where it takes place.

Any data communication to third parties located in countries outside the European Economic Area (hereinafter, “EEA”) will be subject to an adequate level of protection that guarantees the security and legitimacy of the processing of your personal data, in accordance with the applicable regulations (for example, European Commission Adequacy Decision or the signing of Standard Contractual Clauses).

For more information about international data transfers and the guarantee mechanisms applied, you can contact ABANCA’s Data Protection Officer at the following email address: privacidad@abanca.com.

3.1. Adobe

This application uses technical, analytics, and behavioral advertising SDKs provided by Adobe Systems Software Ireland Limited (hereinafter, “Adobe”), whose main office is at 4-6 Riverwalk, Citywest Business Campus, Saggart D24, Dublin, Ireland.

You can find more information about Adobe SDKs at the following links:

You can also find additional information about Adobe’s privacy options by clicking hereYou will be redirected to another website.

3.2. Celebrus

This application integrates technical SDKs provided by Celebrus Technologies Plc (hereinafter, “Celebrus”), whose main office is at Elmbrook House, 18-19 Station Road, Sunbury-On-Thames, United Kingdom, TW16 6SB.

You can access more information about Celebrus SDKs by clicking hereYou will be redirected to another website.

3.3. Google

This application uses technical SDKs from Google Ireland Limited (hereinafter, “Google”), a company incorporated and operating under European Union law, with its main office at Gordon House, Barrow Street, Dublin 4, Ireland.

You can find more information about Google SDKs through the following links:

3.4. IronChip

This application integrates technical SDKs from Ironchip Telco, S.L. (hereinafter, “Ironchip”), with registered office at Calle Espronceda (Lonja), 4 - 48902 Barakaldo, Bizkaia, Spain.

You can access more information about the Ironchip SDK by clicking hereYou will be redirected to another website.

3.5. Medallia

This application uses technical SDKs from Medallia Inc. (hereinafter, “Medallia”), whose main office is in San Francisco, US-CA US 94105.

You can access more information about the Medallia SDK by clicking hereYou will be redirected to another website.

3.6. IBM

This application integrates technical SDKs from International Business Machines Corporation (“IBM”), whose main office is at 590 Madison Avenue, New York, United States.

You can find additional information about IBM Trusteer Mobile by clicking hereYou will be redirected to another website.

4. How long do we keep the data generated by the use of cookies?

The data generated by the use of SDKs will be kept only for as long as strictly necessary to fulfill the purpose for which they were collected and, in any case, for a maximum period of twenty-four (24) months.

After this period, the data will be deleted from our systems, so you will need to reconfigure the SDKs according to your preferences.

Although, as indicated, consent related to the use of SDKs is renewed every twenty-four (24) months, there are some exceptions to this period that require us to obtain your consent again before the end of the stated period (for example, if there are substantial changes in the operation of the SDKs, when new types of SDKs are implemented in their corresponding categories that require consent, or whenever technical changes occur whose operation depends on a re-publication of the notice and/or the Activity Tracking panel).

5. How can you configure or disable the SDKs integrated into Mobile Banking?

5.1. First access to the application

When you first access Mobile Banking, we show you information about the use of SDKs in the application, where you can take the following actions: * Privacy settings: you can obtain more information about the types of SDKs integrated into the application and modify their settings according to your preferences. * Accept all: you can directly activate all SDKs (subject to consent) regardless of their purposes, duration, or the entity that developed them, allowing you to use all the features of our application without limitations. * Reject optionals: you can directly reject the activation of all SDKs except those with technical purposes, which, as previously informed, are enabled by default and cannot be disabled.

In any of the three cases, we will retain your choice and you will not see the SDK information panel again when you access the application for a period of twenty-four (24) months, without prejudice to the possibility of accepting, rejecting, or configuring the SDKs through the application’s options menu at any time, as explained in the following section.

Likewise, we inform you that if you save the SDK configuration without having activated any of the available options, it will be equivalent to directly rejecting all SDKs, except for the technical ones, which, as indicated, are always active by default.

Regardless of the option selected in the SDK information panel when you first access Mobile Banking, you can accept, reject, or configure the SDKs at any time through the application’s options menu. To do so, follow these steps: 1. App menu 2. “Privacy” section 3. Activity Tracking

5.3. Deleting SDKs

Unlike other tracking technologies such as cookies, the SDKs integrated into our application cannot be deleted or uninstalled, as they are part of the application’s code itself.

However, you can disable their purposes subject to consent through the options menu, as described in the previous section.

6. Data Protection

Regardless of the selection you make in the Activity Tracking console, we inform you that, in any case, we will process your personal login data in Mobile Banking solely for the purpose of identifying you when storing and applying the consent options you have selected. You can contact the organization’s Data Protection Officer and exercise your Data Protection rights at the following email address: privacidad@abanca.com.

You can also find more information about how we process your personal data in the Mobile Applications Privacy Policy.