SPC Kite Privacy Policy

Last updated: 05/12/2026

This Privacy Policy describes how SMART PRODUCTS CONNECTION (SPC) collects, uses, and shares information in relation to the SPC Kite application.

1. Data controller

Smart Products Connection, S.A., hereinafter SPC, is the entity responsible for processing the personal data handled through the SPC Kite application.

Company name: Smart Products Connection, S.A.
Registered office: Euskadi Technology Park, Leonardo da Vinci 14,
01510 Vitoria-Gasteiz (Álava), Spain
Contact email: privacy@onspc.com

SPC is committed to protecting the privacy and personal data of its users and applies the necessary measures to ensure lawful, fair, and transparent processing.

2. Scope of application

This Privacy Policy describes how SPC processes the personal data of users who use SPC Kite, a family-use application intended for parental control and supervision of devices used by minors.

This policy applies exclusively to SPC Kite. Other SPC products, applications, or services will be governed by their own privacy policies when expressly indicated.

3. Definitions

Adult user / Legal guardian: adult who creates the main account and manages the supervision.
Minor / Supervised user: minor whose device is supervised through SPC Kite.
Supervised device: mobile device linked to the parental account.
Personal data: any information related to an identified or identifiable natural person.
Supervision / monitoring: continuous processing of certain data from the supervised device in order to provide parental control functions.

4. Use of supervision and monitoring functions (EXPRESS DISCLOSURE)

SPC Kite is specifically designed to allow parents or legal guardians to remotely supervise and manage certain aspects of a minor's mobile device usage, including device usage information, device status, and, if the legal guardian activates it, its approximate location.

These features involve the continuous collection and processing of certain data from the supervised device and are only activated after the legal guardian has been clearly informed and has given their explicit consent through visible notices within the app during the initial setup process.

SPC Kite does not operate covertly, does not hide its monitoring capabilities, and does not perform any type of monitoring unless the legal guardian has consciously configured and activated these functions.

5. Legal basis for processing

SPC processes personal data in accordance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018, based on:

The explicit consent of the legal guardian.
The execution of the contract, necessary to provide the parental control service.
The legitimate interest of the legal guardian in protecting the minor's safety and well-being.

In Spain, the processing of personal data of minors under 14 years old requires the consent of the person holding parental authority or legal guardianship.

6. Categories of personal data processed

a) Data processed when creating an SPC Kite account

Email address
Password
User identifier

b) Data processed when linking a device

Technical identifiers necessary for linking
Association of the device with the parental account

c) Data processed during supervision

Device usage information
Device status
Battery level
Parental control events (blocks, permissions, limits)

d) Subscription and payment data

Information necessary to manage subscriptions

Payment data is processed exclusively through secure payment platforms and is neither stored nor directly accessible by SPC.

7. Background execution

To offer its main features, SPC Kite may run in the background on the supervised device, allowing parental control functions to remain active even when the app is not open.

This behavior is essential for the service's purpose, is directly related to its main functionality, and is clearly communicated to the user before activation.

8. Use of the AccessibilityService API

SPC Kite uses the Android AccessibilityService API exclusively to enable essential parental control functions, such as applying usage restrictions, detecting app status, and executing predefined actions necessary to manage the supervised device.

The app is not an accessibility tool nor does it claim such status, and the use of this API is not intended to assist people with disabilities.

SPC Kite does not collect or transmit sensitive content through this API, including, but not limited to:

Text entered by the user or keystrokes
Passwords
Private messages
Financial or payment data

The use of this API requires the knowledge and explicit informed consent of the legal guardian, obtained through a specific disclosure within the app before its activation.

The data processed through the AccessibilityService API is used exclusively for parental control purposes, is not reused for other purposes, and is not shared with third parties for advertising or commercial purposes.

9. Processing of minors' data

SPC Kite involves the processing of personal data of minors, so SPC applies enhanced protection measures.

In particular:

The minor's data is only accessible by the authorized legal guardian.
No personalized advertising is shown to minors.
No commercial profiling of minors is performed.
Data of minors is not sold, rented, or shared for advertising or marketing purposes.

10. Platform transparency and data safety statements

SPC Kite complies with the Google Play User Data Policy and provides accurate information in the Data Safety section of Google Play, reflecting:

What data is collected and processed.
For what purposes data is used.
If data is shared (it is not shared, except with providers acting as data processors).
That users can request the deletion of their data.

The information provided on Google Play is consistent with this Privacy Policy.

11. Legitimate use and limitations

SPC Kite is not designed for covert surveillance, corporate espionage, or unauthorized tracking of adults.

Its use is strictly limited to family environments and requires the legal guardian to have a legitimate right to monitor the configured device, in accordance with applicable law.

12. Data retention

Personal data will be retained:

While the SPC Kite account is active.
While there is a contractual relationship.
For the periods required by applicable regulations.

Once the relationship ends, data will be deleted or anonymized, except for legal retention obligations.

13. Data recipients

Personal data is not sold or shared with third parties.

SPC may use service providers acting as data processors under written contracts that guarantee compliance with the GDPR.

14. International data transfers

If any service involves international data transfers, SPC will ensure an adequate level of protection through legally recognized mechanisms.

15. User rights

Users can exercise their rights of access, rectification, deletion, opposition, restriction of processing, and portability by sending a request to privacy@spc.es.

They may also file a complaint with the Spanish Data Protection Agency (www.aepd.es).

16. Parental responsibility

SPC Kite is a parental control support tool. The legal guardian is responsible for:

Properly configure the monitoring features.
Inform the minor about the use of the app, according to their age and level of maturity.

17. Changes to the privacy policy

SPC may update this Privacy Policy to adapt it to legal or functional changes. Updates will be communicated through the app or by other reasonable means.

18. Applicable law

This Privacy Policy is governed by Spanish and European data protection legislation.

CONTENTS AND THE QUALITY OF SERVICE

SMART PRODUCTS CONNECTION, S.A. does not assume any responsibility arising from the contents linked on the Website, provided they are external to it, nor does it guarantee the absence of viruses or other elements in them that may cause alterations in the computer system (hardware and software), in the user's documents or files, excluding any liability for damages of any kind caused to the user for this reason.

In the event that any user, client, or third party considers that the content or services provided by the linked pages are unlawful or harm the goods or rights of the user, a client, or a third party liable for compensation, and, in particular, consist of:

- Activities or contents that may be considered criminal under Spanish criminal law.

- Activities or contents that violate intellectual or industrial property rights.

- Activities or contents that endanger public order, criminal investigation, public safety, and national defense.

- Activities or contents that endanger the protection of public health, respect for human dignity and the principle of non-discrimination, and the protection of health and childhood.

You may notify SMART PRODUCTS CONNECTION, S.A. of this; however, receipt of such communication shall not imply knowledge for the purposes of the liability provided for in article 17 of the LSSICE.

SMART PRODUCTS CONNECTION, S.A. is not responsible for the lack of usefulness or suitability for a specific use of this Website. It is also not liable for any harm the User may suffer due to errors or omissions that the contents of this Website may have, although it commits to periodically verify and monitor its contents and information.

USE OF THE WEB PORTAL

SMART PRODUCTS CONNECTION, S.A. will not be held responsible under any circumstances for the use that Users may make of the Website or the Contents, nor for any damages or losses that may arise from it.

LINKS TO OTHER WEBSITES

Any third-party link to the Website must be to its main page, with “deep links,” “framing,” and any other use of the Website’s content for the benefit of unauthorized third parties expressly forbidden.

Through this Website, the User may access websites belonging to and/or managed by third parties.

The presence of such links is purely informative and does not in any case constitute an invitation to contract products or services offered on the destination Website. The User accesses the content under their sole responsibility and according to the terms of use governing those sites. The User acknowledges and agrees that SMART PRODUCTS CONNECTION, S.A. is not directly or indirectly responsible for any damages caused by access to such links.

If SMART PRODUCTS CONNECTION, S.A. becomes effectively aware that the information or activity referred to by such links is unlawful, constitutes a crime, or may harm the goods or rights of a third party subject to compensation, it will act with due diligence to remove or disable the corresponding link as soon as possible.

INDUSTRIAL PROPERTY

The use of the website does not grant the user any rights over trademarks, trade names, distinctive signs, or designs of any kind that appear on the website.

Articles, news, legislation, and other public content whose intellectual property rights do not belong to SMART PRODUCTS CONNECTION, S.A. are published solely to inform the users of this site.

SMART PRODUCTS CONNECTION, S.A. holds the rights to the source code, design, navigation structure, databases, and the various software elements of the website, as well as the industrial and intellectual property rights related to the content included therein.

APPLICABLE LAW AND JURISDICTION

SMART PRODUCTS CONNECTION, S.A. reserves the right to take civil or criminal actions it deems appropriate for the improper use of its website or for the breach of these terms.

The relationship between the user and the provider shall be governed by the laws in force and applicable within the Spanish territory. Should any dispute arise, the parties may submit their conflicts in accordance with the rules on jurisdiction and competence in this regard. SMART PRODUCTS CONNECTION, S.A. is domiciled in ARABA/ÁLAVA, Spain.