Legal · Phone app
Privacy policy for the phone app
Last updated:
This policy explains what data “DNIe NFC: Spanish ID & e-sign” (in Spanish, "DNIe NFC: firma y trámites"), NEXO APEX S.L.'s app for iPhone and Android, processes. The short version: your DNIe data, your PIN and your documents never leave the phone, and we have no server of our own, no accounts and no analytics. The only things that leave the phone are the connections described below. The Mac app and this website have their own privacy policy.
1.Data controller
- Controller
- NEXO APEX S.L. ("nexoapex"), publisher of the app
- Spanish tax ID (NIF)
- B55467146
- Registered address
- Edificio Camí Reial, c/ Camí Reial 13-17, 3a planta, 43700 El Vendrell, Tarragona, Spain
- Contact
- macdnie@nexoapex.com · +34 659 696 741
- Data protection
- rgpd@nexoapex.com, to exercise your rights
- Scope
- The “DNIe NFC: Spanish ID & e-sign” app for iPhone (iOS) and Android
2.What never leaves your phone
The app reads the chip of your DNIe, passport or TIE over NFC. Everything below is processed only on your phone and is not sent to nexoapex or to anyone else:
- The chip data: name, number, address, photo and certificates.
- Your PIN. It is only kept in the phone's memory for a few minutes, so you can retry a tap that failed; it is never written to storage or logged. It is wiped if it is wrong, after 5 minutes unused, after 2 minutes in the background, when you tap "Forget" or when the app closes.
- The CAN. It is stored encrypted in the iPhone Keychain or in Android's encrypted storage, on that device only, and you can delete it.
- The documents you sign or check, which are saved only where you choose.
- The .p12 or .pfx certificates you import, which stay in the system's secure store (the iOS Keychain or the Android Keystore).
- Camera images, which the app uses on the spot to read the MRZ of a passport or TIE, or the CAN: they are processed on the phone and are neither stored nor sent.
3.The app's network connections
The app connects to the Internet only for the following. None of these connections goes through nexoapex servers and, like any connection, each one exposes your IP address to the server it reaches.
- Revocation check (OCSP), with the authority that issued the certificate (for example the Spanish National Police or the FNMT): only the certificate's serial number and its issuer's identifier are sent.
- Timestamp: only the document's fingerprint (hash) is sent to the timestamping service, never the document.
- E-offices you open in the DNIe Browser: you are talking directly to the public body, and your certificate is only used when you authorise it. What you do on each e-office is governed by that public body's privacy policy.
- Purchases: with Apple or Google, and with RevenueCat to validate them (section 4).
- Ads: with Google AdMob, only on the Free and Plus plans (section 5).
4.Purchases: Apple, Google and RevenueCat
Subscriptions are bought through Apple's (App Store) or Google's (Google Play) payment system, which process the payment entirely. nexoapex has no server of its own and never sees your card or payment details. Apple's and Google's processing is governed by their own policies: apple.com/legal/privacy and policies.google.com/privacy.
To validate purchases and keep your plan in sync we use RevenueCat (RevenueCat, Inc.) as a data processor. RevenueCat receives:
- the app's purchase and transaction history (product, dates, renewal or trial status);
- a random anonymous identifier the app generates on the device, not your name, your email or any account;
- basic device and app details: operating system, app version, language and store country.
RevenueCat receives no data from your DNIe or your documents. The legal basis for this processing is the performance of the subscription contract (Art. 6(1)(b) GDPR). RevenueCat, Inc. is based in the United States, which may involve a transfer of data outside the European Economic Area. Its policy: revenuecat.com/privacy.
5.Advertising (Free and Plus plans)
On the Free and Plus plans we show non-personalised Google AdMob ads. We do not ask for tracking permission and do not use the advertising identifier. Even so, Google's SDK collects technical data (device and app identifiers, interaction with ads, approximate location derived from the IP address, and diagnostics) to show ads, measure them and prevent fraud. Ads never appear on screens with your personal data, the PIN or the DNIe reading.
In the European Economic Area we ask for your consent with Google's tool (UMP), and you can change it at any time under "About DNIe" › "Ad privacy options". The Pro plan loads no ads. Google processes this data under its own policy, which may involve a transfer of data outside the European Economic Area: how Google uses information from apps that use its services.
6.No analytics or crash reporting of our own
The app has no analytics or crash reporting of our own: we do not know how often you open it or what you do with it. If you share crash reports with Apple or Google from the system settings, that is your choice, handled by them.
7.Email
If you write to us at macdnie@nexoapex.com, we process your address and the content of your message for the sole purpose of replying and following up on your query (legal basis: your consent and our legitimate interest in providing support). We keep the correspondence for as long as needed for that purpose and to evidence the support given.
8.Your rights (GDPR and LOPDGDD)
Under Regulation (EU) 2016/679 (GDPR) and Spain's Organic Law 3/2018 (LOPDGDD), you have the right to access, rectify and erase your data, to restrict or object to its processing, to data portability and to withdraw your consent. You can exercise them by writing to macdnie@nexoapex.com or to rgpd@nexoapex.com. Because the app has no accounts and we do not know who you are, to find the purchase data linked to your anonymous identifier we may ask you for a detail of the purchase, such as the Apple or Google order number.
If you believe we have not handled your rights properly, you can lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos): aepd.es.
9.Changes to this policy
If this policy changes, we will publish the new version here with its date. If a change were to substantially affect data processing in the app, we will also flag it in the release notes of the relevant version.