Owner and Data Controller: ASSOCIATION MUSEUM LAB
4bis, Rue Fraj Ben Saad
Carthage Byrsa, Tunisia
Phone: (+216) 20 276 643
Email: contact@museumlab.tn
Website: https://museumlab.tn/
Legal name: ASSOCIATION MUSEUM LAB
Unique identifier: 1519236E
Association creation date: 06/06/2017

Last updated: May 31, 2025

At ASSOCIATION MUSEUM LAB, the publisher of the Viabagrada application (hereinafter the “Application”), the protection of your privacy is our absolute priority. This privacy policy describes how we collect, use, and share your information when you use our mobile application “Viabagrada”.

1. Types of Data Collected

Among the types of Personal Data that the “Viabagrada” Application collects, by itself or through third parties, are: geographic position (precise and approximate, continuous or non-continuous), storage permission, camera permission, phone permission, social media accounts access permission, Cookies, Usage Data, first name, last name, email address, phone number, and unique device identifiers for analytics (e.g., Google Advertiser ID).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanatory texts displayed prior to Data collection. Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using the Application. Unless specified otherwise, all Data requested is mandatory and failure to provide this Data may make it impossible for the Application to provide its services. In cases where the Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner (ASSOCIATION MUSEUM LAB). Any use of Cookies – or of other tracking tools – serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy (if available). Users are responsible for any third-party Personal Data obtained, published, or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

2. Precise geographic location in the background for the Viabagrada application

The Viabagrada application collects location data to enable continuous guidance features, real-time discovery of relevant places, and activities requiring position tracking (e.g., hiking trails), even when the application is closed or in the background. This setting can be changed at any time in the device settings.

3. Mode and Place of Processing the Data

Methods of Processing
The Owner (ASSOCIATION MUSEUM LAB) takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal Basis of Processing
The Owner may process Personal Data relating to Users if one of the following applies:
• Users have given their consent for one or more specific purposes.
• Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.
• Processing is necessary for compliance with a legal obligation to which the Owner is subject.
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner.
• Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place
The Data is processed at the Owner’s operating offices (ASSOCIATION MUSEUM LAB, 4bis, Rue Fraj Ben Saad Carthage Byrsa, Tunisia) and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can contact the Owner. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries (such as the UN), and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention Time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill those purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period.

4. The Purposes of Processing

Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes:
• Location-based interactions
• Device permissions for Personal Data access
• Analytics
• Hosting and backend infrastructure
• Infrastructure monitoring
• Interaction with external social networks and platforms (if applicable, e.g., content sharing)
• Interaction with online survey platforms (if applicable)
• User registration and authentication
• SPAM protection
• Contact management and message sending (including push notifications if enabled)
• Heat mapping and session recording (if applicable for UX improvement)
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

5. Device Permissions for Personal Data Access

Depending on the User’s specific device, the Application may request certain permissions that allow it to access the User’s device Data as described below. By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. To revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document. The exact procedure for controlling app permissions may be dependent on the User’s device and software. Please note that revoking such permissions might impact the proper functioning of the Application. If the User grants any of the permissions listed below, the respective Personal Data may be processed (i.e., accessed, modified, or removed).
• Approximate location permission (non-continuous): Used for accessing the User’s device approximate location. The Application may collect, use, and share User location Data in order to provide location-based services. The geographic location of the User is determined in a non-continuous manner.
• Precise location permission (continuous): Used for accessing the User’s device precise location. The Application may collect, use, and share User location Data in order to provide location-based services and real-time guidance.
• Camera permission: Used for accessing the camera or capturing images and video from the device.
• Storage permission: Used for accessing shared external storage, including the reading and adding of any items (e.g., for uploading photos from the gallery).
• Phone permission: If the Application offers the possibility to call listed places directly (restaurants, hotels), this permission may be used to access typical features associated with telephony (e.g., reading phone status, device phone number).
• Social media accounts access permission: If the Application integrates features for logging in or sharing via social media account profiles (such as Facebook and Twitter).

6. Users’ Rights

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:
• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of, or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner, or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner (ASSOCIATION MUSEUM LAB) through the contact details provided in this document (see section “Owner and Data Controller” at the beginning or “Contact Us” at the end). These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

7. Cookie Policy

The Application uses Cookies. To learn more and for a detailed cookie notice, the User may consult the [Link to your Cookie Policy if separate, otherwise delete or integrate cookie information here].

8. Additional Information about Data Collection and Processing

Legal Action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of the Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional Information about User’s Personal Data
In addition to the information contained in this privacy policy, the Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System Logs and Maintenance
For operation and maintenance purposes, the Application and any third-party services may collect files that record interaction with the Application (System logs) and use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document (section “Owner and Data Controller”).

Handling of “Do Not Track” requests
The Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor “Do Not Track” requests, please read their privacy policies.

9. Changes to this Privacy Policy

The Owner (ASSOCIATION MUSEUM LAB) reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within the Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top. Should a User object to any of the changes to the Policy, the User must cease using this Application and may request the Owner to remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Owner has about Users.

10. Definitions and Legal References

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy. The list of Data Processors may be requested from the Data Controller.

Data Controller (or Owner)
The Data Controller is: ASSOCIATION MUSEUM LAB
4bis, Rue Fraj Ben Saad
Carthage Byrsa, Tunisia
Phone: (+216) 20 276 643
Email: contact@museumlab.tn
Website: https://museumlab.tn/
Legal name: ASSOCIATION MUSEUM LAB
Unique identifier: 1519236E
Association creation date: 06/06/2017

To request access to personal data: Contact the Data Controller (ASSOCIATION MUSEUM LAB).

Contact Us
If you have any questions about this Privacy Policy, your data, or if you wish to exercise your rights, please contact us:
By email: contact@museumlab.tn
By mail: ASSOCIATION MUSEUM LAB, 4bis, Rue Fraj Ben Saad Carthage Byrsa, Tunisia.