Privacy policy

Privacy policy

This Privacy Policy applies to the processing of personal data resulting from the registration, access and use of Glucovibes, for the purposes detailed below.

By the very nature of Glucovibes, aimed at obtaining blood glucose data, analysis of lifestyle habits, activity and nutrition, participation in GLUCOVIBES requires you to provide us with a series of personal data, including data on your physical condition or health.

Before accepting this personal data processing policy, please read this document carefully and, if you have any doubts about its content, please let us know by any of the means of contact detailed here. If you do not agree with the terms of this Policy, please do not access or use the Glucovibes app.

In accordance with Data Protection regulations, we inform you of the following aspects:

1.- WHO IS RESPONSIBLE FOR THE TREATMENT OF YOUR PERSONAL DATA?

The controller responsible for the treatment of your personal data is::

XH Digital Health SL con NIF B05335377, residing at Parque Empresarial Zuatzu
Juan Fermín Gilisagasti, 2 Oficina 312 20018 Donostia–San Sebastián Gipuzkoa, España – Email address: info@glucovibes.com.

2.- FOR WHAT PURPOSES WILL WE PROCESS YOUR PERSONAL DATA?

  • To manage your registration and use of Glucovibes, which allows, through a computer application installed on your mobile device, access to myglucovibes and the sensor attached to your body, the monitoring of your glucose level, physical evaluation and analysis of lifestyle, activity and nutrition habits.
  • To create a profile of each user in Glucovibes based on the data relating to their glucose entered in the application, as well as the nutritional and activity data entered and the evolution of the same during the duration of their Glucovibes subscription.
  • To manage communications with users.
  • For statistical and/or research purposes, your data, duly pseudonymised, will be used for statistical and/or research purposes in the area of sports and nutritional activity.

Glucovibes will process the following personal data:

  • Identification data, including image.
  • E-mail address.
  • Habits related to your physical and nutritional activity.
  • Specially protected data: Data relating to health (Art. 9 of the General Data Protection Regulation (EU Regulation 2016/679). 

You are not obliged to provide us with any personal data about yourself or third parties, but in order to use GLUCOVIBES it is necessary to collect the data required for the operation of the GLUCOVIBES software application, so that the intended purposes can be fulfilled. If you do not provide us with this data, you will not be able to use Glucovibes.

We will not process your personal data for any purpose other than those described above unless required by law.

CONSERVATION PERIOD: The personal data provided by you will be kept for the period of time during which you are a user of Glucovibes. After this period of time, the data may be kept by the person responsible for GLUCOVIBES duly anonymised and/or disaggregated, for research or statistical purposes. This is without prejudice to the possibility of exercising your right to erasure, in which case GLUCOVIBES will block your data for as long as its legal obligations persist.

3.- WHAT IS THE LEGAL BASIS FOR US TO PROCESS YOUR DATA?

  1. The legal basis for the processing of your data for the purpose of enabling the use of Glucovibes is your CONSENT.  
  2. EXPRESS CONSENT TO THE PROCESSING OF HEALTH DATA: As a user of Glucovibes, you understand and expressly authorise us to process the essential data relating to your glucose level.
    Este consentimiento expreso se materializará cuando usted se registre como usuario/a en Glucovibes a través de cualquiera de los formularios establecidos al efecto, o se registre como usuario en la aplicación informática, activando la casilla o el botón correspondiente.

     

    Prior to your acceptance, you have been able to access the basic information on data protection, as well as the further information and details contained herein, which are always accessible online via the website www.glucovibes.com.

    The legal basis for the treatment of your personal data for statistical or scientific research purposes is regulated in article 6.1. section f) of the GDPR on the basis of the legitimate interest of the Data Controller, in accordance with article 89, paragraph 1 of the GDPR.

     

  3. The legal basis for the treatment of your data for the purpose of invoicing as well as the sending of commercial communications in your case is the existing contractual relationship.

4.- RECIPIENTS OF ASSIGNMENTS OR TRANSFERS.

Your data will be kept under strict security measures that guarantee their confidentiality and security. For the complete development of Glucovibes, some of your personal data may be transferred or communicated to third parties other than the party responsible for providing certain services included, related or necessary for the operation of Glucovibes.

By way of example and without limitation of the services provided to us and which may involve the processing of your personal data on behalf of the data controller, we can cite: multidisciplinary professional services, logistics, advice and consultancy, technological services, IT services, courier services, maintenance, etc.

The user may also allow certain authorised users (prescribers, trainers, medical staff, etc.) to access his/her profile (and data) in order to analyse his/her progress. A review of permissions is recommended in order to check that the authorisation of these authorised users is still valid and is done with their consent.

GLUCOVIBES, apart from the situations mentioned above, will not transfer your personal data to other third parties unless we are legally obliged to do so, or unless you have expressly authorised us to do so. Nor are there any plans for international transfers or assignments.

Acceptance of this Privacy Policy implies that you expressly authorise these transfers of data for the purposes foreseen.

5.- WHAT ARE YOUR RIGHTS?

Any person participating in Glucovibes. has the right to obtain confirmation of how personal data concerning him/her are processed. In particular, you have the following rights under data protection regulations:

  • Right of access: allows the data subject to know and obtain information about his or her personal data undergoing processing.
  • Right of rectification: to correct errors, to modify data that prove to be inaccurate or incomplete and to guarantee the accuracy of the information undergoing processing.
  • Right of erasure: allows the data subject to request the deletion of the data undergoing processing.
  • Right to object: the data subject’s right not to have his or her personal data processed or to have the processing cease.
  • Limitation of processing: in certain circumstances, data subjects may request the limitation of the processing of their data, in which case it will only be kept for the exercise or defence of claims.
  • Data portability: data subjects may request to receive the data concerning them that they have provided to us or – where technically feasible – to have it sent to another data controller of their choice, in a structured, commonly used and machine-readable format.
  • Right not to be subject to automated individual decisions (including profiling): the right not to be subject to a decision based on automated processing which produces effects or significantly affects.

Likewise, the data subject has the right to withdraw the consent given at any time, without this affecting the lawfulness of the processing based on the consent given at the time of providing us with the data.

If you wish to exercise any of the above rights, please send us a letter with all your details to: Parque Empresarial Zuatzu – Juan Fermín Gilisagasti, 2 Oficina 312 20018 Donostia–San Sebastián Gipuzkoa, España by attaching your ID card or any other valid identification documentation or by e-mail to dpo@glucovibes.com

GLUCOVIBES also informs you of your right to lodge a complaint with the Spanish Data Protection Agency (www.agpd.es).

6.- WHAT SECURITY MEASURES DO WE APPLY TO PERSONAL DATA?

We implement the necessary security measures to prevent theft, alteration or unauthorised access to data, taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of the processing, as well as risks of varying likelihood and severity to the rights and freedoms of natural persons.

In the case of outsourced services, we require and ensure that the processor implements appropriate technical and organisational measures to ensure a level of security appropriate to the risks involved, as set out in art. 32 of the General Data Protection Regulation.

We also carry out Impact Assessments on those processing operations that we consider may have a risk to the rights and freedoms of individuals, in order to implement the necessary and appropriate measures to prevent a breach of confidentiality.

7.- DATA PROTECTION OFFICER

Glucovibes has appointed a Data Protection Officer (DPO) duly notified to the AEPD, who can be contacted at the following address or email: dpo@glucovibes.com