ONAVITAL PRIVACY POLICY
In compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data («GDPR«) and Organic Law 3/2018 of 5 December 2018 on the protection of personal data and guarantee of digital rights («LOPDGDD»), then Onalabs Inno-hub, S.L. (hereinafter «Onalabs«), developer and responsible for the OnaVital+ application, provides the user with information on the processing of their personal data carried out in this application (hereinafter, the «OnaVital«).
- Who is the data controller?
| Identity | Onalabs Inno-hub, S.L. |
| NIF | B66905936 |
| Mailing Address | Avinguda Parc Tecnològic 3, 08290 Cerdanyola del Vallès (Barcelona) |
| legal@onalabs.com |
- For what purpose and legal basis do we process personal data?
If you are a user of OnaVital, you should know that Onalabs may process your data based on the following purposes and legal bases:
| Installation of OnaVital | For the correct installation and operation of OnaVital on the user’s device, it is necessary to know and process certain technical information, such as the installed operating system, or the available memory space. Legal basis: the processing of the user’s personal data will be carried out on the basis of legitimate interest. |
| User registration and management in OnaVital | In order for the user to access OnaVital, it is necessary for the user to provide how much data is required for the user’s registration. Once the user’s profile has been created, the data will be used for its management, which means that data from the profile can be added, modified or deleted.
Legal basis: the processing for the management of the user’s registration will be carried out for the performance of a contract to which the user is a party (Article 6(1)(c) of the GDPR). |
| Facts about the OnaVital bracelet | In the event that the user links an Ona Vital bracelet to its user, vital signs such as: pulse, oxygen saturation, systolic blood pressure, diastolic blood pressure and skin temperature will be monitored. The information is collected through the wristband linked to OnaVital that will send the information to the user and display it through OnaVital. This processing includes the processing of physiological and health data. OnaVital is a solution that seeks to monitor in real time and in a non-invasive way the main physical parameters for the health care of its users, and allows detecting anomalies in the data it monitors and alerting when values are reached that are outside the ranges determined as normal for a standard person. Legal basis: The processing of users’ physiological and health data will be carried out on the basis of the explicit consent necessary for registration with Onalabs. See consent information. |
| Query management | If you contact Onalabs to raise a query or file a complaint, your personal data will be used to respond to and manage, if applicable, the query or complaint. Legal basis: any processing of personal data related to a query or claim will be carried out on the basis of the user’s consent given when the query, complaint or claim was made, or on the basis of the execution of a contract, if it is related to the service received. |
| Compliance with legal obligations | The processing of the user’s personal data may be carried out in compliance with legal obligations imposed on Onalabs, including, where appropriate, communication to competent authorities. Legal basis: the processing of the user’s personal data will be carried out on the basis of a legal obligation imposed on Onalabs. |
| Commercial Communications | Provided that there is a legal basis that allows it, your data will be used to send you information about Onalabs and our own commercial communications informing you of news or events organized by us and that may be of interest to you. Legal basis: the processing of the user’s personal data will be carried out on the basis of the consent given or on the basis of legitimate interest, as the case may be. |
| Satisfaction and quality surveys | We may contact you, from time to time, to find out how satisfied you are with the use of OnaVital and to improve the quality of our products and services. Legal basis: the processing of the user’s personal data will be carried out on the basis of legitimate interest |
- How long will we keep personal data?
Personal data will be processed for the period of time necessary to comply with the purposes described in this Privacy Policy and with the obligations imposed by the applicable laws, the legal limitation periods, and for the formulation, exercise or defense of claims, in which case, the personal data will be duly blocked.
The health data collected by the bracelet and displayed in OnaVital will be deleted once the user profile linked to the bracelet is cancelled.
- To which recipients can your data be disclosed?
Without prejudice to the fact that your personal data must be communicated under legal obligation to competent authorities, Onalabs will communicate your personal data to third parties who process your personal data in their capacity as data processors.
OnaVital allows users who have an OnaVital wristband linked to their profile to proactively authorize other users to access vital signs monitoring data. The purpose of this feature is for caregivers or healthcare professionals to be able to track the health data of the user with a linked wristband and it is this user who is solely responsible for authorizing or denying this access. Onalabs is not responsible for the processing of data that may be carried out by authorized users.
- What are your rights?
- Right to request access to personal data: you can ask if we are processing your data, and if so, access it.
- The right to request rectification if the data is inaccurate, or to complete the data that we have incomplete.
- Right to request the deletion of your data.
- Right to request the restriction of its processing: in this case, we will only keep your information for the exercise or defence of claims.
- Right to object to processing: we will no longer process personal data, with the exception that it must continue to be processed for legitimate reasons or for the exercise or defence of possible claims.
- Right to data portability: in the event that you want your data to be processed by another data controller, we will facilitate the transfer of your data to the new controller, whenever technically possible.
- The right not to be subject to a decision based solely on the automated processing of your personal data.
Onalabs processes data on the basis of consent, you should be aware that the affected party may withdraw consent at any time, without the withdrawal of consent affecting the lawfulness of the processing carried out prior to the withdrawal.
To exercise your rights, you can contact Onalabs by legal@onalabs.com or in writing to the postal address indicated in point 1 of this privacy policy. Likewise, the user may file a complaint whenever he/she deems it appropriate with the competent authority, in this case, the Spanish Data Protection Agency (https://www.aepd.es), especially when he/she has not found satisfaction of his/her rights before Onalabs.
- Additional information.
| Child Use Policy | The benefits of this campaign are aimed exclusively at people of legal age. We do not knowingly collect information from minors. In any case, if you are a mother or father or legal representative and you consider that the minor has provided personal data to Onalabs, please contact us by sending an email to legal@onalabs.com. |
| Personal data of third parties | If the data provided belongs to a third party, the user guarantees that they have duly informed the third party of the aspects contained in this privacy policy and that, where appropriate, they have obtained their consent for the processing whose execution requires it. |
| Links | On OnaVital there may be links to other websites that Onalabs considers to be of interest to the user. Please note that Onalabs is not responsible for the processing of personal data that may be carried out by third party owners of the domains of these links. |
| Updates | The processing of the user’s personal data will be carried out in accordance with the provisions of this privacy policy. In the event that Onalabs makes a modification to its policies, the user will be informed appropriately. |
Update date: 06/11/2023
