Privacy Policy
1. General
The objective of this privacy policy is to provide transparent information about the nature, scope, and purposes of the collection and processing of your personal data arising from the use of VIVELIBRE MOVILIDAD, as well as inform you of your rights and options regarding data protection.
VIVELIBRE fully complies with data protection regulations, specifically with Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016, concerning the protection of individuals with regard to the processing of personal data (GDPR), the Organic Law 3/2018, of December 5, on Personal Data Protection and guarantee of digital rights, or any regulations that complement or replace them. Any personal data processing carried out during the development of VIVELIBRE SERVICES will comply with the required legal guarantees and obligations.
2. Who is responsible for your data?
The Data Controller for the personal data entered into the VIVELIBRE MOVILIDAD application is VIVELIBRE AUTONOMÍA PERSONAL, S.L. (VIVELIBRE), with registered office at Calle La Orotava 4, 28660, Boadilla del Monte, Madrid, and VAT number B-87070199.
By contracting, accessing, and/or using the application, you will be considered a user (hereinafter “User”), for which reading and accepting this Privacy Policy is necessary.
If you have any questions regarding data protection related to the VIVELIBRE MOVILIDAD application, you can contact the Data Protection Officer (DPO) of VIVELIBRE via email at protecciondedatos@vivelibre.es.
3. What data do we collect?
The VIVELIBRE MOVILIDAD application may process the following personal data of the User, whether as a User of the Service, a Family Member, or another authorized contact person. The personal data collected by VIVELIBRE will be used solely to provide the services for which the VIVELIBRE MOVILIDAD application is designed.
The data collected through the application will include:
– Identity information: Name, surname, ID/NIE or passport, profile photo, health card or mutual insurance number, private medical insurance, medical history number.
– Contact information: Phone number, email, postal address, city, and postal code.
– Personal characteristics: Sex, nationality, age, date of birth, height, weight, anthropometric characteristics.
– Family circumstances: Relationship between the User of the Service and the designated contacts, affiliation, or other family data.
– Device information: Information to ensure the app’s operation and service provision: operating system version, device brand and model, device settings (battery percentage and connectivity status).
– Location information: GPS location of the mobile device.
– Health data: Medication regimen, disability condition, dependency degree, or other information related to physical or mental difficulties, if applicable. These health data will be processed solely by the VIVELIBRE Support Unit to respond to emergencies or when the User contacts the Support Unit.
– Device movement and orientation data: Data from the device sensors (accelerometer and gyroscope).
– Family data: Relationship between the User and the designated contacts.
– Data of interactions with VIVELIBRE: Time, date, email, sender identity, technical data, and data included in any communication between the User and VIVELIBRE.
– Data collected in teleassistance service and contact with the VIVELIBRE Support Unit: Personal data in the event of an emergency communication or notification about the User’s situation, including health data and, if applicable, geolocation of the User.
VIVELIBRE may also process observed data regarding the use of the VIVELIBRE MOVILIDAD app or device settings information (e.g., operating system, location, language, etc.).
4. Purpose and legal basis for processing personal data
In accordance with applicable regulations, VIVELIBRE only collects data that is strictly necessary to provide the services related to its activity and other tasks, management, and activities attributed by law. Your personal data will be used for the following purposes:
- Creating a VIVELIBRE account: The User, after contracting the Services, can proceed with creating a User account either directly or through the person who contracted the Services. This allows the User to manage all tasks related to registering in the VIVELIBRE MOVILIDAD application.
- Contacting and providing information to contacts provided by the User: This allows VIVELIBRE or the User to contact the family members, caregivers, or professionals provided by the User of the Service to the VIVELIBRE Support Unit or, if applicable, the User’s legal representative or guardian.
- Using teleassistance service and contacting the VIVELIBRE Support Unit: VIVELIBRE will process your data to provide you with the Support Unit service in case of any emergency situations. This may involve sharing data with the appropriate health authorities to provide medical attention.
- Geolocating via the mobile device to show location: VIVELIBRE will access GPS data of the mobile device to provide the VIVELIBRE MOVILIDAD services. If the User does not grant access to geolocation, the services may not be fully available.
- Sending reminders to the User: VIVELIBRE will send reminders related to the User’s personal information or health status, as well as medical appointments or events. These reminders may also be communicated to family members, caregivers, or support professionals.
- Access to interaction history: VIVELIBRE may process data related to alerts generated by the User during the course of the service, and these alerts will be accessible to the User, their family, caregivers, support professionals, or legal representative after they have been managed by the Support Unit.
- Statistical purposes to improve the quality of services: VIVELIBRE may process anonymized personal data to conduct studies or statistical reports to improve the VIVELIBRE MOVILIDAD service.
5. Will your data be communicated to third parties?
Your personal data will not be transferred to other entities for their own purposes, unless there is explicit consent from the User or a legal obligation that applies to VIVELIBRE, or if such communication is necessary to protect the vital interests of the User. However, certain subcontracted entities may access personal data as data processors to ensure proper functioning of VIVELIBRE MOVILIDAD services, primarily related to technological, logistical, or service delivery aspects.
No international data transfers outside the European Economic Area are planned. If any occur, VIVELIBRE will adopt necessary measures to ensure compliance with applicable regulations.
6. How long will we keep your personal data?
In general, data will be retained during the User’s condition as a service user and, later, may be stored in a blocked state for five (5) years from cancellation or deletion. Health data may be stored as part of the User’s medical history for the legal retention periods.
7. Rights of Data Subjects
The User, their family, or designated contacts can exercise the following rights:
- Withdrawal of consent, Access, Rectification, Deletion, Opposition, Limitation, Portability, and the right not to be subject to automated decisions, as detailed in the GDPR.
8. Security Measures
VIVELIBRE has implemented legally required data security measures to protect your personal data from destruction, loss, misuse, alteration, unauthorized access, and theft.
9. Minors and Users with Limited Capacity
To use VIVELIBRE MOVILIDAD services, the User must be over 18 years old and fully capable. If the User has limited capacity, the registration must be completed by their legal representative or guardian.
10. Data Quality
The User, or their legal representative, guarantees the accuracy and authenticity of the personal data provided or collected through the services.
11. Deactivation of the User’s account
In general, VIVELIBRE may proceed to deactivate the User’s account when (i) the User revokes his/her consent or expressly requests the deactivation of his/her account or (ii) in the event that VIVELIBRE or the contractor of the VIVELIBRE MOBILITY Services decide to terminate the provision of services.
12. Updating and modifying the Privacy Policy
VIVELIBRE reserves the right to modify this Policy to adapt it to legislative or jurisprudential developments as well as to industry practices. In such cases, VIVELIBRE will announce the changes introduced on this page with reasonable advance notice of their implementation.