Privacy policy — VitalKeep

Legal

Your family’s data, treated with the respect it deserves.

1. Data controller

The controller of your personal data is:

Ingeniatic Desarrollo, S.L. (hereinafter «Vitalkeep»).
Tax ID: B-30861728
Address: Calle del Ángel s/n, Edificio ELDI-UPCT, 30202 Cartagena (Murcia), Spain.
Data Protection Officer: privacidad@vitalkeep.es

2. What data we collect

Data collected through the website

Browsing data (technical cookies, IP address, browser, language).
Data you provide in forms: name, email, phone, shipping and billing details.

Data collected through the product and app

Account and invited caregivers’ data (name, email, phone).
Monitored user data: name, age, sex, health- and care-related data (routines, presence by room, fall events, SOS alerts, device battery).
Hardware technical identifiers (serial numbers, MAC).
Mobile-phone location, only if companion mode is turned on (section 12): the position of the monitored person’s phone when they are away from home, and whether they are at home or out. The wristband has no GPS and never sends coordinates on its own.

What we do NOT collect: images, video or audio. The wristband has no camera, no microphone and no GPS, and we do not use a SIM card. The only outdoor location we process is the one from companion mode, which is optional, is turned on in the monitored person’s own phone and is explained in section 12.

3. Why we process your data

To deliver the monitoring service you’ve contracted and to send alerts to the designated caregivers.
To manage your account, subscription, payments and billing.
To assist you when you contact support, including the app’s artificial intelligence assistant.
To let the family know whether the monitored person is at home or out and where they are when they go out, only if companion mode is turned on (section 12).
To improve the product based on aggregated and anonymised statistics.
To fulfil our legal obligations (tax, accounting).
To send you commercial communications about Vitalkeep, only with your explicit consent.

4. Legal basis

Performance of contract: to deliver the service you’ve signed up for and answer your queries.
Explicit consent: for processing health data, for sending the phone’s location in companion mode (section 12) and for sending commercial communications. You can withdraw it at any time.
Legal obligation: retention of tax and billing data.
Legitimate interest: improving the product based on aggregated, anonymised data.

5. How long we keep your data

Account and service data: while the subscription is active, and up to 12 months after cancellation.
Health and monitoring data: 12 months (rolling window) unless the user requests early deletion.
Tax and billing data: 6 years, as required by law.
Marketing data: until you withdraw consent.
Conversations with the AI assistant: 60 minutes after the last interaction (see section 11).
Companion-mode location: 24 hours. Only the last 24 hours are kept; anything older is deleted automatically. If you stop sharing your location, it is deleted immediately.
Companion-mode consent record: while companion mode is active and, afterwards, for as long as is necessary to be able to evidence it.

6. Recipients and international transfers

Your data is not shared with third parties, except for those strictly necessary to provide the service: hosting provider in the European Union (Netherlands and Germany), payment gateway and push notification platform. All of them are bound by data processing agreements compliant with the GDPR.

The service infrastructure (monitoring platform, backend and database) is hosted in data centres within the European Union (Netherlands and Germany). We do not carry out international transfers outside the European Economic Area for monitoring data. The only exception is the artificial intelligence assistant described in section 11.

7. Your rights

As a data subject, you have the right to:

Access: know what data we hold about you.
Rectification: correct inaccurate data.
Erasure («right to be forgotten»): delete your data when no longer needed.
Object: object to certain processing.
Restriction: restrict processing in certain cases.
Portability: receive your data in a structured, commonly used format.
Not be subject to automated decisions with significant legal effects.
Withdraw consent at any time.

8. How to exercise your rights

Write to privacidad@vitalkeep.es stating your request and attaching a copy of a document proving your identity. We will reply within a maximum of one month.

If you feel we haven’t handled your request properly, you can file a complaint with the Spanish Data Protection Agency (www.aepd.es).

9. Security

We apply appropriate technical and organisational measures to protect your data: encryption in transit (TLS) and at rest, access control, regular audits, backups and incident response plans. We will notify any relevant security breach to the AEPD and, if applicable, to those affected, within the timeframes required by law.

10. Changes to this policy

We may update this policy to reflect legal or service changes. We’ll notify you by email of any substantial change.

11. Artificial intelligence assistant

The app includes a help assistant based on artificial intelligence (AI). We inform you of this in accordance with Article 50 of Regulation (EU) 2024/1689 (the AI Act) and Spanish AI legislation.

What it is: an automated help assistant for the app and the devices. It identifies itself as an AI within the conversation and will confirm it if you ask. It is not a person.
What it is not: it does not provide medical advice or diagnosis, and it does not replace emergency services or a caregiver’s supervision. In an emergency, call 112.
It makes no decisions about you: VitalKeep alerts (falls, inactivity, leaving home, SOS) are generated by a rule-based system defined and documented by our team, not by the assistant, and they are always handled by a person: the designated caregiver. No decision with legal or similarly significant effects is taken solely by automated means.
What data it processes: the text you type and, in order to answer, a summary of the current monitoring status of the people in your care (first name, room, activity, rest, battery and recent alerts). No billing data or full identifiers are sent to it.
Who processes it: the conversation text is sent to an external language-model provider solely to generate the reply, under a data processing agreement. That provider may process the data outside the European Economic Area; in that case the transfer relies on the safeguards of Chapter V of the GDPR (European Commission standard contractual clauses).
How long it is kept: VitalKeep does not store conversations. They are held in server memory only during the session and deleted after 60 minutes of inactivity.
Your rights: you can use the app without the assistant; it is an optional feature. The rights in section 7 also apply to this processing.

Companion mode is an optional feature that lets the family know whether the monitored person is at home or out and where they are when they go out. Unlike the rest of the service, in this mode the monitored person’s own phone sends its location to VitalKeep.

How it is turned on: by installing the app on the monitored person’s phone and pairing it with a one-time code generated by a family administrator. Before any location is sent, the app shows a consent screen and asks for the system location permission. Without that consent, the mode is not enabled.
What is sent: at home, only the notice that they are at home (no coordinates) and the phone’s status (battery and whether location permission is on). Away from home, also the phone’s position. If the permission granted is approximate location, the position is sent and marked as approximate.
How often: at home, one update every 15 to 30 minutes. Away from home, the position every 5 minutes at most. When they leave home or come back, the family knows right away.
Who sees it: the family members on the VitalKeep kit and the VitalKeep administrator. It is not sold or used for advertising, and it is not disclosed to third parties other than the data processors strictly necessary to provide the service.
How long it is kept: only the last 24 hours; anything older is deleted automatically (see section 5).
How it is protected: location is encrypted in transit (TLS) and stored encrypted on the server with field-level encryption (AES-256-GCM with keys that are destroyed periodically). It is never stored in the clear.
How to stop sharing: with “Stop sharing” on the app’s main screen. The phone stops sending location and VitalKeep deletes the location it already had. There is also a temporary pause. The monitored person can withdraw this consent at any time without losing the rest of the service.
Maps: the family sees the position on a map with OpenStreetMap tiles. The tile provider receives the IP address of the family member viewing the map and the area they are looking at, but not the monitored user’s coordinates as data. Google Maps is not used.
No automated decisions: the location is shown to the family; it does not by itself produce any decision with legal effects on the monitored person.
Vulnerable people: the mode is enabled from the monitored person’s own phone, with their consent, or with that of their legal representative where applicable. The detail of the consent and of the impact assessment is settled with the service’s legal review.

Last updated: October 2026.