May 27, 2024

Privacy Policy

RESPONSIBLE FOR THE TREATMENT: (“Healthupp”), Fiscal Address: CIF of the Responsible: B-19512755 (after this, “Healthupp”), as the Owner and manager of this portal, informs the users of the Internet portal of its property (from now on, the “Users” and the “Portal”) about its data protection policy of a personal nature (from now on, “Personal Data”) so that users can freely and voluntarily determine whether they wish to provide HEALTHUPP with the Personal Data that may be required of them or that may be obtained from Users on the occasion of visiting our web reserves the right to modify this policy to adapt it to new legislation or jurisprudence as well as to industry/consumer practices, or similar that are applicable to the specific case. In such cases, HEALTHUPP will announce on this page the changes introduced with reasonable anticipation of their implementation.

Healthupp, as Responsible for the treatment of the personal data of ITS USERS, and the rest of the affected / owners with whom it maintains a relationship, informs you that these data will be treated in accordance with the provisions of Regulation (EU) 2016/679 of April 27 2016 (GDPR)  regarding the protection of natural persons with regard to the processing of personal data and the current LOPD-GDD 3/2018 of December 5 (LOPD-GDD) regarding the protection of data of character personal.

INFORMATION / DATA TREATED: Merely identifying data (name + surname) and contact information where appropriate (address, telephone number and email address), data necessary for contracting the Healthuppapplication, access to DEMO, registration in our service of Corporate Newsletter, C. Vitae received by email, data provided in events or acts of presentation of the application, data provided in the profiles in social networks of which Healthuppis the Owner, training activities managed by


Corporate website :

Designated DPO contact :


MAINTENANCE OF THE RELATIONSHIP with Users, updating and maintenance of the application, management of the relationship with the Healthupp providers, control and management of the relationship with employees and external collaborators, registrations and cancellations, management of the contractual relationship existing with collaborators, sponsors and the commercial relationship with suppliers, selection of HEALTHUPP workforce, candidates in selection processes, followers in Healthupp social networks, registered users on our website, participants in activities and events, including the possibility of training actions where HEALTHUPP manages or participates. In this sense, the operations planned to carry out the treatment are:


By filling in any of our forms, depending on each case:

In the aforementioned forms / sections, you are allowed to provide, among others, the following personal data:

Your name and surname and contact information (address, telephone numbers and email), and a space for free text.

Other contact information and preferences.

We collect your data if you contact us through the Site/access our DEMO.

Contact phone if you request “free call.”

When you visit our website, we will collect your data if you fill in any of our data / contact / training forms, request for information, or subscription to present or future newsletters.

If the personal data had been provided by users, they must be truthful, and HEALTHUPP must be notified of any changes that may occur in them, responding in any case to the veracity and accuracy of the data provided at all times.

The interested party who provides their personal data to HEALTHUPP declares to be of legal age and is entirely responsible for said declaration.

SENDING OF ADVERTISING COMMERCIAL COMMUNICATIONS by email, SMS, WhatsApp, social networks, or any other electronic or physical means, present or future, that enables commercial communications. These commercial electronic communications will be made by the CONTROLLER and related to the activities of HEALTHUPP, its collaborating companies and sponsors, or suppliers with whom it has reached an agreement. In this case, third parties will never have access to personal data, unless it is strictly necessary to manage an activity or similar.

ACTIONS REQUESTED BY THE USER: Process requests or any request that, regarding our catalog of activities and services offered by HEALTHUPP, is carried out by the user through any of the contact forms that are made available to them.

DATA STORED DURING YOUR VISIT: When you visit our website, our web servers generally store, among other data, information about the browser and operating system that you use, the web page from which you visit us, the pages you visit in our website and the date of your visit. For security reasons – for example, in order to detect possible attacks on our website – the IP address assigned to you by your Internet service provider is also stored for a period of seven days. With the exception of the IP address, personal data is only stored if you provide us with such information, for example, on the occasion of a registration for an activity, training, a survey, application, user registration. HEALTHUPP uses your personal data for the technical administration of the web pages, the management of users, owners, conducting surveys, training activities, promotional activities, etc …, only to the extent necessary, and always informing previously to the User and Owner of the data.

NEWSLETTER / NEWSLETTERS SUBSCRIPTION : In the case of subscribing to any of our informative Newsletter, present or future, as reported, you consent to the use of your personal data for sending advertising or carrying out other actions marketing, these will be stored and used for said uses, such as sending the aforementioned newsletters, news in our offer of activities offered by Healthupp,Through communication channels such as email, postal mail or any other channel authorized by you. We may use your data to create and update your user profile and thus be able to send you personalized information about advertising actions. Likewise, we may use the data you provide us to analyze and improve the effectiveness of our website services, advertising, marketing, market research and commercial activities.

SENDING OF C. VITAE BY CANDIDATES : In case of sending C. Vitae by candidate to any of our contact emails, or in the option enabled on our website: -with-us / the applicant authorizes HEALTHUPPto analyze the documents sent to him, all the content that is directly accessible through search engines (Google), the profiles he maintains in professional social networks, such as Linkedin or similar, the data obtained in the entrance exams and the information you reveal in the job interview, with the aim of evaluating your candidacy and being able, where appropriate, to offer you a position. In case the candidate is not selected, HEALTHUPP You may keep your C. VITAE stored to include it in future calls, unless the candidate states otherwise, through any of the referred channels.

DATA CONSERVATION CRITERIA : The data provided, in general terms, will be kept as long as there is a mutual interest to maintain the end of the treatment and when it is no longer necessary for that purpose, they will be deleted with adequate security measures to guarantee the pseudonymisation of the data or the total destruction of the same.

Given this general rule, the following possible variations are proposed : ( i ) Disaggregated Data: they will be kept without deletion period, ( ii ) Data of users, companies and suppliers, etc … HEALTHUPP: conservation period of 4 years (Art. 66 and following of the General Tax Law), conservation period of 6 years Art. 30 of the Commercial Code on accounting books and invoices), ( iii ) Data supplied on the occasion of subscribing to our newsletter: since the User gives your consent, until it withdraws, ( iv )Documentation of a labor nature or related to social security: 4 years Article 21 of Royal Legislative Decree 5/2000, of August 4, which approves the revised text of the Law on Violations and Sanctions in the Social Order, (v ) data provided by candidates by sending their C. Vitae: the C. Vitae may be kept for a maximum of two years for future selection processes unless the candidate states otherwise, (vi) Images obtained by video surveillance systems HEALTHUPPownership : 30 days , according to the instructions of the AEPD.

COMMUNICATION OF DATA: Your personal data may be communicated to:

Companies and entities and other organizations that have been contracted to provide services, such as: hosting, marketing services, market analysis and information society services.

Collaborating / sponsoring companies with which HEALTHUPP has reached a collaboration or sponsorship agreement.

Companies or other organizations to which you have requested or accepted that we can share your personal data.

The purpose of communicating the data to the companies above, which make up and are integrated with the person in charge, will be the same as those previously announced.

Professional service providers, such as lawyers, attorneys, arbitrators, notaries, registrars, or other similar professionals in certain cases.

Public bodies, courts, regulators and other administrative authorities, when we consider it necessary to comply with a legal or regulatory obligation, or in another way to protect us from claims against us or third parties, or the safety of people, as well as to prevent, or in any other way to fight, against fraud or for reasons of security or protection.

Any third party that purchases, or to whom we transfer, all or a substantial part of our assets and businesses. In the event of such a sale or transfer, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal data uses it in accordance with this Privacy Policy.

In such cases, we will ensure that your data is used for appropriate purposes in accordance with this Privacy Policy and the corresponding contracts or clauses for data processing (Standard Clauses) will be signed, applying the same or similar security measures to those that HEALTHUPPapplies.


As a general rule, before the processing of personal data, HEALTHUPP obtains express and unequivocal consent from the Owner of the same by incorporating informed consent clauses in the different information collection systems, and based on a legitimate interest of the User .

Notwithstanding the foregoing, the bases of legitimation are the following:

When the treatment is necessary for the execution of a contract to which it is a party or the data is necessary within the framework of a pre-contractual relationship.

When the use of your personal data is necessary for the satisfaction of our legitimate interests or those of the companies with which we have shared your personal data.

When the data processing is necessary to be able to comply with the legislation / regulations regulating the legal obligations of the sector, RGPD and LOPD-GDD legislation and similar applicable at all times, among which are the one relating to the placing in the market of products and services of HEALTHUPP (merchandising) or of third parties, defense of consumers and users, organization of retail trade, and other applicable regulations.

In accordance with the provisions of the applicable regulations on Information Society Services (LSSI), if there is a prior demonstrable relationship , the data may be used to send electronic commercial communications relating to that specific activity, unless opposed to this in the manner provided for this purpose.

When we consider that it is necessary to process your personal data to comply with a legal or regulatory obligation , or a vital interest.

When we have your consent, for example, to collect technical information such as cookie data and similar technologies as described in: “Information on the Use of Cookies”.

Acceptance of a contractual relationship in the environment of the corresponding social network, and in accordance with its Privacy policies in each case, when visiting any of our social profiles.


Right to withdraw the consent provided at any time.

Right of access and rectification of your data.

Right to erasure (right to be forgotten) of your data.

Right to limitation or opposition to your treatment.

Right to the portability of your data: understood as the power to receive your data in a structured format, of common use and mechanical reading, and to transmit it to another person in charge of the treatment (Art. 20 RGPD)

Right to file a claim with the control authority ( ) if you consider that the treatment does not comply with current regulations.

CONTACT DETAILS TO EXERCISE YOUR RIGHTS: HEALTHUPP, in application of Regulation (EU) 2016/679 of April 27, 2016 (GDPR), and recent LOPD-GDD 3/2018 of December 5, has a designated internal manager for Data Protection management and whose contact details are detailed below:

Email DPO :


The data collected by any of the contact forms enabled on this Website, or the data provided by the Users due to their participation in activities / events, application presentations, etc … developed by HEALTHUPP, will be incorporated, depending of its purpose, to the Registry of Internal Treatment Activities (Article 30 of Regulation (EU) 2016/679 of April 27, 2016). The Register of Treatment Activities is available to the Control Authority.

Users, by checking the corresponding boxes and entering data in the different fields, marked with an asterisk (*) in the contact forms or presented in paper forms, expressly and freely and unequivocally accept that their data They are necessary to meet your request, by HEALTHUPP, the inclusion of data in the remaining fields being voluntary. The User guarantees that the personal data provided is true and is responsible for communicating any changes to them.

HEALTHUPPinforms and expressly guarantees users that their personal data will not be transferred in any case to third parties and that, whenever they plan to make any transfer in the future, the express, informed and unequivocal consent of the Users will be requested in advance, informing about the data of the assignee, and the purpose of the assignment. All the data requested through the website are mandatory, as they are necessary for the provision of an optimal service to the User. In the event that all the data is not provided, it is not guaranteed that the information and services provided will be completely adjusted to your needs.


In accordance with the provisions of current regulations on personal data protection, and in particular in Regulation (EU) 2016/679 of April 27, 2016 and recent LOPD-GDD 3/2018 of December 5, HEALTHUPP is complying with all the provisions of the regulations for the treatment of personal data of its responsibility, and manifestly with the principles described, by which they are treated in a lawful, loyal and transparent manner in relation to the interested party and adequate, pertinent and limited to what necessary in relation to the purposes for which they are processed.

In any case, HEALTHUPP has implemented sufficient mechanisms to:

Guarantee the confidentiality, integrity, availability and permanent resilience of the treatment systems and services.

Restore availability and access to personal data quickly, in the event of a physical or technical incident.

Verify, evaluate and assess, on a regular basis, the effectiveness of the technical and organizational measures implemented to guarantee the security of the treatment.

Pseudonymize and encrypt personal data, if applicable.

HEALTHUPP guarantees that it has implemented appropriate technical and organizational policies to apply the security measures established by Regulation (EU) 2016/679 of April 27, 2016 and the recent LOPD-GDD 3/2018 of December 5 in order to protect the rights and freedoms of Users and has communicated the appropriate information so that they can exercise them. The company has installed all the technical means and measures at its disposal to prevent the loss, misuse, alteration, unauthorized access and theft of the Personal Data provided by the Owner to HEALTHUPP. However, the User must be aware that Internet security measures are not impregnable.

The personal data that is incorporated into the Registry of Internal Treatment Activities will be treated with the utmost confidentiality and security, the Owner of the indicated File may send you commercial information regarding our activities, present or future, in this case, the sender will You agree to indicate your advertising purpose when making the shipment, and to coordinate a simple, clear and free system in the event that you wish to stop receiving them.

The services of the HEALTHUPP website , the offer of its application in its different options and formats , etc …, contents on the web are intended exclusively for adults, in the case that HEALTHUPP offers any event, activity, or similar, in which the collection of Personal Data of minors may occur, HEALTHUPP will always request parental consent so that minors can access them and their Personal Data can be subject to automated treatment as provided in this notice about the Data Protection Policy.

As previously reported, the purpose of the collection and automated processing of Personal Data is to maintain the commercial relationship, where appropriate, established with HEALTHUPP, the management, administration, provision, expansion and improvement of the services of our website, or use the adaptation of said services to the preferences and tastes of the Users, the study of the use of the services by the Users, the sending of updates to the services, the sending, by traditional and electronic means, of commercial information about HEALTHUPP now and in the future.


HEALTHUPP has different profiles on different social networks, specifically:

ng to treat your personal data?

Answer your questions, requests or requests.

Manage the requested service, answer your request, or process your request.

Relate to you and in a community of followers.

What is the legitimacy for the processing of your data?

For more information about Facebook, click  here .

For more information on Twitter click  here .

For more information about Instagram, click  here .

For more information about YouTube click  here .

For more information about LinkedIn, click  here .

The acceptance of a contractual relationship in the environment of the corresponding social network, and in accordance with its Privacy policies:

Knowing HEALTHUPP in all cases responsible for the treatment of the data of its followers, fans, subscribers, commentators and other user profiles (hereinafter, followers). The treatment that HEALTHUPPwill carry out with said data will be, at most, the one that the social network allows to corporate profiles. Thus, HEALTHUPP may inform its followers by any means that the social network allows about its news and activities. In no case Healthupp will extract data from social networks, unless the user’s consent is specifically and expressly obtained to do so. When, due to the very nature of social networks, the effective exercise of the rights of the follower is subject to the modification of the personal profile of the latter, HEALTHUPP will help and advise to this end to the extent of its possibilities.


After the corresponding request, HEALTHUPP will notify you immediately in writing, in accordance with the applicable legislation, if we have stored your data and what they are. In the event that you are registered as a user, we offer you the possibility of personally consulting your data, and, where appropriate, proceed to delete, modify and update it.


Our Users of the Healthupp Application are informed that, in accordance with the RGPD and LOPD-GDD regulations applicable to the activity carried out by healthupp and health centers, the use of our tool will imply:

Prepare a record of treatment activities in accordance with article 30 of the RGPD.

Identify the legal bases of data processing, in accordance with articles 6 and 9 of the RGPD.

Inform those interested in relation to the processing of their data, in accordance with articles 13 and 14 of the RGPD. The Guide on patients and users of the Healthcare prepared by AEPD.

Address the rights of the interested parties, in relation to their rights of: access, rectification and deletion, limitation of treatment, data portability (article 20 of the RGPD), opposition and automated decisions.

Sign a treatment manager contract, in accordance with article 28 of the RGPD. Healthuppfacilitates the aforementioned process by making accessible: 1) document of compliance guarantees and details of the measures adopted, 2) model of the Healthuppmanager contract. For your convenience, and thinking of facilitating these procedures, both files can be downloaded from our website. To do this, click here .

Carry out a risk analysis and, where appropriate, an impact assessment; To facilitate compliance with these obligations, you can consult the AEPD website: -de-report-to-help-companies .

Report security breaches; It is up to the CLIENT to notify data security violations to the data protection authorities (article 33 of the RGPD) and to the subjects whose data has been compromised (article 34 of the RGPD). To this end, in the event of any incident that poses a risk to the rights and freedoms of those affected, HEALTHUPP will notify the CLIENT as soon as possible, and will assist them in making such notifications.

Appoint a data protection delegate, in accordance with articles 37, 38 and 39 of the RGPD, the CLIENT must appoint a data protection delegate and communicate their identity to the data protection authorities. In addition, the CLIENT must indicate to HEALTHUPP the contact details of said data protection officer.

For its part, HEALTHUPP, makes available to the CLIENTS / users, the following contact email for issues related to protection:

CONTACT : Please, if you have any questions about this Privacy Policy, get in touch with us through:

Email DPO :

In case you need any clarification about this Privacy Policy, wish to formulate any question or claim, or exercise of rights, please write to our Internal Data Protection Officer through the following email address: indicating in the subject: “Data Protection.