Privacy policy

Draft pending review by legal counsel. Last updated: October 2026.

1. Data controller

[Company name, address and VAT number: to be completed]. Privacy contact: [email protected].

2. Data we process

• Location: only when an event occurs (possible fall or SOS). Continuous location is off by default and needs a dedicated consent.
• Device sensor signals: summary values (e.g. acceleration peak, stillness) computed on the phone to decide whether a possible fall occurred. Raw sensor data is uploaded only with specific consent.
• Contacts: name, phone number and email of family members and contacts to alert, entered by whoever sets up the service.
• Consent records: which consent, text version, date, who gave it and how.
• Technical and account data: phone model, app version, battery status, periodic liveness signal (heartbeat), notification tokens, family members' email and hashed password.

Audio: Vigla does not record or store ambient audio. In a future phase, for the personalised keyword, training voice samples may be collected only with consent and deleted within 24 hours of training.

Some of this data (such as location during a possible emergency) may reveal health-related information: we process it only with your explicit consent.

3. Purposes and legal bases

• Detecting possible falls and alerting contacts: explicit consent (Art. 6(1)(a) and 9(2)(a) GDPR).
• Managing the account and providing the service: performance of a contract.
• Security, abuse prevention, legal obligations: legitimate interest and legal obligation.
• Measuring the effectiveness of the app's advertising campaigns, only if you agree: consent (Art. 6(1)(a) GDPR and Art. 122 of the Italian Privacy Code). See section 6.

4. Retention

When an account is deleted, personal data is erased or anonymised, except where the law requires otherwise.

5. Processors and recipients

• Twilio (SMS and voice calls)
• Firebase / Google (push notifications)
• Email delivery provider [to be named]
• Hosting on servers in the European Union [provider to be named]

In addition, only if you consent, the app shares some technical data with Meta Platforms Ireland Ltd., which processes it as an independent controller to measure advertising campaigns (see section 6).

A data processing agreement is in place with each of the providers listed above. Any transfer outside the European Economic Area relies on standard contractual clauses or other GDPR safeguards [to be verified].

6. Advertising campaign measurement (Meta SDK)

To understand how many installs come from our advertising campaigns on Facebook and Instagram, the Vigla app for Android and iOS includes the software development kit (SDK) of Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

• Only with your consent: on first launch the app asks whether you agree to advertising measurement. If you decline, the SDK is not started and sends nothing. On iPhone, after you consent, the system also asks for tracking permission (App Tracking Transparency): without it the advertising identifier is not shared.
• Purpose: only to attribute and measure installs coming from Meta campaigns. Only the automatic install and app-open events are sent; no custom events and no purchases.
• Data processed by Meta: the device advertising identifier (IDFA on iPhone if you granted tracking permission, Google Advertising ID on Android), technical device data (model, operating system, app version, language, time zone, IP address), date and time of install and app opens.
• No data about falls, health or location: Meta receives no sensor data, locations, alarm events, family contacts, or account name, email or phone number.
• Legal basis: consent (Art. 6(1)(a) GDPR and Art. 122 of the Italian Privacy Code for access to the identifier on the device).
• Withdrawal: from the app's "Privacy and data" screen (effective from the next app restart). On iPhone also via Settings → Privacy & Security → Tracking; on Android via Settings → Google → Ads, where you can reset or delete the advertising ID. Withdrawal does not affect prior processing.
• Transfers outside the EU: Meta may transfer data to the United States under the EU-US Data Privacy Framework and standard contractual clauses.
• Retention: according to Meta's policies.

For details see Meta's privacy policy.

7. Your rights

You may request access, rectification, erasure, restriction, portability and objection, and withdraw any consent at any time (also in the app) without affecting prior processing. Write to [email protected]. You also have the right to lodge a complaint with the Italian Data Protection Authority (garanteprivacy.it) or your national authority.

To delete your account and data see Delete account.

8. Security

Encrypted connections, hashed passwords, restricted access, encrypted backups in the EU.

9. Notice

Vigla is not a medical device and does not replace 112 or your local emergency number.