I. Introduction
In compliance with applicable legislation, WOSLER, operating under the legal name SMART HEALTH DIGITAL APP S.L., undertakes to implement the necessary technical and organizational measures appropriate to the level of risk associated with the personal data collected.

Laws incorporated into this Privacy Policy:
This policy is adapted to current Spanish and European regulations on personal data protection, including:

• Regulation (EU) 2016/679 (GDPR)

• Organic Law 3/2018 (LOPD-GDD)

• Royal Decree 1720/2007 (RDLOPD)

• Law 34/2002 (LSSI-CE)

Identity of the data controller:
The data controller is SMART HEALTH DIGITAL APP S.L., with VAT ID: B67918151 and registered office in Granada, Spain.
For any inquiries, you may contact:
📧 hello@wosler.es

II. Personal Data Registration
The personal data provided by users when completing forms on the website (such as name, email, and phone number), as well as data entered during the service purchase process (via Stripe), will be collected and processed for the following purposes:

• To facilitate, manage, and fulfill the commitments between WOSLER and the user

• To provide digital medical assistance

• To issue invoices

• To respond to inquiries or requests

• To send operational communications related to the service

III. Principles applicable to the processing of personal data

• Lawfulness, fairness, and transparency

• Purpose limitation

• Data minimization

• Accuracy

• Storage limitation

• Integrity and confidentiality

• Proactive responsibility

IV. Categories of personal data
WOSLER only processes identifying data (name, email, phone number, country of residence).
If the service is contracted, billing data will also be processed.
No special categories of personal data, as defined in Article 9 of the GDPR, are processed.
Medical data is managed solely by the independent healthcare professional and is not stored on the website.

V. Legal basis for processing personal data

• Explicit consent of the user

• Execution of a contract

• Compliance with legal obligations

• Legitimate interest in improving the service

VI. Purposes of the processing

• To manage the digital medical assistance service purchased

• To issue tax documentation (invoices)

• To respond to user communications

• To anonymously analyze website usage in order to improve functionality

VII. Data retention period
Personal data will be retained for a maximum of 24 months, or until the user requests its deletion.
Data related to payments and invoicing will be retained for the periods required by Spanish tax regulations.

VIII. Recipients of personal data
Personal data will not be shared with third parties, except in the following cases:

• Stripe, Inc., for payment processing (based in the USA, under standard contractual clauses)

• Independent healthcare professionals, if the service is contracted

• Public authorities, when legally required

• Technical providers under confidentiality agreements (servers, forms, cookies)

IX. Personal data of minors
Only individuals over the age of 14 may give valid consent for the processing of their personal data.
For minors under this age, authorization from parents or legal guardians is required.

X. Confidentiality and security of personal data
WOSLER is committed to ensuring the security and confidentiality of personal data through appropriate technical measures.
In the event of a data breach that poses a high risk to users’ rights, users will be notified without delay.

XI. User rights
Users may exercise the following rights at any time:

• Access, rectification, erasure

• Objection or restriction of processing

• Data portability

• Withdrawal of consent

• Filing a complaint with the Spanish Data Protection Agency (www.aepd.es)

To do so, you may write to: hello@wosler.es

XII. Acceptance and changes
Use of this website implies acceptance of this policy.
WOSLER reserves the right to modify this policy in order to adapt to legislative or operational changes.
Users are encouraged to review it periodically.