Privacy Policy

Last version: 21st October, 2020


Para una versión reducida en español con lenguaje sencillo sobre GDPR, lee

Hearts Radiant SL. (‘We’ or ‘Rosita’ or ‘Hola Rosita’) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our Website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

In this Privacy Policy, we explain how we collect and use your personal information. ‘We’ are Hola Rosita, and we are the data controller for the purposes of the EU General Data Protection Regulation.

Details of how to contact us if you have any questions about privacy or data protection can be found in the Contact Details section, below.

This policy explains what our lawful basis is in respect of each purpose for which we keep and use information about you. Generally, we are allowed to process your personal data where it is necessary by accessing our Website located at a domain or subdomain owned by us, using our products and services through the Website or our mobile applications, or otherwise providing us with Personal Information, where it is necessary in order for us to provide our service, to comply with our legal obligations, or where we have a legitimate interest to do so (but we will always consider whether your right to privacy overrides our interest).

Accessing to our Website, you confirm that you have read and accept the terms of this Privacy Policy and expressly consent to the collection, storage, use and disclosure of your Personal Information in accordance with the terms of this Privacy Policy.

If you do not agree to the terms of this Privacy Policy you must immediately leave the Website and discontinue your use of our products and services.

How do We use your personal information?

Rosita exists to help our seniors live a more fulfilling and engaging ageing process, creating healthy habits with physical, mental and social activities. This process requires data in order to be more personalized, relevant and contextual, and to provide the right activities and monitoring that help in such ageing process.

In application of the aforementioned regulations and commitment, Rosita and its members treat the data strictly necessary to satisfy their legitimate purposes:

  • The creation of a senior profile that aims to understand behavior and habits in order to provide more accurate and contextual activities and continue to improve our offering
  • The ability for the senior to decide and proactively share relevant information with other parties, including connected loved ones or institutions to which he/she is subscribed (e.g. local townhall) for their direct benefit (online caretaking, health monitoring, etc).
  • The anonymized aggregation of data to show our seniors where they stand in their health indicators (like frailty and others) compared to other seniors their age

How do We collect your personal information?

Your personal data is obtained:

  • From the users themselves through the Rosita app and forms.
  • Through phone calls that Rosita's team might make to our customers to complement information that might be difficult for the senior to complete online
  • Through the phone activity, from permissions provided to the Rosita app for the sole purpose of safety and monitoring.
  • Quantitatively through the use of the product itself

Personal information We collect and treat

What Personal Data type we can collect:

  • Identifying data, specifically phone, name and address, to help connect with other entities as requested.
  • General wellbeing information, like age, weight and habits
  • Subscription and participation in activities in the Rosita app
  • Friends list, in order to help our seniors create social activities

You can download all the data we hold about you on our Website, as specified below in this document.

Why we may collect data includes:

  • To provide more contextual and intelligent activities for healthy habits:
    • based on information you provide directly
    • based on information you provide to third parties, like institutions and associations
  • To provide a better user experience:
    • To understand better what parts of the Rosita services work for our customers and not, so that we can improve our offering
  • To connect with other parties:
    • To provide interactive information the activity creators (hosts), including associations and institutions the senior subscribes to
    • To provide monitoring information to the primary caretaker (selected by the senior upon sginup)

We collect Personal Information so that we can carry out our business activities in a professional and efficient manner, in particular to:

  • Most importantly, provide a relevant service
  • Provide support services in respect of your Rosita account and Rosita app services.
  • Communicate with you, including regular checkups with our specialists.
  • Comply with local legal obligations;
  • Calculate anonymous, aggregate statistics, for product development and analytics purposes including for sharing with third parties on an anonymous and aggregated basis;
  • Manage complaints and disputes.

Rosita Commitments

Your data is yours. We will not kidnap your data or make it difficult for you to use it elsewhere.

  • We undertake to update the data processed, as soon as possible, in case of the deficiency or mistakes, as well as the secrecy and confidentiality of the information involved, not assuming in any way the possible damages arising from the falsity of the information provided by the interested users or parties.
  • In application of the principle of transparency and information, will inform clearly and accurately to the interested parties, at the time of the collection of the data or later as the case may be, of the circumstances of treatment established in the EU General Data Protection Regulation, or particular European Country Law applies.
  • We will not treat minors' data or special categories of data referring to ideology, religion, ethnic or racial origin, sexual orientation or criminal infractions.
  • We will not sell or transfer personal data to third parties, outside of those cases authorized by the Law relating to the fulfilment of the obligations with the Social Security, the Treasury and other public entities, as well as the assignments or communications to collaborating entities that request their services.
  • The realization, where appropriate, of international data transfer to third countries will be done in accordance with the Law, prior to the consent of the interested party, adequacy established, where appropriate by the Spanish Agency for Data Protection or compliance with the requirements established in the agreement between the US and the EU on the privacy shield. These transfers will be carried out to fulfil information storage purposes. The contracts with third parties for the management of personal data comply with the provisions of the EU General Data Protection Regulation, or particular European Country Law applies. We, verify the professionalism and preparation of said managers and including clauses in accordance with the Law in the corresponding contracts.
  • We undertake to respect the exercise by the interested parties of the rights recognized by the EU General Data Protection Regulation, or particular European Country Law applies, to which it authorizes internal forms and procedures that facilitate said exercise to the interested parties.
  • To facilitate the proper application of the above commitments, We committed to all procedures, resources, tools, applications and others that are intended or carry out the processing of personal data, are designed and implemented from a perspective of full respect to the regulations and principles of data protection. In this sense, in those cases in which there are several applicable options, We will apply the most respectful with those.
  • In addition, We committed to implement all security, technical and organizational measures that are necessary to ensure the protection of personal data they treat and the privacy of their owners. These measures will be adapted to the level of risk anticipated, to the nature of the data and the treatments that are carried out and their purpose.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis for us to do so.

Who do we share your personal information with?

Sharing your information within our company

The raw information that builds your reputation score is private. We might share your profile with our staff when it might be required for the purpose of customer service or providing services to you.

Sharing your information with third parties

We may share your data with selected third parties. For example, we may share your information with:

  • Internet hosting providers to host the Website, related infrastructure, services and applications. A detailed list of providers can be found at
    Cookies and 3rd parties we use
  • To the institutions you are subscribed to, only when you provide the permission to do so (because you benefit directly from it, for example, to connect you with your townhall).
  • With your primary caretaker or loved one, as selected by you upon signup or modified later.

There are certain exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:

  • Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings.
  • Necessary to protect the safety of our employees, our property or the public.
  • Proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved.

How long do We keep your personal information?

We will only store your personal information for as long as we need it for the purposes for which it was collected. Where we provide you with any service, we will retain any information you provide to us at least for as long as we continue to provide that service to you.

If there is a contract or information has been provided, the personal data will be kept for a period of five (5) years from its formalization, to guarantee the existence of a probative document during the period of prescription of debts. This term will be extended until the term of existence and claim of the debt ends, in the event that it has been interrupted.

In all other circumstances, we will keep your information until you have exhausted any funds on your account, all claims and legal disputes have been settled, there is no direct risk of fraudulent activity from erasing the data and that your account can be determined to be permanently dormant.

What rights do you have in respect of your personal information?

You have the right to be informed

We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to do just that, but if you have any questions or require more specific information, you can get in touch using Contact Us section of the Website.

You have the right to access your personal data

You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:

  • Why we have been using your information
  • What categories of information we were using
  • Who we have shared the information with
  • How long we envisage holding your information

In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold.

The first copy of your information that you request from us will be provided free of charge. If you require further copies, we may charge an administrative fee to cover our costs.

If you need to download or delete your data, please email data@holarosita.com or call us

You have the right to correct any inaccurate or incomplete personal data

Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case, you can contact us so that we can correct our records.

You have the right to be forgotten

There may be times where it is no longer necessary for us to hold personal information about you. This could be if:

  • The information is no longer needed for the original purpose that we collected it for
  • You withdraw your consent for us to use the information (and we have no other legal reason to keep using it)
  • You object to us using your information and we have no overriding reason to keep using it
  • We have used your information unlawfully
  • We are subject to a legal requirement to delete your information

In those situations, you have the right to have your personal data deleted. If you believe one of these situations applies to you, please get in touch using our Website.

You have the right to have a copy of your data transferred to you or a third party in a compatible format

Also known as data portability, you have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy or transfer your personal data more easily from one IT system to another, in a safe and secure way.

If you would like us to transfer a copy of your data to you or another organisation in a structured, commonly use and machine-readable format, please contact us. There is no charge for you exercising this right.

You have the right to object to direct marketing

You can tell us at any time that you would prefer that we do not use your information for direct marketing purposes. If you would not like to receive any direct marketing from us, please contact us or use the links provided in any of our marketing communications, and we will stop sending direct marketing immediately.

You have the right to object to us using your information for our own legitimate interests

Sometimes, we use your personal information to achieve goals that will help us as well as you. This includes:

  • When we tell you about products or services that are similar to ones that you have already bought
  • When we use your information to help us make our business better
  • When we contact you to interact, communicate or let you know about changes we are making

We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal data for these purposes.

In order to exercise your right to object to our use of your data for the purposes above, please contact us.

You have the right to restrict how we use your personal data

You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:

  • You have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this
  • You have objected to us using your information for our own legitimate interests and we are in the process of considering your objection
  • We have used your information in an unlawful way, but you do not want us to delete your data
  • We no longer need to use the information, but you need it for a legal claim

If you believe any of these situations apply, please contact us.

You have rights related to automated-decision making and profiling

Any automated decision-making or profiling we undertake is solely for the purpose of tailoring the information which we provide to you. We will not use automated decision-making or profiling to make any decisions which will have a legal effect upon you or otherwise significantly affect you, and you have the right not to be subject to such decisions. If you have any concerns or questions about this right, please contact us.

Use of Cookies

On occasion, we may gather information about your computer for our services and to provide statistical information regarding the use of our Website.

Such information is statistical data about our visitors and their use of our site.

We may gather information about your general internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer as cookies contain information that is transferred to your computer's hard drive. They help us to improve our Website and the service that we provide to you.

Everything is described in detail in our


Changes to our Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

This version was last updated on 23/04/2020 and historic versions can be obtained by contacting us.


If you wish to make a complaint about our collection or use of your personal data, please contact us so that we may seek to resolve your complaint.

You have the right to lodge a complaint with the Spain Information Commissioner: Agencia Española de Protección de Datos.

Contact Details

Our Data Protection Officer is Juan Cartagena, who can be contacted at the address below.

Post: Balneario, Cofrentes, 46625, Spain

Email: privacy@holarosita.com

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