RinoMONITOR Privacy Policy

Version 2026-11-01 · Last updated: 2026-11-01

This is an English translation provided for convenience. The Spanish version is the legally binding version and prevails in case of discrepancy. Versión en español →

Summary in 30 seconds

  • Your camera image is processed in your browser. It is never recorded or sent to our servers.
  • We store your account data, any profile data you choose to enter, and aggregated metrics from each session.
  • Only you and the professional who invited you can see your individual data. The administrator sees only aggregated, anonymized statistics.
  • You can request access to, correction of, or deletion of your data by writing to facundo.atmek@gmail.com.
  • If you live in Spain or another European Union country, in Mexico, or in Colombia, an annex at the end of this Policy sets out your specific rights.

    • Contents

    1. Data controller

    2. What RinoMONITOR is

    3. What data we process

    4. What we use your data for

    5. Legal basis

    6. Who can see your data

    7. International transfers

    8. Security

    9. How long we keep your data

    10. Minors

    11. Your rights

    12. Browser permissions

    13. Cookies

    14. Changes to this Policy

    15. Contact

  • Annex A — Spain and the European Union
  • Annex B — Mexico
  • Annex C — Colombia

    • 1. Data controller

    The controller of the personal data processed through RinoMONITOR is Juan Facundo Couto Icasati, an individual, Argentine tax ID (CUIT) 20-25696841-0, domiciled at Otamendi 224, postal code C1405BRB, Autonomous City of Buenos Aires, Argentina ("RinoMONITOR", "we" or "us"). Contact: facundo.atmek@gmail.com.

    This Policy is governed by Argentine Personal Data Protection Law No. 25,326 and its Regulatory Decree No. 1558/2001. If you reside in Spain or another European Union country, in Mexico, or in Colombia, the rules set out in Annexes A, B and C also apply and prevail over this Policy to the extent they are more favorable to you.

    The RinoMONITOR database is registered with the National Database Registry of Argentina's Agency for Access to Public Information under No. EX-2026-106110857- -APN-DNPDP#AAIP.

    If ownership of the service is transferred to a company in the future, we will inform you as described in section 14.

    2. What RinoMONITOR is

    RinoMONITOR is a wellness web application. It uses your device's camera to alert you in real time when your mouth stays open or your neck and shoulders slump, so you can improve your breathing and posture habits.

    RinoMONITOR is not a medical device, does not diagnose or treat any condition, and does not replace consultation with a health professional.

    3. What data we process

    a) Camera image. Processed in real time exclusively within your browser using computer vision. Video frames are not recorded, stored, or sent to our servers or to third parties.

    b) Account data. Your email address (for sign-in), a pseudonym (a made-up name or an alphanumeric code) instead of your real name, and your role (user, professional, or administrator). For users, also the professional who invited them.

    The pseudonym reduces the exposure of your identity, but it does not make your data anonymous: the professional who invited you may know who you are outside the platform, and your email remains linked to your account. We therefore continue to treat this data as personal data.

    c) Profile data. Sex, age, weight, and height, from which we automatically calculate your Body Mass Index (BMI). This data is optional. The professional may pre-fill it when sending the invitation, and you can edit or delete it at any time from your profile.

    d) Session metrics. Each time you end a monitoring session while signed in, we store aggregated metrics for that session: date, duration, and the time and number of breathing and posture alerts. If you entered weight and height, we also store the values current at that time to keep their history.

    e) Consent record. When you accept this Policy we store the date, the version accepted, your IP address, and your browser data (user agent) as proof of your consent.

    f) Technical data. We use strictly necessary session cookies to keep you signed in. Our infrastructure providers generate technical operation and security logs.

    g) Analytics. In production we use Vercel Web Analytics to obtain aggregated visit statistics, without advertising tracking cookies.

    h) Test mode. Test mode requires signing in with a Google account. When you do so, Google shares your your name, email address, and profile picture with us. Test mode does not store monitoring session data. Each access generates an email notification to the platform administrator that includes your email address and the date and time of access, for security and usage-control purposes.

    Sensitive data. Profile data and breathing and posture metrics may be considered health-related data, that is, *sensitive data* under Article 2 of Law 25,326. We process it only with your express consent. No one is required to provide sensitive data: profile data is optional.

    4. What we use your data for

  • To provide the monitoring service and show you your statistics and usage history.
  • To allow the professional who invited you to see your usage consistency and history.
  • To authenticate you through sign-in links sent by email and to manage invitations and reports.
  • To protect the security of the service and prevent misuse.
  • To produce aggregated, anonymized statistics to improve the service and for research on breathing and posture habits. We only produce statistics for groups of at least 20 people and never publish or share individual data. This purpose is voluntary: you can object by writing to facundo.atmek@gmail.com without losing access to the service.

    • We do not sell your data, do not use it for advertising, and do not share it for commercial purposes.

    The app's alerts are automated, indicative feedback. They are not decisions with legal effects on you and do not produce similarly significant effects.

    5. Legal basis

    We process your data with your free, express, and informed consent, which is recorded when you accept this Policy within the application. You may withdraw it at any time (section 11), without retroactive effect. If you reside in the European Union, Annex A details the legal basis for each purpose.

    6. Who can see your data

  • You, from your profile and statistics.
  • The professional who invited you. They see your pseudonym, profile data, BMI, and statistics, and may export them to a spreadsheet (Excel or Google Sheets in their own Google account). From that export onward, the copy is the professional's responsibility and, where applicable, subject to Google's policies.
  • The platform administrator. Sees aggregated, anonymized statistics, the list of professionals, and the number of users each one has. Does not see any user's individual data.
  • Our providers, which process data only on our behalf and to provide the service:

    • - Vercel (application hosting and analytics);

    - Neon (database);

    - Resend (email delivery);

    - Google (test-mode authentication and Google Sheets export if a professional uses it).

  • Competent authorities, when required by law or court order.

    • 7. International transfers

    Our providers may store and process data on servers located outside Argentina, mainly in the United States. By accepting this Policy you give your express consent to that international transfer under Article 12 of Law 25,326. We choose providers that apply recognized security measures. If you reside in the European Union, Annex A details the applicable safeguards.

    8. Security

    We apply reasonable technical and organizational measures:

  • invitation-only access;
  • passwordless sign-in through links that expire after 15 minutes;
  • server-side role-based permission control;
  • encrypted connections;
  • video never leaves your device.

    • No system is completely invulnerable. If a security incident occurs that may affect your rights, we will inform you without undue delay, stating what happened, which data may be affected, and what measures we took. Where applicable law requires, we will also notify the competent supervisory authority within the legal deadlines.

    9. How long we keep your data

    We keep your data while your account is active. If you request account deletion, we will delete or anonymize your data within 30 calendar days, except data we must retain by legal obligation. Your consent record is kept only for as long as needed to prove it. Statistics that are already anonymized do not identify you and may be retained.

    10. Minors

    People under 18 (or under the age of majority in their country, if higher) may only use RinoMONITOR with the authorization and supervision of their parent or legal guardian. In that case:

  • the invitation is sent to the responsible adult's email;
  • the responsible adult accepts this Policy and the Terms on the minor's behalf;
  • the responsible adult exercises the rights in section 11;
  • a professional inviting a minor must first obtain the responsible adult's consent;
  • we recommend that minors' monitoring sessions take place under adult supervision.

    • If we detect a minor's data entered without that consent, we will delete it.

    11. Your rights

    You have the right to:

  • access your data;
  • rectify and update it;
  • request its deletion;
  • withdraw your consent;
  • object to the use of your data for research statistics.

    • To exercise these rights, write to facundo.atmek@gmail.com from the email linked to your account.

  • We respond to access requests within 10 calendar days.
  • We respond to rectification, update, or deletion requests within 5 business days, under Articles 14 and 16 of Law 25,326.

    • Data subjects may exercise their right of access free of charge at intervals of no less than six months, unless a legitimate interest is shown, as established in Article 14, paragraph 3 of Law No. 25,326.

    Argentina's AGENCY FOR ACCESS TO PUBLIC INFORMATION, as the Supervisory Authority under Law No. 25,326, is empowered to handle complaints and claims filed by those whose rights are affected by non-compliance with personal data protection rules.

    If you reside outside Argentina, you may also exercise the rights granted by the laws of your country (see Annexes).

    12. Browser permissions

  • Camera. Required for monitoring. You can revoke the permission at any time in your browser settings.
  • Notifications, sound, vibration, and Picture-in-Picture. Optional, and used only to alert you when the app detects an open mouth or poor posture while the tab is in the background.

    • 13. Cookies

    We only use cookies that are strictly necessary to start and maintain your session. We do not use advertising cookies or third-party tracking cookies.

    14. Changes to this Policy

    We may update this Policy. Each version is identified by its date. If a change is substantial or adds a new purpose, the application will ask you to accept the new version before you continue using it.

    15. Contact

    For any question about this Policy or your data: facundo.atmek@gmail.com.

    Annex A — Users in Spain and the European Union

    In addition to this Policy, Regulation (EU) 2016/679 (GDPR) applies and, in Spain, Organic Law 3/2018 on Personal Data Protection and Guarantee of Digital Rights (LOPDGDD).

    Legal bases.

  • Account data: performance of the service-use contract (Art. 6(1)(b) GDPR).
  • Profile data and breathing and posture metrics (health-related data): your explicit consent (Art. 9(2)(a) GDPR).
  • Consent record and technical security data: legitimate interest in proving consent and protecting the service (Art. 6(1)(f) GDPR).
  • Aggregated statistics for research: your consent, which you may withdraw at any time.

    • Your rights. Access, rectification, erasure, restriction of processing, data portability, objection, and withdrawal of consent at any time, without affecting the lawfulness of prior processing. We respond within one month of receiving your request. You may also lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) or with the supervisory authority of your country of residence.

    EU representative. Under Article 27 GDPR, our representative in the EU is JFCI 49466526N.

    International transfers. The European Commission recognizes Argentina as providing an adequate level of protection.

    Transfers to providers in the United States are made to providers certified under the EU-U.S. Data Privacy Framework.

    Transfers to providers in the United States are covered by standard contractual clauses approved by the European Commission.

    Minors. In Spain, the law allows people aged 14 and over to consent to the processing of their data themselves. RinoMONITOR applies a stricter standard: authorization from a parent or legal guardian is required until age 18 (section 10).

    Incidents. If a security incident poses a risk to your rights, we will notify the supervisory authority within 72 hours of becoming aware of it, and you when the risk is high.

    Annex B — Users in Mexico (Comprehensive Privacy Notice)

    The Federal Law on the Protection of Personal Data Held by Private Parties (2025) applies.

    Controller. Juan Facundo Couto Icasati, domiciled at Otamendi 224, postal code C1405BRB, Autonomous City of Buenos Aires, Argentina. Contact: facundo.atmek@gmail.com.

    Data we process. Identification and contact data: email and pseudonym. Sensitive personal data: profile data (sex, age, weight, and height, if you enter them) and breathing and posture metrics, as they relate to your health.

    Necessary purposes (without them we cannot provide the service): providing the monitoring service; showing you your statistics; allowing the professional who invited you to see your usage consistency and history; authenticating you; protecting the security of the service.

    Voluntary purposes (you may refuse without losing the service): producing aggregated, anonymized statistics for research. To object, write to facundo.atmek@gmail.com.

    Consent for sensitive data. We process your sensitive data only with your express written consent, which you give by accepting within the application after authenticating with the link sent to your email.

    ARCO rights and withdrawal. You may access, rectify, cancel, or object to the processing of your data, withdraw your consent, and limit its use or disclosure by writing to facundo.atmek@gmail.com from your account email, stating the right you wish to exercise and the data involved. We will respond within the deadlines set by law.

    Processors and location. Your data is hosted by providers located mainly in the United States, which act as processors on our behalf (section 6).

    Changes. We will inform you of any change to this notice within the application. If a new purpose is added, we will ask for your consent again.

    Annex C — Users in Colombia

    Law 1581 of 2012 and its regulatory decrees apply.

    Controller and contact point. Juan Facundo Couto Icasati. Inquiries and complaints: facundo.atmek@gmail.com.

    Sensitive data. Profile data and breathing and posture metrics are sensitive data. You are not required to authorize their processing or to answer questions about them. Their processing requires your prior, express, and informed authorization.

    Your rights. To know, update, and rectify your data; to request proof of the authorization granted; to be informed about the use of your data; to file complaints with the Superintendence of Industry and Commerce; to revoke the authorization or request deletion of your data; and to access it free of charge.

    Deadlines. We handle inquiries within 10 business days and complaints within 15 business days of receipt.

    Minors. Processing the data of children and adolescents requires authorization from their legal representative and respects their best interests.

    See also: Terms of Use