Privacy Policy

VisionApp Solutions SL privacy policy Last update: 07/15/2020

What does this privacy policy cover? 

VisionApp respects your privacy and is committed to protecting your personal data. We want to be transparent with you about the way we collect and use your Personal Data by making our (i) website ( and all its subdomains, and all other websites that are available to you owned, operated or maintained, directly or indirectly, by VisionApp and its affiliated companies, (ii) mobile applications, (iii) online mobile application management platform (collectively, the "VisionApp Sites") and inform you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

This Privacy Policy is intended to provide information on how VisionApp collects and processes your Personal Data through the use of the VisionApp Sites, including any data you may provide through the VisionApp Sites.

The Privacy Policy aims to fulfill our Transparency duties under the "General Data Protection Regulation" or "GDPR". We will post any modification or change to this privacy policy on this page.

Who we are

VisionApp, Inc., is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as "VisionApp", "we", "us" or "our" in this Privacy Policy).

Our address is: VisionApp, Avenida Juan Carlos I, 53 - BJ, Águilas, 30880, Murcia, Spain.

How to contact us

You can get in touch by sending an email to :: [email protected].    

You can contact our representative in the EU by sending an email to the following address: [email protected].

The rights you have in relation to Personal Data

By law, you have the right to:

How to exercise your rights:

If you want to exercise any of the rights described above, please contact us through the contact details shown above.

Normally, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, in certain circumstances we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or we may refuse to comply with your request in these circumstances.

We may need to ask you for specific information to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to anyone who is not entitled to receive it. We may also contact you to ask for more information regarding your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us more than a month if your request is particularly complex or if you have made several requests. In this case, we will notify you and keep you informed.

Complaints / Claims

If you wish to file a complaint regarding this Privacy Policy or our practices regarding your Personal Data, please contact us at: [email protected].

We will respond to your complaint as soon as we can.

If you believe that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact the local supervisory authority for data protection.

Marketing communications preferences

You can ask us to stop sending you marketing messages at any time by:

When you choose not to receive these marketing messages, this option will not apply to communications related to the service (and to any processing of your Personal Data that involves sending such communications). As an example, these service-related communications may include: emails that we may have to send you in connection with managing your account on the VisionApp Sites, your use of the VisionApp Sites, updates to this Privacy Policy , etc.

What personal data we collect

All the personal data that we collect, both from you and from third parties about you, are described in the following table.

Before reading this table, it may be helpful to explain what "Personal Data" is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is directly identified or can be identified.  

It does not include "anonymous data" (that is, information that does not relate to an identified or identifiable person) or "anonymous data" (that is, previously identifiable information in which the person's identity has been permanently removed).

However, it does include "indirect identifiers" or "pseudonymous data" (that is, information that does not by itself identify an individual but that, when combined with some additional and reasonably accessible information, could be attributed to a particular person) .                                                        

Category of personal data collected

What this means

Identity data

Your first name, last name, middle name, username or a similar identifier

Contact details

Your email address and telephone numbers.

Profile data

Your username and password, preferences and comments linked to your account on VisionApp sites.

Image data

The images, videos, graphics and other content that you upload to the VisionApp Sites for certification and authentication and any metadata attached to or related to such content (including the creator, date, time, device and location of where that content was captured, along with certain contextual media related to that content. When we refer to "contextual media" related to content, as some examples of what this means, we can capture: multiple frames before and after Have your image taken using VisionApp applications to help determine camera device movement, as well as ambient light sensor and barometric pressure

information Transaction Data

Any details about payments to and from you and others details of the subscriptions and services you have purchased

from us Marketing and communications details

Your preferences at the reception marketing information from us and our third parties and your communication preferences.

Technical data

Internet protocol (IP) address, your login data, browser type and version, time zone location and configuration, types and versions of browser plugins, operating system and platform and other technologies of the devices you use to access the VisionApp Sites or use our services.

Aggregated Data

We also collect, use and share "Aggregated Data" as statistical or demographic data for any purpose. The Aggregated Data may be derived from your Personal Data, but once in aggregate form they will not constitute Personal Data for the purposes of the GDPR since these data do not directly or indirectly reveal your identity. For example, we may add certain Technical Data and Behavioral Data to calculate the percentage of users accessing a specific feature of the VisionApp Sites. However, if we combine or connect the Aggregated Data with your Personal Data so that they can identify you directly or indirectly, we treat the combined data as Personal Data to be used in accordance with this Privacy Policy.

We do not collect any "Special Category of Personal Data" about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, union membership, health information. and genetic and biometric data). We also do not collect information on convictions and criminal offenses.

Why do we need access to the camera?

We do not save any photos taken with the camera, we only use the camera to measure the distance. In order for the device to be safe for the eyes, we need to measure the distance and help users to increase the distance when conditions and habits make it risky for the eyes. Other than your name and the profile photo you select, we only upload metrics that will help with eye care habits.

How we use your personal data and why

We will only use your Personal Data for the purposes for which we have collected it (as indicated in the table below), unless we reasonably consider that we need to use it for another reason and that reason is consistent with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and explain the legal basis that allows us to do so.

What is our "legal basis" for the processing of your personal data?

Regarding each of the purposes for which we use your personal data, the GDPR requires us to ensure that we have a "legal basis" for that use. The most common is that we rely on one of the following legal bases:  

We generally do not rely on your consent as the legal basis for using your personal data.

Below we have established, in the form of a table, the legal bases on which we base ourselves with respect to the relevant purposes for which we use your Personal Data.                                                                      


Category (s) of personal data involved

Why do we do this?

Our legal basis for this use of data

Account creation and maintenance


data Profile

data Contact data

To register as a new customer and maintain your account on VisionApp sites Contractual


Provision of services


data Profile

data Data Image


information Technical data

To provide you with the services and functionalities of the VisionApp sites, including:

- authenticating and storing the creator, the date, the time, the device and the location of the place where the content that is uploaded is captured. VisionApp sites, as well as other information that allows us to verify an image; and

- make the Image Data associated with the content uploaded to the VisionApp Sites available to the public through a URL that can be shared and accessed by third parties that you share

Contractual need

Payment processing


data Contact data

Transaction Data

To process and manage the payments, fees and charges for any subscription you may acquire to the VisionApp Sites (or any paid portion thereof)

Contractual need

Fraud prevention


data Contact

data Technical data

To maintain the sites VisionApp, our services and associated operating systems and insurance

Legitimate interests.

We have a legitimate interest in ensuring the continued security and proper functioning of our services, VisionApp sites and associated IT services and networks.


Technical data

To track down problems that may be occurring on our systems

Legitimate interests.

It is in our legitimate interest that we can monitor and ensure the proper functioning of the VisionApp Sites and associated systems and services



data Contact

data Marketing and communications data

To form an opinion on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant to you.

Legitimate interests.

We have a legitimate interest in providing you with updates to VisionApp sites and related offers where you have purchased or shown interest in similar services from us

What happens when you do not provide the necessary personal data?

In cases where we need to process your Personal Data, either to comply with the law or to comply with the terms of a contract that we have with you and you do not provide such data when requested, we may not be able to comply with the contract we have or are trying to enter into with you (for example, to provide you with the functionality of the VisionApp Sites).

In this case, we may need to stop using the VisionApp Sites that you have with us, but we will notify you if this is the case at that time.

Personal Data from Third Party Sources

In addition to the Personal Data we collect directly from you (as described in the section immediately preceding this one), we also collect some of your Personal Data from third party sources. These sources are broken down in the following table, along with a description of whether they are publicly available or not.                          

Third Party Data Source

Available to the Public?

Category (s) or other types of personal data received

Social media sites



data Contact data  

How we use cookies and other tracking or profiling technologies

We may collect information using "cookies". Cookies are small data files that a website stores on the hard drive of your computer or mobile device. We may use both session cookies (which expire after you close your web browser) and persistent cookies (which remain on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on the VisionApp Sites.

We use two broad categories of cookies:

The cookies we use

The VisionApp sites use the following types of cookies for the purposes indicated below:                                          

Type of Cookie


Essential Cookies

These cookies are essential to provide you with the services available through the VisionApp Sites and to enable you to use some of their features. For example, they allow you to enter secure areas of the VisionApp Sites and help the content of the pages you request load quickly. Without these cookies, the services you have requested cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow VisionApp Sites to remember the choices you make when using VisionApp Sites, such as remembering your language preferences, remembering your login details, and remembering changes you make elsewhere in the VisionApp sites that you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid having to re-enter your preferences each time you visit the VisionApp Sites.

Analysis and performance

cookies These cookies are used to collect information about the traffic of VisionApp sites and about how users use VisionApp sites. The information collected through these cookies does not "directly" identify any individual visitor. However, you can make such visitors "indirectly identifiable". This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the VisionApp Sites. The information collected is aggregated - includes the number of visitors to the VisionApp Sites, the Web sites that referred them to the VisionApp Sites, the pages they visited on the VisionApp Sites, the time of day they visited the VisionApp Sites , if you have visited the VisionApp Sites before, and other similar information. We use this information to help operate the VisionApp Sites more efficiently, to gather broad demographic information, and to monitor the level of activity on the VisionApp Sites.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve the functioning of VisionApp sites. You can find more information about Google Analytics cookies here:

You can find more information about how Google protects your data here:

Social media cookies

These cookies are used when you share information using a social media share button or a "like" button on VisionApp sites or when you link your account or commit to our content on or through a website from social networks like Facebook, Twitter or Google. The social network will record that you have done this.

Deactivating cookies

Normally, you can delete or reject cookies through your browser settings. To do this, follow the instructions provided by your browser (usually located within the "settings", "help", "tools" or "editing" options). Many browsers are configured to accept cookies until you change the settings.  

If you do not accept our cookies, you may experience some inconvenience in using the VisionApp Sites. For example, we may not be able to recognize your computer or mobile device and you may have to log in each time you visit the VisionApp Sites.

For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit and

You can also prevent the use of Google Analytics in connection with the use of the VisionApp Sites by downloading and installing the browser plug-in available through this link:

With whom we share your personal data