1. Data controller
Fundació Institut Guttmann (Institut Guttmann), Tax ID G08519100, Camí de Can Ruti, s/n, 08916 Badalona (Barcelona), Spain.
- App support: bbhi@guttmann.com
- Data Protection Officer: jremacha@guttmann.com and institutional channel protecciodades@guttmann.com
- Telephone: +34 93 497 77 00
2. Scope and purpose
This policy applies to the Progressive Web App named PrecisePrevent Coaching App, available at
preciseprevent.guttmann.tech. The app supports a personalised multimodal digital intervention promoting brain-health-related habits.
The app is not publicly available. It may only be used by selected participants who have received the study information, meet the eligibility criteria and provided the required informed consent.
3. Data we process
| Category | Examples and source | Purpose |
|---|---|---|
| Identification and study management | Participant code, centre, allocated arm, visits, eligibility, consent, follow-up and withdrawal. | Manage and document the study. |
| Demographic and health data | Age, sex, education level, relevant history, eligibility criteria and adverse events. | Safety, follow-up and research. |
| Questionnaires | Lifestyle, nutrition, physical activity, sleep, socialisation and psychological well-being. | Intervention and scientific analysis. |
| Google Health | Raw and derived data relating to steps, distance, calories, activity minutes and sleep duration, timing and stages. | Personalised follow-up and authorised study analyses. |
4. Google Health access
Connecting Google Health is voluntary and requires specific OAuth authorisation. We request only the read-only scopesgooglehealth.activity_and_fitness.readonlyandgooglehealth.sleep.readonly. The app does not write, modify or delete Google Health data.
5. Legal grounds
Processing is carried out under the EU General Data Protection Regulation, Spanish Organic Law 3/2018 and applicable health-research law.
6. Recipients
Access may be granted, strictly as needed, to authorised Institut Guttmann research, technical and data-management staff and authorised project partners.
7. Hosting and international transfers
The Institut Guttmann research database is hosted on infrastructure located in Spain.
8. Retention
Pseudonymised research datasets will be retained for ten years after the study ends, unless applicable law requires a different period.
9. Withdrawal, disconnection and erasure
Participants may stop using the app, disconnect Google Health or request study withdrawal and data erasure.
10. Security
Measures include pseudonymisation, separation of identifiers, role-based permissions and secure transfer channels.
11. Rights
Participants may request access, rectification, erasure, restriction, objection and portability where applicable.
12. Children
The app is intended only for participants aged 18 or over.
13. Changes
We may update this policy to reflect changes in law, technology or the study.