Privacy policy

1. WHO are we?

Telefónica Innovación Alpha S.L. is part of the Telefonica Group and is the Data Controller of your personal information as a user of HOLD.

Name: Telefónica Innovación Alpha S.L. (Alpha)


Ronda de la Comunicación, Distrito Telefónica, 28050 Madrid, España.


Data Protection Officer Contact:

2. Why do we collect personal data about you and what do we do with it?

Inviting you to use HOLD or any other new product that might be of interest:
If you sign up on the website to register your interest in the app, we will process your personal data to send you an invitation to use HOLD. We may retain your personal data for some time (see section 5) in order to invite you to try other new products from Alpha.

Main functionalities of the app (Help you adopting good behaviours):
The main purpose of the HOLD application is to help users reflect more about topics that they care and help them reframe a problem or a situation that concerns them.Your consent is the basis for the collection and processing of personal data for the main functionalities of the app. You can remove your consent at any time by contacting us in using if possible the same e-mail address with which you registered in the App.

We process personal data to send you information about our new services or products.
We may use 3rd party services to facilitate communication such as promotional emails.  We may use, with your consent, third party cookies for this purpose of marketing analytics as described in our cookies policy

Improving the functioning of the application and our services: 
We process personal data to improve the website and application performance, usability and to provide a better service. This includes aspects related to performance, navigation, availability and usability. To do this we consider things like how often and for how long you use the app, how you navigate between screens, the activities you use, and which screens you spend more time on. We might also ask for your feedback through email or the app. We will not process any sensitive data for this purpose.  In some cases the functionality of the application uses third party services to support analytics and navigation and these functions may involve cookies as described in our cookies policy .
Our legitimate interest is the legal basis for this purpose, in case any of these cookies collects personal data, your consent is the basis for collecting the personal data. We are working to improve the recommendations within HOLD on an ongoing basis. To do this we may also process data, but only after it has been anonymised in a way that no longer identifies you. We may also use this anonymised data to improve research that supports the creation of products and services similar to the HOLD app. Anonymisation is performed under our legitimate interests, but you can always opt-out for this processing, following the process described in section 6.

3. What personal data do we collect about you and how?

HOLD functionalities require the collection of personal data such as audio recordings and text, and how negative or positive you feel about a journal. For example, if you start a conversation within the app, we will ask you to introduce text or record an audio with your thoughts.

HOLD does not diagnose, detect, prevent, monitor, predict, treat or alleviate any medical condition in any way. You are urged and advised to seek the advice of a doctor before beginning any reframing improvement program. Please also refer to our End-User Licence Agreement. 

Personal data we might collect on the website: 
- Email Address;
- User activity on the web page: Frequency of access to the web page, time spent in the web page, interaction with third party services through the web page. We may use cookies or similar technologies to collect this information.

Personal data we might collect on the app: 
- Thoughts of the user through audio or free text.
- How positive or negative the user feels when a conversation is recorded or typed.
- Statistical user activity in the application: Frequency of access to the app, time spent on different screens, functions used etc. We may use cookies or similar technologies to collect this information.

4. Do we share personal data about you with others?

We do not share personal information about you with other Data Controllers.
Our internal team members process your personal data following professional responsibilities and contractual obligations only for the purposes established in this Privacy Policy.
We take appropriate measures to guarantee the fair and confidential use of all personal data by our employees.

We may share some of your personal data with service providers for specific activities such as hosting (e.g. AWS) or analytics (e.g. Mixpanel or Google ), read our cookies policy. We only authorise our service providers to process your information following our instructions.
We make sure that our service providers erase all your personal information right after their services are finished. Some of our service providers may be located outside the EEA, including in countries (such as the United States) whose level of data protection may not be the same as that of the country of origin of our customers. We take the appropriate measures to ensure those providers comply with EEA standards in every processing of personal data they perform on our behalf, by requiring guarantees such as Standard Contractual Clauses or Privacy Shield certificates.

5. How long do we keep your data?

We may retain your personal data for different periods of time, depending on the type of data involved and the purposes of the processing, but generally, following these criteria:

- As long as you are an active user of our services or we have legal or contractual requirement to retain the data.
- If you are not active in our app, we will erase your data after 12 months from last access. We will also erase or stop processing your data if you withdraw consent or require us to do so. In these cases we will erase your data or anonymise it in such a manner that is no longer identifiable.

6. What rights do you have related your personal data and how can you use them?

The data protection laws give you a series of rights regarding the personal information that we manage about you. Specifically, the rights of access, rectification, erasure, limitation, objection, portability, as well as not being subject to automated decisions and to remove your consent at any time.

You can exercise these rights by contacting us in, using if possible the same e-mail address with which you registered in the App and identifying the right you want to request. In the event that you decide to exercise one of these rights through a representative, it will be necessary to provide with the request, the documentation that proves this condition.

You also have the right to file a complaint with a Data Protection Control Authority (e.g., the Information Commissioner's Office).

In order to register and use our services you must be over 16 years old or have the authorisation of your parents and/or legal guardians. Therefore, by signing up you confirm that you meet this condition.  We may contact you to confirm this. We do not knowingly collect information from those younger than 16 years. If you are a parent or guardian and believe that your child has used the application you may contact us at and we will delete all related personal data.

7. How do we keep your data safe?

Alpha is responsible for ensuring the security, integrity and confidentiality of your personal information. Therefore, as part of our commitment and in compliance with current legislation, we have adopted the most demanding and robust security measures and technical means to prevent their loss, misuse or access without your authorisation.

We protect all communications between the applications, website and the servers in line with best practice by using TLS for encryption and server authentication. We use ISO 27001 certified systems in order to protect your registration information including email and password.  We store your personal data in an encrypted database.

Also, we promise to act quickly and responsibly in the event that the security of your data may be in danger, and to inform you if necessary.

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