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Privacy policy

How Vitality Plus SA processes the personal data of its customers (Annex B of the licence agreement).

Last updated 14 August 2026. The Italian text is the official version.

Demo requests

This note supplements the Customer Privacy Notice below. When you request a demo, Vitality Plus SA uses the details you enter in the form to answer you, arrange the demo and send you a proposal, and for nothing else. Legal basis, retention, recipients and your rights are described in the Customer Privacy Notice, in particular in point 4.2 on pre-contractual measures.

Annex B – Customer Privacy Notice

Notice on the processing of personal data pursuant to Article 13 of Regulation (EU) 2016/679 and Article 19 of the Swiss Federal Act on Data Protection of 25/09/2020

Dear Customer,

this notice on the processing of personal data governs the processing of the personal data of Customers who enter into a technology licence agreement with Vitality Plus SA for the APP and Web APP software named "Vitality+".

The rules indicated above apply to Customers located in the territory of the European Union and of the Swiss Confederation respectively.

In this regard, please note that, depending on where you or the company you represent are located, your personal data will be processed under one of the two sets of provisions referred to above.

1. Data subject

You, i.e. the person to whom this notice is addressed, also referred to as the Customer.

2. Data Controller

The Controller of your personal data is Vitality Plus SA (hereinafter also the "Controller" or "Vitality Plus"), with registered office at Via Emilio Maraini 27, 6942 Savosa, which can be contacted at the following e-mail address: info@vitalityplus.app.

3. Representative in the European Union

For Users established in EU countries, pursuant to Article 27 of Regulation (EU) 2016/679, the Controller has appointed as its representative in the European Union INDO SRLS, Viale Giacomo Mancini, 156 – 87100 Cosenza (CS), Italy, VAT no. 03510180783, Tel. +39 02 87366082, Email dpo@indoconsulting.it.

4. Purpose of processing, justification/legal basis, retention period of your personal data

Your data is processed for the following purposes.

4.1. Legal obligation

To comply with any obligation provided for by the federal or cantonal laws in force, ordinances, related regulations and commercial practices, in particular in tax and fiscal matters.

Justification: (for Users in Switzerland) Art. 31(1) FADP, processing justified by law. Legal basis: (for Users in the EU) Art. 6(1)(c) GDPR, legal obligation. Retention period: data will be retained for as long as the Controller is subject by law to retention obligations.

4.2. Taking pre-contractual measures

Where you contact Vitality Plus to request information about the services or products we offer, including for the purpose of taking pre-contractual measures aimed at issuing a quotation. Provision of the data is necessary; without it, it will not be possible to follow up requests or issue quotations.

Justification: (for Users in Switzerland) Art. 31(2)(a) FADP, overriding interest of the Controller, namely the processing of data relating to the Data Subject in direct connection with pre-contractual measures. Legal basis: (for Users in the EU) Art. 6(1)(b) GDPR, performance of pre-contractual measures taken at the Data Subject's request. Retention period: data will be retained for the time necessary to process the request or for the period of validity of the quotation.

4.3. Performance of a contract

Where you are entering into the Technology Licence Agreement with Vitality Plus. Provision of the data is necessary; without it, it will not be possible to perform the contract and the services concluded.

Justification: (for Users in Switzerland) Art. 31(2)(a) FADP, overriding interest of the Controller, namely the processing of data relating to the Customer in direct connection with the performance of the contract. Legal basis: (for Users in the EU) Art. 6(1)(b) GDPR, performance of the contract. Retention period: data will be retained for the entire term of the contract and, consequently, for 10 years from the end of the financial year, in accordance with the Swiss Code of Obligations (CO).

4.4. Assessing creditworthiness

To assess the Customer's creditworthiness where the type of contract entered into makes this necessary, except in the case of advance payments. Provision of the data is necessary; without it, it will not be possible to allow deferred payments or payment in instalments.

Justification: (for Users in Switzerland) Art. 31(2)(c) FADP, overriding interest of the Controller, namely assessing the Customer's creditworthiness; however, we do not collect sensitive personal data and do not carry out high-risk profiling, the data is disclosed only to third parties who need it for the conclusion or performance of the contract with the person concerned, the data is not more than ten years old and the person concerned is of legal age. Legal basis: (for Users in the EU) Art. 6(1)(f) GDPR, legitimate interest of the Controller. Retention period: data will be retained for the entire term of the contract.

4.5. Direct marketing to Customers (Soft Spam)

Where you have already purchased a product or service from Vitality Plus, we will send you promotional communications concerning services and products similar to those already purchased. Provision of the data is authorised by law. Your contact details will therefore be used for direct marketing purposes.

Justification: (for Users in Switzerland) processing justified by law, namely by Art. 3(1)(o) of the Federal Act against Unfair Competition (UCA). Legal basis: (for Users in the EU) Art. 6(1)(f) GDPR, legitimate interest of the Controller. Retention period: until you object or unsubscribe via the "opt-out" system at the bottom of our e-mails.

4.6. Direct marketing

To send you commercial and informational communications of various kinds concerning the sector in which the Controller operates, to send newsletters, commercial proposals, invitations to workshops or events promoted by us and notices of advertising events, through traditional channels such as telephone operators and mailing, or more innovative systems such as SMS, social media including WhatsApp, and e-mail, for services and products other than those you may already have purchased. Provision of the data is therefore optional; without it, we will not be able to keep you updated on our services and promotional activities or invite you to our events.

Justification: (for Users in Switzerland) Art. 3(1)(o) UCA and Art. 31(1) FADP, through the Data Subject's consent expressly given at the bottom of this notice or elsewhere (for example following your explicit request to subscribe received by us via e-mail, SMS or social media). Legal basis: (for Users in the EU) Art. 6(1)(a) GDPR, consent of the Data Subject. Retention period: until you object or unsubscribe via the "opt-out" system at the bottom of our e-mails.

5. Categories of recipients of personal data, disclosure and dissemination

Your data will not be disseminated to unspecified parties by being made available or consultable. We disclose your data to the following categories of recipients:

5.1. Collaborators or other staff authorised to process data (by way of example: administrative, sales and accounting staff, system administrators), within the limits necessary to carry out their duties for the Controller, subject to a letter of appointment imposing the duty of confidentiality and security.

5.2. Consultants or suppliers acting as data processors (by way of example: IT companies, communication agencies or other parties carrying out outsourced activities on behalf of the Controller), within the limits necessary to carry out their duties for the Controller, subject to the signing of a contract imposing the duty of confidentiality and security.

5.3. Bodies and, in general, any public or private party to which we are obliged (or entitled under primary, secondary or EU legislation) or need to disclose data, within their respective and specific areas of competence, such as, for example: i) the cantonal and federal authorities (e.g. for accounting or tax reasons) where a legal notification obligation applies; ii) other recipients (e.g. banks); iii) the offices responsible for collecting unpaid debts.

The Controller uses exclusively certified and secure service providers which: (i) are established in Switzerland; (ii) are established in the EEA; (iii) are established outside the EEA, in particular in Colombia. This takes place only after verifying that the safeguards provided for by Federal – European laws have been adopted, in particular:

  • for Users in the EU, in accordance with adequacy decision 2003/490/EC;
  • for Users in Switzerland, in accordance with Annex 1 of the DPO, which contains the list of States providing an adequate level of data protection.

Disclosure of personal data to providers that do not adequately protect data under Swiss and European law is therefore excluded.

Data Subjects established in Switzerland may request further information by writing to the following e-mail address: info@vitalityplus.app.

Data Subjects established in an EU country may request further information by writing to our EU representative at the following e-mail address: dpo@indoconsulting.it.

6. Processing methods

Data is processed by means of technical and organisational measures suitable to ensure that the security of personal data is appropriate to the risk. Processing may be carried out both on paper and with the aid of automated IT tools capable of storing, managing and transmitting the data.

7. Rights of Data Subjects

7.1. If you are domiciled in Switzerland

Articles 25 to 32 of the FADP grant you the following rights and claims, within the limits of the prescribed legal framework:

  • the right of access, to request information on the processing of your personal data;
  • the right to request the updating and rectification of your personal data;
  • the right to request the restriction of processing and of disclosure to third parties;
  • the right to request erasure or destruction;
  • the right to request a ban on processing or on disclosure to third parties;
  • the right to request that the disputed nature of the data or the court decision be noted.

If you have a complaint about how we handle your data, we would like to hear from you, but you also have the right to lodge a complaint with the Federal Data Protection and Information Commissioner.

7.2. If you are domiciled in the EU

Articles 15 to 21 of the GDPR grant you the following rights, within the limits of the prescribed legal framework:

  • the right of access under Article 15 GDPR and the right to rectification (to amend your data) under Article 16 GDPR;
  • the right to erasure under Article 17 GDPR and the right to restriction of processing (i.e. that such data is not subject to further processing and can no longer be modified) under Article 18 GDPR;
  • the right to data portability (i.e. to receive the personal data concerning you, which is processed by automated means, in a structured, commonly used and machine-readable format, and to transmit it to another controller, or to have it transmitted directly) under Article 20 GDPR;
  • the right to object to processing (i.e. to object to the processing of data concerning you and to the sending of advertising material, direct sales and market research) under Article 21 GDPR.

If you have a complaint about how we handle your data, we would like to hear from you, but you also have the right to lodge a complaint with the supervisory authority competent for the country in which you habitually reside, without prejudice to any other administrative or judicial remedy.

8. How to exercise your rights

To exercise your rights and claims, in the manner and within the time limits prescribed by the FADP or the GDPR, you may proceed as follows:

  • If you are established in Switzerland, by writing to the following e-mail address: info@vitalityplus.app.
  • If you are established in an EU country, by writing to our EU representative at the following e-mail address: dpo@indoconsulting.it.

We kindly ask you to promptly inform the Controller, or its representative in the European Union appointed by us, of any change to your personal data so that we can comply with Article 6 of the FADP and/or Article 16 of the GDPR, which require that the data collected be accurate and, therefore, up to date.

9. Prevailing language version

This notice is available in several languages. Translations are provided for ease of understanding only: in the event of any divergence, doubt of interpretation or conflict between versions, only the Italian version prevails and is legally binding.