App-user policy · Final legal review recommended
Privacy policy
This policy explains the two distinct ways data is handled in IOLResearch: research databases stay under the user’s control on the device, while limited Sponsor and Key Evidence Leader account information is processed through Supabase to manage access.
Last updated: 9 September 2026
Privacy at a glance
- Research records
- Stored locally. IOLResearch does not send research databases or participant measurements to the Developer or Supabase.
- Access accounts
- Name, email address, Sponsor or KEL role, and access information are processed to create and administer authorized accounts.
- Backups and exports
- Occur only when a user chooses a device, iCloud, email, file-sharing, or other external service. The user or their institution controls those destinations.
- Advertising and tracking
- Account information is not sold, used for advertising, or used to track users across third-party apps and websites.
1. Scope
This policy applies to the IOLResearch iPad application and to the web pages used for invitations, account registration, email confirmation, password recovery, support, and account-security notices. It does not govern services that a user independently chooses for device backup, cloud storage, email, or file sharing.
2. Developer, controller, and contact
For Sponsor and Key Evidence Leader account and access information, the controller is INDALOFTAL S.L. (the “Developer”), Camino de Bobar, 1, 04007 Almería, Spain, Tax ID B04570446.
Privacy and data-rights enquiries may be sent to academy@qvision.es. General information is available at qvisionacademy.com.
The research institution, investigator, or other organization using IOLResearch normally determines the purpose and means of processing participant data entered into a local research database. That party, rather than the Developer, is normally the controller of those research records. Users should follow their institution’s privacy information and contact process for requests concerning participant data.
3. Data we process
3.1 Sponsor and Key Evidence Leader accounts
To administer authorized access, the Developer processes the user’s name, email address, Sponsor or Key Evidence Leader role, assigned access level and status, and an internal account identifier. The information may be supplied by the user, an authorized Sponsor, or an administrator who sends the invitation.
Supabase Authentication also processes the credentials, verification and recovery tokens, session information, and security-event records needed to create and protect the account. The Developer does not receive the user’s password in readable form.
3.2 Authentication website and technical records
When a user opens an invitation or account-security page, Supabase and the website host may process limited technical information required to deliver and secure the service, such as IP address, browser or device information, request time, requested route, and authentication events. This website does not ask users to enter clinical or research data.
3.3 Support communications
If a user contacts support, the Developer processes the sender’s contact details and the contents of the request to respond and maintain an appropriate support record. Users must not send passwords, one-time tokens, re-identification keys, or participant data in support messages.
4. Research data stored locally
IOLResearch can store study identifiers, participant pseudonyms, eye and implanted-lens information, protocol and visit details, measurements, analyses, and related research records. These data are stored in databases controlled by the user on the iPad. They are not uploaded to the Developer’s or Supabase’s servers by IOLResearch.
Pseudonymized research data may still be personal data when a person can be re-identified using additional information. The user or their institution is responsible for choosing appropriate pseudonyms, keeping any re-identification key separately and securely, defining access permissions, establishing a lawful basis, providing required participant information, obtaining consent or ethics approval when applicable, and meeting local research and data-protection requirements.
The Developer recommends that a re-identification key never be kept in the IOLResearch database, on the same device, or in the same cloud account used for a database backup.
4.1 Backups, iCloud, and external storage
IOLResearch does not operate a cloud backup service for research databases. A database may be included in a device or iCloud backup, or copied to another service, only through settings and actions controlled by the user. Apple or another provider then processes the copy under its own terms and privacy policy.
The user or their institution is responsible for deciding whether a backup or external storage service is permitted for the study; configuring encryption, access, retention, and recovery; checking the provider’s processing locations and contractual safeguards; and deleting every copy when required. Disabling iCloud or deleting the App may not delete copies already stored elsewhere.
4.2 Exports and sharing
When a user exports or shares a database, table, chart, or other file, the user chooses the destination and recipients. After export, the data are governed by the safeguards, retention rules, and permissions of that destination. The Developer cannot access, recover, or delete user-controlled exports.
5. Purposes and legal bases
| Processing | Purpose | Legal basis under the GDPR |
|---|---|---|
| Account and access data | Create an account, assign Sponsor or KEL permissions, administer access, and provide the requested service. | Performance of a contract or steps requested before entering a contract (Article 6(1)(b)). |
| Authentication and security events | Verify identity, protect accounts, prevent misuse, investigate incidents, and maintain service integrity. | The Developer’s legitimate interests in secure service operation (Article 6(1)(f)), balanced against user rights. |
| Support communications | Answer requests and resolve account or service issues. | Contract performance (Article 6(1)(b)) and legitimate interests in user support (Article 6(1)(f)). |
| Required records | Comply with law and establish, exercise, or defend legal claims. | Legal obligation (Article 6(1)(c)) and legitimate interests (Article 6(1)(f)), as applicable. |
The Developer does not use consent as a catch-all legal basis. If a future optional feature requires consent, the request and withdrawal method will be presented at the relevant time.
6. Recipients, processors, and international transfers
Access is limited to authorized Developer personnel who need the information for account administration, security, support, or legal compliance. The Developer does not disclose account information to independent advertisers or data brokers.
- Supabase provides the hosted database and authentication service for Sponsor and KEL accounts. It does not receive IOLResearch research databases. See the Supabase Privacy Policy.
- Vercel hosts the invitation, registration, recovery, and policy website. See the Vercel Privacy Notice.
- Apple and user-selected services process device backups, iCloud copies, purchases, email, or exported files only when the user enables or chooses those services. Their own terms and privacy policies apply.
These providers may use subprocessors or processing locations outside the European Economic Area. Where a restricted international transfer applies, the Developer will rely on an applicable adequacy decision or appropriate contractual safeguards, such as the European Commission’s Standard Contractual Clauses. Users may request information about applicable safeguards using the contact address above.
7. Retention and deletion
- Local research data: retained until the user deletes the relevant database or local copy. The Developer cannot delete a file it does not receive. Users must separately manage backups and exports.
- Account and access records: retained while access is active and afterward only as needed to complete deactivation, handle security and support matters, comply with law, or resolve claims. Records are then deleted or irreversibly de-identified.
- Authentication and technical logs: retained according to the security configuration and applicable retention period of the relevant provider, then deleted or aggregated.
- Support communications: retained while the request is handled and afterward only where needed for continuity, security, or legal obligations.
A Sponsor or KEL may request account deletion at the contact address above. The Developer may need to verify the requester’s identity. Deletion of the Supabase account does not delete locally stored research databases, iCloud backups, or files exported by the user.
8. Security
The Developer applies access controls and reasonable technical and organizational safeguards appropriate to the limited account data it controls. No system is completely secure. Users are responsible for device passcodes, operating-system updates, account credentials, database access, secure exports, and any backup or recovery configuration they choose.
9. Your data-protection rights
Subject to applicable law, users may request access, rectification, erasure, restriction, portability, or objection in relation to account data controlled by the Developer. Users may withdraw consent where a specific processing activity relies on consent and may complain to their competent supervisory authority. In Spain, this is the Spanish Data Protection Agency (AEPD).
Requests are free in ordinary cases and will be answered within the period required by applicable law. These rights concern data the Developer controls. Requests about participant research data held only by a research institution must be directed to that institution.
10. Automated decisions, advertising, and children
The Developer does not use Sponsor or KEL account data for automated decisions that produce legal or similarly significant effects, behavioral advertising, or cross-service tracking. IOLResearch is intended for authorized professional and research use and is not directed to children. If a study includes minors, the research institution remains responsible for the required safeguards and authorizations for locally held research data.
11. Changes to this policy
The Developer may update this policy when the App, providers, or legal requirements change. The revised version will show a new date. Material changes affecting account-data processing will be communicated through an appropriate channel, such as the App, website, or account email, before they take effect when required by law.
12. Language
The English and Spanish versions are intended to have the same meaning. If a discrepancy remains, the Spanish version prevails to the extent permitted by applicable law.