This Privacy Policy explains how ZorgaNova B.V., operating the VocaCare AI service, collects, uses, stores, and protects personal data in connection with its voice-based wellbeing monitoring platform for elderly users. The service is designed as a non-medical, privacy-conscious, GDPR-oriented solution.

01

Data Controller

The data controller for the processing described in this Privacy Policy is:

ZorgaNova B.V.
The Netherlands
Email: info@zorganova.nl

ZorgaNova B.V. acts as the controller within the meaning of Article 4(7) GDPR for the VocaCare AI service.

02

Scope of This Policy

This Privacy Policy applies to the processing of personal data through the VocaCare AI platform.

Primary Users

  • Elderly individuals receiving short voice-based interactions
  • Individuals living independently and using the service for wellbeing monitoring

Secondary Users

  • Authorized family members
  • Caregivers or care organizations acting with user permission

The service is intended for non-medical wellbeing monitoring and does not provide emergency response, clinical treatment, or medical diagnosis.

03

Categories of Personal Data

VocaCare AI processes only the categories of personal data necessary to provide the service.

Identification & Contact Data

  • Name
  • Phone number
  • Language preference

Voice & Interaction Data

  • Short audio recordings from voice interactions
  • Speech-to-text transcriptions
  • Interaction metadata such as duration and response timing
04

Purpose of Processing

Personal data is processed solely for legitimate, specified, and limited purposes related to the operation of VocaCare AI.

Providing daily or near-daily voice-based wellbeing monitoring
Detecting changes in communication patterns over time
Informing authorized users of general wellbeing signals
Improving and maintaining the service
Ensuring security, service integrity, and compliance
Supporting early awareness rather than medical evaluation

Voice interaction is used because it is intended to be less intrusive than cameras, continuous sensor tracking, or location monitoring.

06

Security and Safeguards

ZorgaNova B.V. implements appropriate technical and organizational measures to protect personal data and reduce privacy risks.

Encryption

Encryption in transit and at rest where appropriate.

Access Controls

Restricted access, role-based permissions, and secure authentication practices.

EU-Oriented Infrastructure

Preference for EU-based hosting and appropriate safeguards where transfers are necessary.

Security Reviews

Regular security assessments and incident response procedures.

Data Minimization

Processing is limited to what is necessary for service provision.

Human Oversight

Indicators are informational and intended to be interpreted by authorized users.

07

Your Rights Under GDPR

Data subjects have rights under the GDPR, subject to applicable legal conditions and limitations.

Right of Access Request access to your personal data.
Right to Rectification Request correction of inaccurate or incomplete data.
Right to Erasure Request deletion of data where legally applicable.
Right to Restriction Request limitation of processing in certain circumstances.
Right to Data Portability Request transfer of data where applicable.
Right to Object Object to certain processing activities where legally available.

Requests regarding these rights may be submitted to info@zorganova.nl.

08

Data Retention

We apply retention limits designed to keep personal data no longer than necessary for the purposes for which it is processed.

09

Data Sharing and Processors

We do not sell personal data to third parties. Personal data may be shared only where necessary for service delivery, legal compliance, or security.

10

Automated Processing and Wellbeing Indicators

The service uses automated analysis of speech, language, and interaction patterns to generate informational wellbeing indicators.

Analysis of speech rhythm, pauses, and response timing
Analysis of language coherence and repetition patterns
Comparison to an individual historical baseline
Human interpretation remains necessary for any follow-up action

The system does not make decisions with legal or similarly significant effects and does not provide automated medical diagnosis. Outputs are informational only and are intended to support awareness.

11

DPIA Summary

A Data Protection Impact Assessment (DPIA) has been prepared to assess privacy risks associated with the service, particularly because processing includes voice data, automated analysis, and elderly individuals who may constitute a potentially vulnerable group.

Following these safeguards, the residual risk has been assessed as low to medium and is considered manageable in light of the service scope, intended benefits, and non-medical design.

12

Contact and Complaints

For questions regarding this Privacy Policy, personal data processing, or data subject rights, please contact:

ZorgaNova B.V.
info@zorganova.nl
VocaCare AI

If you believe that your data protection rights have been violated, you may also lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).