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    Privacy Policy

    Last reviewed: October 10, 2026

    1. Introduction

    This page explains what personal data is processed on the website ronquidoyapneas.com, what for, under which legal basis, how long it is kept, who else sees it and what you can ask for at any time. It is written in compliance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 (LOPD-GDD).

    The website has been designed under the principle of "privacy by design": whenever technically possible, sensitive data is calculated on your own device and never leaves it.

    Informing you is not the same as asking your permission. This page fulfils the duty to inform you (Articles 13 and 14 GDPR) and applies to everyone. Consent is something else: it is one of the possible legal bases, and you are only asked for it when the law requires that specific basis — for example, for the extended AI report or for analytics cookies. When you are a patient and the doctor treats you, the basis is not consent (see section 4): that is why you receive this information even when there is nothing to tick.

    2. Data Controller

    The controller who decides why and how your data is processed on this website is:

    Owner

    Iván Méndez-Benegassi Silva

    Tax ID (NIF)

    44813151C

    Address for notifications

    Av. de Juan Antonio Samaranch, 51, Hortaleza, 28055 Madrid, Spain

    Professional status

    Physician specialised in Otorhinolaryngology, registration no. 282855946 of the Official College of Physicians of Madrid (ICOMEM), bound by professional secrecy.

    3. What Data Is Processed and What For

    Browsing and reading this website does not require you to give us any data. Data only appears when you do something specific:

    • Writing us an email: your email address, your name if you sign it and whatever you tell us in the message (which may be health information). Purpose: to read and answer you. The route that email follows is explained in section 8.
    • Booking a video consultation: your email, your phone number if you leave it, the date and time and the payment details. Purpose: to schedule the appointment, remind you of it, charge for it and email you the invoice, which is mandatory.
    • Entering the video consultation waiting room: your first name, your surnames, your ID/NIE number and your date of birth. Purpose: to open or complete your medical record, which the law requires, and to write your prescription if you need one (a prescription requires that data). The video consultation application does not keep them: they go directly to the doctor's medical record, stored encrypted on his server in Paris, together with the email, the phone number (if you left it when booking) and the booking language, so that the report and prescriptions can be sent to you. If you already had a record and the data do not match, the doctor checks your identity before opening it. If the patient is a minor, their mother, father or guardian books and is present in the room; the data are the minor's and are provided by their representative. The patient needs their own ID card or NIE, also if they are a minor; if they do not have one, they must ask for an in-person appointment. To enter the room you use the personal link you receive by email (it can be reused during the time window of your appointment, for example if your connection drops, and it is stored encrypted until the appointment data is deleted) or, if you do not have it, you type your email and receive a 6-digit code by email, valid for 10 minutes; knowing the email is not enough. If you book in English, the emails, the entry page and the waiting room are in English.
    • Booking a private consultation by calling Elena: Elena is an artificial intelligence virtual assistant and tells you so when the call starts. She does not record the call or keep what is said in it, and she does not ask you anything about your health. To give you an appointment she stores your first name, your surnames, the phone number you call from and the appointment (clinic, day and time); if you leave a message for the doctor, your name and your phone number. Purpose: to give you the appointment, call you the day before to remind you of it and, if the doctor cannot see patients that day, offer you another slot. The doctor is the controller of this appointment data. The in-person consultation is provided and invoiced at the HM Hospitales centre you choose: there HM asks for your details and keeps your medical record as controller of that processing. Elena does not send your data to HM; the doctor only lets the centre's reception know if needed to organise your appointment (for example, if you cancel it on the same day).
    • Being seen in consultation: the clinical data of the care provided. Purpose: to treat you and to document it in your medical record, as the law requires.
    • Completing the questionnaires and the self-examination: your answers. Purpose: to calculate your result on your own device (see section 5).
    • Requesting the extended AI report: a reduced version of that data (see section 5). Purpose: to write an orienting, educational text.
    • Writing in the virtual assistant, the Orientation Guide or the website's search boxes and pressing their button: the text you write. While you type in the search boxes nothing is sent; the text only leaves your device when you press the button. Purpose: to generate the answer or to point you to the relevant information on the website (see sections 6 and 9).
    • Accepting analytics cookies: aggregated usage data. Purpose: to know which pages are read and improve the website. Only if you accept them (see section 10).
    • Using the AI tools: a daily usage counter linked to an irreversible code derived from your IP address (the IP itself is not stored). Purpose: to prevent abuse and protect the service.

    None of this is used for advertising or sold. Who else is involved in the processing, and on what terms, is explained in section 8.

    4. Legal Basis for Processing

    Health data is special category data (Article 9 GDPR) and needs a reinforced legal basis. There is not just one here: there are two different situations, and each one has its own.

    a) You come to the doctor: contact email, appointment, video consultation and healthcare

    The basis is not your consent, but Article 9.2.h GDPR: the processing is necessary for medical diagnosis and the provision of health care, and it is carried out by a professional bound by professional secrecy (Article 9.3 GDPR and Additional Provision 17 of Spanish Organic Law 3/2018). Alongside it apply, as the case may be, Article 6.1.b (the relationship you request: arranging and attending the appointment) and Article 6.1.c (legal obligations, such as documenting the medical record under Spanish Law 41/2002 and keeping tax documentation).

    This is what the Spanish Data Protection Agency recommends for health care: asking for a consent that would not really be free (if you do not give it, you cannot be treated) would be a false legal basis and would leave you less protected.

    b) You are a visitor using the tools: tests, questionnaires, AI report, snore analyzer, virtual assistant, Orientation Guide and search boxes

    Here you are not yet a patient of this doctor and no healthcare is under way. That is why, when any of this data leaves your device, the basis is your explicit consent (Article 9.2.a and Article 6.1.a GDPR): the box that appears unticked before the extended AI report or the one for the snore analyzer second opinion; and, in the Orientation Guide, the website's search boxes and the virtual assistant, pressing the button ("Search", "Clinical search" or "I understand and accept") after reading, next to it, that by pressing it you agree that an artificial intelligence analyses your text. Typing without pressing sends nothing. Giving it is free and nothing happens if you do not: the rest of the website works the same.

    c) Cookies and security

    Analytics cookies are only installed with your consent (Article 6.1.a GDPR and Article 22.2 of Spanish Law 34/2002). Technical cookies and the counters that prevent abuse of the tools rely on the controller's legitimate interest in keeping the website working and undegraded (Article 6.1.f GDPR).

    5. Questionnaires, Self-Examination and Snore Analyzer

    🔒 By default, everything stays on your device: the scores of the self-assessment questionnaires (STOP-BANG, Epworth, etc.), their interpretation, the self-examination results and the PDF report are calculated on your device (web browser). Your answers are not sent to any server unless you request the extended AI report.

    This means that:

    • Risk score calculation runs locally in your browser.
    • The extended AI report is optional. It is only generated if you tick the consent box (which is unticked by default) and press the "Generate extended AI report" button. If you do not request it, the rest of the assessment works the same.
    • In that case, a reduced version of your data is sent encrypted (TLS): the questionnaire scores, your sex and, as ranges rather than exact figures, your age, BMI and neck circumference; in the global results and in the self-examination, also the self-examination findings. The comments or questions you have written are not sent, nor your name, email, phone number or any other data that could identify you.
    • That data is processed on servers in the European Union for the sole purpose of writing the report and is not stored: neither your data nor the report is kept in our systems. It is not used for advertising purposes or to train artificial intelligence models.
    • The PDF report is generated entirely in your browser memory.
    • When you close the tab, the questionnaire data is automatically deleted from your device.

    Snore analyzer: the audio is analysed 100 % on your device by a local acoustic engine. The recording is not uploaded to any server, is not stored outside your browser, and nobody listens to it. The analyzer compares the tone and rhythm of the recording with four example sounds. Only if you tick the optional box (which is unticked by default), the numerical measurements of tone and rhythm — never the audio — are sent to the artificial intelligence provider for a second opinion on that resemblance, and are processed outside the European Union (see section 9).

    6. Virtual Assistant and AI Technologies

    To provide the interactive chat service ("Virtual Assistant"), the platform uses Artificial Intelligence technology.

    Processing:

    When you send a question to the chat, any personal data detected in the text is first stripped out. Then the search in the website's knowledge base and the writing of the answer take place on servers in the European Union, for the sole purpose of answering you. There are two exceptions, explained in section 9: an initial automatic classification of the question (for example, to detect a possible emergency), which takes place outside the European Union, and, when scientific studies need to be looked up, a few English medical keywords taken from the question, which are sent to PubMed.

    No stored conversations:

    Conversations are not stored in a database and are not linked to your real identity (name or email) unless you voluntarily type it into the chat.

    No automated decisions:

    Neither the assistant nor the AI report makes decisions about you: they are orienting, educational texts. No decision with legal or similarly significant effects is taken based solely on automated processing (Article 22 GDPR). AI-generated content is identified as such (Article 50 of Regulation (EU) 2024/1689).

    ⚠️ Warning: it is recommended not to enter sensitive personal data (ID number, full surnames, exact address) in the conversation with the assistant.

    7. How Long Your Data Is Kept

    DataPeriod
    Medical record (if you become a patient)Ten years from your last consultation. The law requires a minimum of five years from the date of discharge of each episode of care (Article 17 of Spanish Law 41/2002); it is kept longer to deal with possible claims and with patients who come back. After that period it is deleted, only once the doctor confirms it, and the encrypted backups disappear within 12 months at most. If the rules of your region require a longer period, that one applies.
    Contact emails that do not lead to a consultationOne month from the last communication; they are then deleted, including the copy forwarded to Gmail (see section 8). If healthcare arises from that email, whatever must be recorded in your medical record is added to it and kept with the medical record (previous row), not for one month.
    Appointment data not included in the medical recordOne month from the date of the appointment; it is then deleted.
    Appointments booked with Elena and messages for the doctorThe appointment is deleted the day after it takes place (or is cancelled); the message, the day after it reaches the doctor. The email notice the doctor receives for each appointment, change, cancellation or message (name, surnames, phone number, clinic, day and time) is kept in his professional mailbox, hosted in the European Union, for as long as needed to manage your appointments.
    Invoice for a paid video consultation (issued by the doctor himself)For as long as the tax authorities can review it: four years, counted from the end of the deadline for filing the tax return in which it is included (Articles 66, 67 and 70 of Spanish Law 58/2003, General Tax Act, and Article 19 of Royal Decree 1619/2012, which regulates invoicing obligations).
    Encrypted backupsData erased on the server may remain in the encrypted backups for up to 12 months (30 daily, 12 weekly and 12 monthly copies are kept); after that they disappear from them. Backups are used only to restore the service after a failure.
    Questionnaire and self-examination answersNot kept: they live in your browser and are deleted when you close the tab.
    Extended AI report and assistant chatNot stored: neither what is sent nor the text generated is kept.
    Anti-abuse countersAn irreversible code derived from your IP, with a counter that resets every 24 hours.
    CookiesThe duration of each one is listed in the cookie policy.

    After those periods, data is erased, unless it must be kept blocked in order to deal with possible legal liabilities.

    8. Recipients and Data Processors

    Your data is not sold or used for advertising purposes. For the website to work, the technology providers in this table are involved, each one only for what is stated:

    • Hostinger, Supabase, the artificial intelligence provider and Google (for Google Analytics) process the data on behalf of the controller, under the data processing agreement (Article 28 GDPR) that is part of their terms of service. The specific identity of the artificial intelligence provider is given to anyone who requests it by exercising their right of access.
    • OVH, a French storage provider, keeps the nightly backups of the server as a data processor, in the European Union. The backups are encrypted on the doctor's server before leaving it, so OVH only stores files it cannot read.
    • Cal.com handled the scheduling of video consultations booked until October 9, 2026 and states in its privacy policy that it processes that data as a data processor. Since that date, bookings are made in the doctor's own video consultation application (see the table).
    • Stripe, the platform that takes the card payment for a paid video consultation on its own secure payment page, states in its privacy policy that it processes the payment data as a data processor and, for its own purposes such as security and fraud prevention, as a controller.
    • Elena's telephone carrier and voice services (recognition of what you say and Elena's voice) process the call data on behalf of the controller, as data processors, only while the call lasts.
    • Google (Gmail) receives the contact email on the terms explained below the table.
    ProviderWhat forWhat it receives
    HostingerHosting, on a server in Paris (European Union), of the website, the domain mailbox, the doctor’s video consultation and booking application (videoconsulta.ronquidoyapneas.com), the doctor’s medical record and Elena’s system, the telephone assistant.The server technical logs and the emails you send to the contact address, before forwarding them to Gmail. If you book a video consultation: your email, your phone number if you give it and the date and time of the appointment, and your personal entry link, stored encrypted and deleted one month after the appointment. The image and voice of the video consultation do not go through the server and are not recorded. If you are a patient: your medical record (your identity data, the doctor's notes and your prescriptions), in an encrypted database.
    SupabaseRuns the functions of the AI report, the virtual assistant, the Orientation Guide and the search boxes, and stores, on servers in the European Union, the website's knowledge base and the anti-abuse counters. It also generates and stores the invoices for paid video consultations (without patient data) and emails them. And it stores, also in the European Union, the private consultation schedule that Elena manages.The reduced version of the report data, the text you write and the irreversible code of your IP. It stores neither the data nor the conversations. For the invoice, it briefly uses the email you gave when booking, without storing it. For the private consultation: the name, surnames, phone number and appointment you give Elena.
    Artificial intelligence providerProvides access to the artificial intelligence models that write the extended report and the assistant answers, to those that perform the knowledge base search and to the service that makes the initial classification of what you write.For writing and searching: the necessary text, through its European Union endpoint; for writing it is also required that the data is not retained (Zero Data Retention) or used to train models. For the initial classification: the text you write in the assistant, the Orientation Guide and the search boxes, already stripped of any personal data detected, which is processed outside the European Union (see section 9). For the snore analyzer second opinion, only if you tick its box: the numerical measurements of tone and rhythm, never the audio, also outside the European Union.
    Elena's telephone carrier and voice servicesConnecting your call with Elena, turning what you say into text and giving voice to Elena's answers. The artificial intelligence model that decides the answer is the one from the provider in the previous row, through its European Union endpoint and with no data retention (Zero Data Retention).The number you call from and the technical data of the call; and, only while it lasts, the audio and its text, which are neither recorded nor stored. Speech recognition and Elena's voice run on servers in the European Union.
    OVHStoring the encrypted nightly backups of the doctor's server (object storage, in the European Union).Files encrypted at source that contain a copy of what the server stores; OVH does not have the key and cannot read them. They are kept for up to 12 months.
    Cal.com (until October 9, 2026)Scheduling of the video consultations booked until that date.Name, email, date and time, whatever you write in the booking form and the payment details. Never your questionnaire answers.
    StripeCard payment for a paid video consultation, on its own secure payment page, and its refunds.Name, email, amount, date and the card details. The doctor does not keep the card details. Never your questionnaire answers.
    Google Analytics 4Measuring website usage, only if you accept analytics cookies.Aggregated, pseudonymised browsing data. Never your health answers.
    Google (Gmail)Receives, by automatic forwarding, the email that arrives at the contact address.The emails you send to contacto@ronquidoyapneas.com, which may contain health data. See the next paragraph.

    The contact email is forwarded to Gmail. The messages you send to contacto@ronquidoyapneas.com arrive at the domain mailbox, hosted by Hostinger, and from there are automatically forwarded to a personal Gmail account of the doctor. Google therefore also receives and stores those messages, which may contain health data, and processes them under its own terms of service and privacy policy. For that reason, and because email is not an end-to-end encrypted channel, we recommend that you do not send medical reports or health data by email: tell us only what is essential and the rest will be covered in the consultation.

    In addition, your data may be disclosed to public authorities, courts and law enforcement when required by law.

    9. Transfers Outside the European Union

    • The extended AI report and the assistant answers are produced in the European Union: the model that writes them is called through the provider's European endpoint, with no alternative route outside the EU, and the search in the website's knowledge base also takes place in the EU. The extended report data only goes to that European endpoint.
    • The initial classification of what you write does leave the European Union: the text you write in the virtual assistant, the Orientation Guide and the website's search boxes first goes, already stripped of any personal data detected, through an automatic service that classifies it (for example, to detect a possible emergency or to know what topic it is about). That service operates outside the EU and receives only the text, not your IP address. The transfer relies on the European Commission's standard contractual clauses that the access provider includes in its data processing agreement. That is why we recommend that you do not write your name or other data that could identify you. The snore analyzer second opinion goes through the same service, only if you tick its box: it receives the numerical measurements of tone and rhythm, never the audio.
    • Bibliographic searches also leave, but without you in them: to look for scientific studies, PubMed, the search engine of the US National Library of Medicine, is queried. For the reports, fixed topic texts written in advance are sent — for example, "daytime sleepiness and sleep apnea"; for the assistant, a few English medical keywords taken from your question. Your full text, your scores, your age or BMI ranges, your sex or any data that could identify you are never sent.
    • Contact email: it is forwarded to Gmail (see section 8). Google may process those messages on servers located outside the European Union; for those transfers it states in its privacy policy that it relies on the safeguards provided for in the GDPR (the EU-U.S. Data Privacy Framework and standard contractual clauses).
    • Calls to Elena: the telephone carrier may process outside the European Union the number you call from and the technical data of the call, with the safeguards of Chapter V GDPR that it states in its terms. What you say is turned into text, answered and voiced in the European Union.
    • Payment and analytics: Stripe may process the payment data in the United States and Google may process Google Analytics data outside the European Economic Area; Cal.com processed in the United States the data of bookings made until October 9, 2026 (current bookings are stored in the European Union). These transfers rely on the safeguards of Chapter V GDPR (an adequacy decision, such as the EU-U.S. Data Privacy Framework, or standard contractual clauses) that each provider states in its own terms.

    10. Cookies and Local Storage

    This website does not use advertising or invasive tracking cookies.

    Technical cookies:

    Essential cookies or local storage (sessionStorage) may be used, which are indispensable for the technical operation of the website (for example, keeping the chat active during the session or remembering that you accepted the legal notice).

    Analytics:

    We use Google Analytics 4 only if you accept analytics cookies in the consent banner (Google Consent Mode v2). Data is collected in aggregated, pseudonymised form, is never linked to your health answers, and we do not use advertising tracking pixels. You can change your mind at any time in the cookie policy.

    11. Your Rights

    You may exercise the following rights at any time, free of charge:

    • Access: to know what data of yours is processed and obtain a copy.
    • Rectification: to correct data that is inaccurate or incomplete.
    • Erasure: to ask for deletion when the data is no longer necessary, subject to what the law requires to be kept (for example, the medical record, which cannot be erased before five years from discharge).
    • Objection: to object to processing based on legitimate interest.
    • Restriction: to ask that data be kept but not used while a claim of yours is resolved.
    • Portability: to receive, in a commonly used format, the data you have provided.
    • Withdraw consent: where processing is based on it (AI report, snore analyzer second opinion, virtual assistant, Orientation Guide and search boxes, analytics cookies), you may withdraw it at any time and as easily as you gave it: by unticking the box or, in the Orientation Guide, the search boxes and the assistant, by no longer pressing the send button. Withdrawing it does not affect processing carried out beforehand: what was done up to that point remains lawful.

    For the tests and the chat:

    Since this data is not stored, the right to erasure takes care of itself: when you close the browser there is nothing left to delete.

    For appointments, emails and medical records:

    Contact the controller, the doctor himself: write to contacto@ronquidoyapneas.com or by post to the address in section 2, stating which right you wish to exercise and attaching a copy of a document proving your identity. You will receive an answer within one month.

    12. Complaint to the Supervisory Authority

    If you believe your data has not been handled properly, you may first write to the controller at the contact address in section 2. In any case, you have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD), C/ Jorge Juan, 6, 28001 Madrid: www.aepd.es

    If you live in another country of the European Economic Area, you may also complain to the data protection authority of your country.

    13. Protection of Minors

    This platform is intended for users over 18 years of age. If you are a minor, you must use this tool under the supervision of a parent, guardian, or healthcare professional. Minors are seen in the video consultation: their mother, father or guardian books it and must be present in the waiting room and throughout the consultation. The minor needs their own ID card or NIE; if they do not have one, they must ask for an in-person appointment.