AirWatch Privacy Policy and Personal Data Processing

Application: Industrial Respirator Monitoring (AirWatch)
Version: 1.0 · Publication date: 08/12/2026 · Last updated: 08/12/2026

1. Purpose and scope

This Privacy Policy explains how personal data processed through the Industrial Respirator Monitoring system (AirWatch) is collected, used, stored, communicated and protected.

The system consists of:

• A sensor installed on an industrial respirator.
• A mobile application that receives measurements from the sensor.
• A web platform that displays information and operational alerts.
• The technology infrastructure used to transmit, store and manage the information.

This policy applies to workers who use respirators fitted with the sensor and to authorized users of the platform.

This policy is informational in nature. Use of the application does not, by itself, constitute consent to all the processing described herein.

This Policy has been drafted taking into account the amendments introduced by Law No. 21,719 to the personal data protection regime. Those amendments will enter into force on December 1, 2026. Until that date, the processing of personal data will be governed by the regulations currently in force, without prejudice to any additional measures and safeguards that BQSense SpA and the responsible company may have decided to implement in advance. References to the rights, procedures and powers of the Personal Data Protection Agency will apply as the corresponding regulations come into force.

Relevant definitions

For the purposes of this Policy, the following terms have the meaning indicated below, without prejudice to the legal definitions applicable under Law No. 21,719 and its implementing regulations:

• Personal data: any information linked or related to an identified or identifiable natural person.
• Sensitive personal data: personal data revealing racial or ethnic origin, religious or philosophical beliefs, union membership, ideology or political opinions, socioeconomic status, data concerning health or human biological profile, biometric data, data concerning a person’s sex life or sexual orientation, and data related to criminal or administrative offenses, or other categories expressly identified as such by law. [Verify the exact and complete list against the law currently in force before publishing.]
• Data subject: the natural person to whom the personal data being processed refers — in the context of this Policy, primarily the worker who uses the respirator fitted with the sensor.
• Data controller: the natural or legal person who, alone or jointly with others, decides on the purposes and essential means of processing personal data.
• Data processor: the natural or legal person who processes personal data on behalf of and following the instructions of the data controller.
• Sub-processor: the technology provider or other third party that the data processor engages to carry out, on its behalf, certain personal data processing operations.
• Processing: any operation or set of operations performed on personal data, such as its collection, recording, organization, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, assignment, transfer, interconnection, restriction, erasure or destruction.
• Legal basis or basis for legitimacy: the specific legal ground that authorizes a given processing of personal data, in accordance with the categories recognized by applicable law (among others, compliance with a legal obligation, performance of a contractual or employment relationship, legitimate interest, or the data subject’s consent).
• Consent: any free, specific, informed, prior and unambiguous expression of will by the data subject, by which they authorize the processing of their personal data for one or more specified purposes.
• Anonymization: an irreversible procedure that reasonably prevents the information from being linked to a specific or identifiable person. The mere replacement of a name, national ID number or other identifier with a code will not be considered anonymization when additional information exists that allows the data subject to be re-identified.
• Pseudonymization: the processing of personal data in such a way that it can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures designed to prevent re-identification. Unlike anonymized data, pseudonymized data remains personal data.
• International data transfer: any disclosure of personal data to a recipient located outside the territory of Chile, including storage or processing on servers or infrastructure located abroad.
• Data protection impact assessment: the prior analysis intended to identify and mitigate risks to the rights of data subjects that may arise from a personal data processing operation that, due to its nature, scope or purpose, presents a high risk.

2. Data controller and data processor

In each implementation, it must be expressly identified who determines the purposes and essential means of the personal data processing.

When the employing or contracting company determines the purposes for which the system will be used, that company will have the status of data controller.

BQSense SpA provides the technology services necessary for the application and platform to function and generally acts as data processor, following the instructions of the data controller.

BQSense SpA will act as data processor with respect to the operations it carries out on behalf of the data controller and will process data exclusively in accordance with the controller’s documented instructions and for the purposes covered by the contracted service.

BQSense SpA will not use personal data processed on behalf of the data controller for its own purposes incompatible with the engagement.

If BQSense SpA autonomously determines a purpose or means of processing other than those established by the data controller, the legal capacity in which it will act with respect to that processing must first be determined, and the corresponding information and legitimacy obligations must be met separately.

3. Categories of data processed

The system may process the following categories of data:

3.1. Identification and authentication data

• National ID number, user ID or other identifier assigned by the company.
• Credentials required to authenticate the user.
• Information related to the status and outcome of authentication.

The password is used to validate access. The mobile application must not store it in readable text or use it for purposes other than authentication.

3.2. Data from the sensor

• Temperature measured inside the respirator.
• Pressure measured inside the respirator.
• Humidity measured inside the respirator.
• Date and time of the measurements.
• Sensor or respirator identifier.
• Connection, transmission and operating status of the device.
• Operational alerts generated from the measurements.

When these measurements are linked to an identified or identifiable worker, they constitute personal data.

3.3. Technical data

To operate and protect the system, technical data such as the following may be processed:

• IP address.
• Application and operating system version.
• Technical device identifiers.
• Token used to send notifications.
• Access, connection, error and security logs.
• Date, time and duration of sessions.

3.4. Derived data and system results

Based on the measurements obtained from the sensor, the system may generate, depending on the features enabled in each implementation:

• Indicators related to the fit or seal between the face and the respirator.
• Indicators or estimates related to the status, saturation or remaining service life of the filters.
• Alerts associated with the operation or use of the respirator.
• Indicators derived from the respiratory signal necessary for the operation of enabled features.
• Historical records and trends associated with the above indicators.
• Confidence level or other technical parameters generated by the algorithms, when necessary to interpret the result.

Derived data linked to an identified or identifiable worker has the status of personal data and will be subject to the same protection measures applicable to the data that gave rise to it.

No indicators will be generated to evaluate a worker’s productivity, job performance, conduct, medical fitness or professional performance.

4. Mobile device permissions

• The application uses Bluetooth to communicate with the sensor.
• Depending on the Android version, the operating system may request permissions related to nearby devices or location to enable certain Bluetooth functions.
• BQSense SpA does not use these permissions to obtain, record, store or transmit the worker’s geographic location.
• The application does not access the microphone, camera, GPS, accelerometer or other phone sensors, unless a future feature is expressly disclosed and enabled in accordance with applicable law.
• The system does not build, store or transmit a location history based on these permissions.
• If a geolocation feature is incorporated in the future, the data subject will be informed in advance, clearly indicating the type of geolocation data processed, the purpose and duration of processing, the applicable legal basis, and whether such data will be disclosed or transferred to third parties.

5. Source of the data

The data processed may come from:

• The sensor installed on the respirator.
• The mobile application.
• The employing or contracting company.
• The worker themselves.
• Technical logs generated by the platform during use.

The data is not obtained from publicly accessible sources.

6. Purposes of processing

The data will be processed exclusively to:

• Verify the operational functioning of the respirator and the sensor.
• Display measurements in real time.
• Maintain a historical record for the authorized period.
• Detect previously defined operating conditions.
• Generate alerts related to the operation of the respirator.
• Allow authorized users to view information.
• Maintain the continuity, availability and security of the service.
• Diagnose technical failures and provide support.
• Comply with legal obligations or requirements from competent authorities.
• Generate statistics using previously anonymized data.

The data will not be used for advertising, marketing, commercial tracking, or the sale of personal information.

Any use for a different purpose must be disclosed in advance and have a valid legal basis.

Personal data obtained through the system will not be used to evaluate a worker’s productivity or job performance, apply disciplinary measures, determine compensation, make hiring or termination decisions, or for general surveillance of their conduct.

Nor will the data be used to train or develop artificial intelligence models for BQSense SpA’s own purposes, unless the data has been previously and irreversibly anonymized, or an independent legal basis exists that has been previously disclosed to the data subject and authorized where applicable.

7. Legal basis for processing

The applicable legal basis will be determined by the data controller before the system is implemented and will be clearly and specifically disclosed to workers.

The basis for legitimacy may differ depending on the category of data and the purpose for which it is processed. The data controller will keep available information identifying, for each relevant processing operation:

• The purpose of the processing.
• The categories of data used.
• The applicable legal basis.
• The recipients or categories of recipients.
• The corresponding retention period.

The bases for legitimacy mentioned above will not be applied indiscriminately to all categories of data. When a processing operation involves sensitive personal data, the special rules provided for that category of data will apply and, where applicable, those specifically applicable to data concerning health or human biological profile.

In particular, satisfying a legitimate interest under the general rules applicable to personal data will not, by itself, be used to justify the processing of sensitive personal data when the law establishes special requirements for such data.

When processing is based on compliance with a legal obligation, the data controller must identify the regulation that supports such processing.

When processing is based on a legitimate interest, the legitimate interest pursued must be identified, and it must be assessed in advance that such interest does not improperly override the rights and freedoms of workers.

When processing is based on consent, such consent must be free, specific, informed, prior and unambiguous, and may be withdrawn in accordance with applicable law.

Processing will not be deemed authorized merely by using the application, receiving the device, or generally accepting this Privacy Policy.

Due to the employment context in which the system may be used, consent will not be used as the general basis for monitoring when the circumstances of the employment relationship prevent it from being considered genuinely free. Where consent is required for a specific feature, the data controller must ensure that it meets the conditions required by applicable law.

8. Nature of the measurements

The pressure, temperature and humidity measurements obtained inside the respirator are primarily intended to assess the operating conditions of the respiratory protection equipment and enable the operation of the system’s algorithms.

Based on these measurements, the system may generate indicators related to the operation and use of the respirator, such as face-to-respirator fit status, conditions associated with filter status, and operational alerts.

When an enabled feature processes signals to obtain indicators related to the user’s respiratory dynamics, such as respiratory rate or other derived parameters, such data will be expressly identified in the information provided to the data subject and will be subject to the measures and bases for legitimacy applicable according to its nature.

The system is not intended to diagnose diseases, determine pathologies, establish a person’s medical or occupational fitness, or replace evaluations performed by health professionals.

When, due to its nature, purpose or capacity to reveal information about a worker’s health status or biological profile, such data must be considered sensitive personal data, its processing will be subject to the special conditions, limitations and safeguards established by applicable law.

In particular, the processing of sensitive personal data related to health or biological profile obtained in the employment context will only be carried out when there is a legal basis that allows such processing in accordance with the special rules applicable to this category of data.

Unless a specific legal basis exists that allows otherwise, the system’s features will be aimed at generating operational indicators related to the respirator and personal protective equipment, avoiding the use of measurements to infer diseases, diagnoses or medical conditions of workers.

9. Background processing

While the worker keeps the sensor connected, the application may continue to receive, temporarily store and transmit measurements in the background.

This processing will be limited to what is necessary to maintain the continuity of the disclosed monitoring.

10. Access and recipients

The following may access the data, only to the extent necessary:

• Workers may access their own data through the features available in the system. The absence or unavailability of a direct-access feature in the application will not limit the exercise of the rights recognized to the data subject by law.
• Supervisors and personnel expressly authorized by the data controller.
• Authorized BQSense SpA personnel who must provide support, maintain the platform, or investigate incidents.
• Technology providers acting as sub-processors.
• Public or judicial authorities where a legal obligation exists.

Access permissions must be assigned according to each user’s role and reviewed periodically.

Information will not be disclosed to persons who do not need to know it for the purposes described.

BQSense SpA may use technology providers acting as sub-processors only when permitted by the contract entered into with the data controller and when the required authorizations are in place.

Sub-processors will be subject to data protection obligations compatible with those assumed by BQSense SpA.

BQSense SpA will maintain an up-to-date list of the main providers involved in personal data processing and will make it available to the data controller.

In accordance with the principle of minimum necessary access, supervisory profiles will only view the information required for the purposes of safety and management of personal protective equipment. Access to raw measurements, respiratory indicators or other more granular information will be restricted to those profiles for which it is strictly necessary and legally authorized.

11. Technology providers

The system uses external technology providers for certain functions necessary to provide the service. An up-to-date list of these providers, including the service used, its purpose, the categories of data involved and, where applicable, the existence of international transfers, will be permanently available at [URL / PROVIDERS ANNEX].

BQSense SpA will only use providers whose participation is authorized under the contract entered into with the data controller and who are subject to adequate confidentiality, security and data protection obligations.

12. International transfers

Certain technology providers used to deliver the service may process personal data from countries other than Chile.

Before carrying out an international transfer of personal data, the data controller and, where applicable, BQSense SpA will verify the existence of a valid legal basis for the processing and of a mechanism enabling the transfer in accordance with applicable law.

Up-to-date information regarding recipient providers, the countries or international organizations involved, the categories of data transferred, the purpose of the transfer and, where applicable, the safeguards enabling the international transfer will be permanently accessible at [URL / PROVIDERS AND TRANSFERS ANNEX] and may also be requested through the channels indicated in this Policy.

Where applicable, the information provided to the data subject will indicate whether the recipient country has an adequate level of protection or the safeguards used to carry out the transfer.

13. Storage and retention

Personal data will be retained only for the period necessary to fulfill the purposes for which it was collected.

When the mobile device temporarily lacks an internet connection, measurements may be stored locally for the time strictly necessary for their transmission to the server. Once synchronization has been correctly confirmed, the temporarily stored data will be deleted in accordance with the system’s defined configuration.

The periods applicable in each implementation will be disclosed by the data controller and will be defined, at a minimum, for the following categories:

• Raw data from the sensor: 3 months.
• Derived indicators and results: 3 months.
• Operational alerts: 3 months.
• Access and security logs: 3 months.
• Account data: while the account remains active and up to 3 months after its deactivation or the termination of the employment or contractual relationship that gave rise to it.
• Backup copies: 3 months.

When the retention period expires, data will be securely deleted or irreversibly anonymized, unless a legal obligation justifies its retention for a longer period.

Data contained in backups will be deleted according to the regular backup rotation cycle and will not be restored to active systems unless necessary for incident recovery.

14. Security

BQSense SpA and the data controller will apply technical and organizational measures appropriate to the level of risk. These measures include, as applicable:

• Encryption of communications via HTTPS.
• Management of users, credentials and permissions.
• Role-based access restrictions.
• Logging of access and security events.
• Backup and recovery mechanisms.
• Updating and maintenance of system components.
• Incident management procedures.
• Periodic review of the effectiveness of implemented measures.

No system can eliminate all risks entirely. Users must keep their credentials confidential and immediately report any suspected unauthorized access.

Depending on the level of risk and the architecture used, measures may include:

• Encryption of data in transit.
• Encryption of stored information when appropriate.
• Pseudonymization of identifiers.
• Logical separation of information corresponding to different clients.
• Enhanced authentication for administrative or privileged accounts.
• Principle of least privilege and role-based access control.
• Logging and auditing of relevant access.
• Vulnerability management and component updates.
• Backup and restoration procedures.
• Periodic testing of the effectiveness of security measures.
• Documented incident response procedures.

15. Data protection by design and by default

BQSense SpA and the data controller, within the scope of their respective obligations, will apply appropriate technical and organizational measures so that, by design and by default, only the personal data strictly necessary for each purpose is collected, used, stored and made accessible.

Depending on the characteristics of the implementation, measures such as the following may be applied:

• Pseudonymization of identifiers.
• Logical separation between identifying information and sensor-derived data.
• Local processing when technically appropriate.
• Deletion of temporary data once its purpose has been fulfilled.
• Role-based viewing restrictions.
• Configuration of automatic deletion periods.
• Minimization of information available to supervisors.

16. Security incidents

BQSense SpA will maintain procedures to detect, log, analyze and manage security incidents that may affect personal data.

When BQSense SpA acts as data processor and becomes aware of a security breach related to data processed on behalf of the data controller, it will notify the controller without undue delay and provide the available information necessary for the controller to assess and fulfill its legal obligations.

The data controller will assess the incident and, where applicable, notify the Personal Data Protection Agency and affected data subjects in accordance with applicable law.

When a breach affects categories of data for which the law requires direct notification to data subjects, the data controller will make such notification under the terms and conditions established by applicable regulations, with BQSense SpA’s collaboration where applicable.

BQSense SpA will collaborate with the data controller in investigating, containing, mitigating, documenting and preventing future incidents.

17. Automated processing, alerts and profiling

The system uses automated processing and algorithms to analyze certain measurements and generate indicators and alerts related to the operation and use of the respirator.

The automatic generation of an alert or indicator does not, by itself, constitute a decision regarding the worker.

The system will not automatically make disciplinary, contractual, compensation, medical, work-capacity, performance-evaluation, hiring or termination decisions regarding workers.

Alerts, indicators and estimates generated by the system are intended to support respiratory safety and personal protective equipment management.

The data subject has the right to object to, and not be subject to, decisions based solely on automated processing of their personal data, including profiling, when such decisions produce legal effects or significantly affect them, under the terms provided by applicable law.

When such a decision exceptionally applies under the law, the controller will adopt appropriate safeguards, including the data subject’s right to receive information and an explanation of the outcome, to request human intervention, to express their point of view, and to request a review of the decision.

In any case, alerts generated by the system are intended to support safety management and will not, by themselves, constitute grounds for a disciplinary, contractual, compensation, medical or performance-evaluation decision.

BQSense SpA and the data controller will adopt measures to prevent features designed for respiratory safety from being used in ways incompatible with general surveillance or evaluation of job performance.

18. Rights of data subjects

Workers may exercise, where applicable, the following rights:

• Access their personal data and obtain information about its processing.
• Request the rectification of inaccurate, outdated or incomplete data.
• Request the erasure of their data when a legal ground applies.
• Object to specific processing.
• Request the portability of their data when the processing is automated and based on consent, under the terms provided.
• Request the temporary blocking of processing while a request for rectification, erasure or objection is resolved.
• Withdraw their consent, when processing is based on consent.
• File a complaint with the Personal Data Protection Agency when a request is denied or not answered in a timely manner.

Requests must be submitted to the data controller through the channels disclosed for that purpose.

When BQSense SpA receives a request relating to data for which it acts exclusively as processor, it will forward it to the data controller and assist in responding to it.

Upon receiving a request, the controller will acknowledge receipt and respond within the period established by applicable law.

Under the regime established by Law No. 21,719, the controller must generally respond within thirty calendar days of receiving the request, a period that may be extended once for up to thirty additional calendar days.

When a temporary blocking request associated with a request for rectification, erasure or objection is duly justified, the controller must rule on that blocking request within two business days of receiving it, in accordance with applicable law.

19. Confidentiality

Persons with access to the data must maintain strict confidentiality, even after their employment, contractual or service relationship has ended.

20. Minors

The system is intended for adult workers and has not been designed to process data of children or adolescents.

21. Changes to this policy

This policy may be updated when features, providers, purposes, legal bases or processing conditions change.

The current version, its date and the main changes made will be permanently available in the application, the web platform or BQSense SpA’s official website.

When changes substantially affect workers’ rights or introduce new purposes, they will be disclosed before the new processing begins.

22. Use of data for development and technological improvement

Personal data processed on behalf of a data controller will not be used by BQSense SpA to train artificial intelligence models, develop independent products, or conduct its own research outside the purposes of the engagement, unless an independent legal basis exists and data subjects have been previously informed where applicable.

BQSense SpA may use previously and irreversibly anonymized information for statistical purposes, technological improvement, research and analysis, provided that such information has ceased to constitute personal data under applicable law.

23. Limitations on use in the employment context

The system has been designed as a tool to support respiratory protection safety and management.

Within the scope of the features, purposes and processing conditions covered by this Policy, data generated by the system will not be used to:

• Measure productivity or job performance.
• Monitor working hours other than those strictly necessary for the disclosed safety purposes.
• Evaluate professional performance.
• Determine compensation, incentives or bonuses.
• Support or justify disciplinary measures against the worker.
• Select workers for hiring, promotion or termination.
• Infer illnesses, medical conditions or work fitness.
• Track the worker’s location.

The future addition of a different purpose will require a prior legal assessment, the determination of a valid basis for legitimacy, an update to the information provided to data subjects and, where applicable, a data protection impact assessment. None of the foregoing will permit processing that is prohibited by applicable law.

24. Contact

For inquiries about privacy, security or personal data processing:

The contact details of the responsible employing company will be available in the application, the platform, or the privacy notice provided to the worker.