Effective as of May 25, 2018
When you sign up to use the App, we may collect Personal Data about you such as:
When you use the App, you may choose to provide personal information about your health such as:
You will also have an option to permit us to import into the App data from third-party services such as Apple HealthKit and Google Fit, among others. Such imported information may include: sports activities, weight, calories burnt, heartbeat rate, number of steps/distance travelled, and other information about your health.
When you access or use the App, we may automatically collect the following information:
YOUR CONSENT. By creating a profile in the App, you explicitly consent that:
II. PERSONAL DATA YOU PROVIDE TO US THROUGH THE ACCOUNT CREATION PROCESS INCLUDES PERSONAL DATA YOU ENTER INTO THE APP, SUCH AS YOUR ACCOUNT DATA (E.G. YOUR NAME AND EMAIL ADDRESS), AND YOUR HEALTH DATA (E.G. BODY MEASUREMENTS, PHYSICAL ACTIVITY AND OTHERS). DEPENDING ON THE DATA YOU PROVIDE, IT MAY ALSO CONTAIN INFORMATION ABOUT YOUR GENERAL HEALTH (E.G. WEIGHT, BODY TEMPERATURE, AND OTHERS).
III. WE WILL NOT TRANSMIT ANY OF YOUR PERSONAL DATA TO THIRD PARTIES, EXCEPT IF IT IS REQUIRED TO PROVIDE THE SERVICE TO YOU (E.G. TECHNICAL SERVICE PROVIDERS), UNLESS WE HAVE ASKED FOR YOUR EXPLICIT CONSENT.
We may use your information, including your Personal Data, for the following purposes:
You are able to modify, correct, erase, and update your Personal Data by writing us at firstname.lastname@example.org.
You have a right to access your Personal Data you insert into the App and ask us about what king of Personal Data we have about you. You can do this by using the app settings or by writing us at email@example.com.
Individuals residing in the countries of the European Union have certain statutory rights in relation to their personal data introduced by the General Data Protection Regulation (the “GDPR”). Subject to any exemptions provided by law, you may have the right to request access to Personal data (including in a structured and portable form), as well as to seek to update, delete or correct Personal data:
Please keep in mind that in case of a vague access, erasure, objection request or any other request in exercise of the mentioned rights we may engage the individual in a dialogue so as to better understand the motivation for the request and to locate responsive information. In case this is impossible, we reserve the right to refuse granting your request.
Following the provisions of GDPR we might also require you to prove your identity (for example, by requesting an ID or any other proof of identity) in order for you to invoke the mentioned rights, specifically if you exercise them in respect to special categories of Personal Data like data about health. This is made to ensure that no rights of third parties are violated by your request, and the rights described in this section are exercised by an actual Personal Data subject or an authorized person.
Please note that we will grant your request within 30 days after receiving it, but it may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems - this is due to the size and complexity of the systems we use to store data.
Among others we may share your Personal Data with the following third-party services:
Information Posted by User. The App features several community areas and other public forums where users with similar interests or medical conditions can share information and support one another or where users can post questions for experts to answer. We also offer online discussions which may be moderated by healthcare experts. Our communities are open to [the public/the App community] and should not be considered private.
Any information (including Personal Data) you share in any online community area or online discussion is by design open to the public and is not private. You should think carefully before posting any Personal Data in any public forum. What you post can be seen, disclosed to, or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines.
If you mistakenly post Personal Data in our community areas and would like it removed, you can send us an email as listed below to request that we remove it. In some cases, we may not be able to remove your Personal Data, e.g. for technical reasons.
You should be aware that we may retain certain Personal Data and other information after your account has been terminated in an aggregated, anonymized form. Any posts or comments you submit may remain visible if and after you delete your account. We are not obligated to remove your posts or comments. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.
If you remove data from your account, you will no longer see it in the App, but some backups of the data may remain in our archive servers for a reasonable period of time due to technical solutions we use. However, we undertake to delete any such backups within a reasonable period of time.
If you choose to delete the App, deactivate your account, we retain your Personal data for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
We take reasonable steps in order to ensure compliance of such third parties with any applicable laws that might govern processing of your Personal Data. For example, for the EU residents’ Personal Data we make reasonable efforts to ensure that such third parties are GDPR compliant and have GDPR compliant privacy policies in place.
We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health). Among others, we utilize the following information security measures to protect your Personal Data:
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable and appropriate steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
General age limitation. We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 13 years old. The App does not collect Personal Data from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the App, please contact us at firstname.lastname@example.org and we will take required steps to delete such information and (or) delete her account.
Age limitation for EU residents. Due to requirements of the GDPR you shall be at least 16 years old in order to use the App. To the extent prohibited by applicable law, we do not allow use of the App by the EU residents younger than 16 years old. If you are aware of anyone younger than 16 using the App, please contact us at email@example.com and we will take steps to delete such information and (or) delete her account.
We may contact you from time to time via email to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you. You can always opt out of receiving emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting-out of these emails will not end transmission of important service-related emails that are necessary to your use of the App. If applicable laws prescribe so, certain exclusions may apply to the residents of some countries regarding an active opt-in for any email communications from us. We may ask such users at the registration screen to provide their consents for any such communications.
The Company is based the United States and the information we collect is governed by U.S. law. We use only such processors and storage providers that self-certified under EU-US Privacy Shield framework as, for example, AWS, or use any other admissible tools for secure and compliant processing of your Personal Data. See more about AWS data privacy compliance and data practices here.
In addition, you agree that information collected through the App may be stored and processed in Canada, where the Company currently rents servers.
The European Commission has so far recognized Canada (commercial organizations) and the US (limited to the EU-US Privacy Shield framework) as providing adequate protection for international data transfers.
To communicate with our Data Protection Officer, please email at firstname.lastname@example.org.
1013 Centre Road, Suite 403‑B Wilmington, DE 19805
Email: email@example.com or firstname.lastname@example.org
Our EU representative:
Agios Athanasios Street, Michael Angelo House, 4102, Limassol, Cyprus
Phone: +357 2 534 534 6