Introduction:

Rasida Udya & Associated Authorised Team (”we, “us”, or “our”), takes your privacy seriously. This Privacy Policy (the “Policy”) explains our data protection commitment and practices and describes the types of information we may process when you install and use our health and heart rate analysis application for mobile devices.

When we refer to personal data (or personal information), we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data or to an identification number (“Personal Data”).

Our Privacy Policy applies to all users and others who access health and our app’s (”Users”) and/or persons whose Personal Data we may process as a result of our business activities. We also refer to such persons by “you” in the text.

PLEASE READ THE FOLLOWING PRIVACY POLICY FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED CAREFULLY.

SCOPE:

This Privacy Policy applies to Personal Data obtained through our app or when you otherwise interact with us.

Our app may contain links to other websites not under our control. We are not responsible for other websites’ information practices or content. You should always review the policies of third-party products and services to make sure you are comfortable with how they collect and use your information.

INFORMATION WE PROCESS:

Your privacy is our high priority, so we prefer, to the maximum possible extent, using instruments that disable the collection of clearly identifiable information and provide us with information in aggregated, encrypted, anonymized, and/or pseudonymized (non-identifiable) form. However, we understand that some categories of such information we use may be deemed Personal Data, in particular, for the purposes of GDPR. With regard to such Personal Data, the rules set out in this Privacy Policy are always strictly followed.

Information that you submit

You may provide personal information directly when you use our app. This information is necessary to adequately perform the contract between you and us. Without such information, it is impossible to provide the complete functionality of our app and perform the requested services. Depending on our app’s (iHealth: Smart Health Monitor) functionality, the following information can be processed:

General Information. You may fill it in when you choose to track physical parameters for your convenience, and/or share by connecting the other app to our app (iHealth: Smart Health Monitor):

• Gender;
• Date of birth or age;
• Race;
• Weight;
• Height.

Contact Information. You may share it when you log in or create a profile in our app or contact us via email:

• Name;
• E-mail address, and any other content included in the email;
• Password or passcode;
• Other information you decide to share when you log in via third-party services; it may also include technical identifiers necessary for the authentication service to run.

Health and well-being. Our app may estimate various metrics such as:

• Heart rate;
• Heart rate variability.

These indicators are based on RR intervals and other metrics our app collects when executing a measurement. You can always decline to save a measurement or delete a previously saved measurement through our app.

For measuring, technically accesses your camera required as a light sensor to estimate your heart rate. During a measurement, images from the camera feed are processed locally on your device and deleted immediately afterward. We cannot collect, store or use the data contained in your camera roll.

The health and well-being information you submit is stored locally on your device. This information is never disclosed to third parties (except our authorized service providers) unless you share it yourself.

You can remove or alter your personal information at any time. Once you uninstall “Our App”, your personal information (including Personal Data) will be stored and used for a period needed to achieve the purposes set out in this Policy.

Information you submit during the onboarding process in “Our App”. “Our App” may include functionality for personalizing “Our App” prior to full access to Our App’s features. While completing the quiz, you may need to pick or submit some categories of Personal Data, so we can personalize “Our App” for you. At this stage, we will not access or collect your health, gender, age, or other sensitive information about you and it will be processed locally on your device. Instead, we will rely on a contract basis and our legitimate interest to process some technical identifiers and log information necessary for “Our App” to function and for us to provide you with the requested service. Once you complete the onboarding process we will ask you for your consent to process the full scope of Personal Data for the purposes described in this Policy.

Other data you may submit to us. Also, we may collect other data that you submit to “Our App” as you participate in any interactive features of them, participate in a survey, contest, promotion, sweepstakes, activity, or event, apply for a job, request customer support, communicate with us via third party social media sites or otherwise communicate with us.

Other persons’ Personal Data. If you are providing information (including Personal Data) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Data as described in this Privacy Policy.

Information collected automatically:

Information from the app. When you use “Our App”, information about your device and user behavior may be collected and processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual. However, a set of this information may allow us to identify you as a separate user of “Our App”, therefore we treat such information as Personal Data and protect it as prescribed by law. We process Personal Data based on the contract between you and us or our legitimate interest in improving “Our App” and giving our users the best experience. If we do not access such data, we may not be able to provide you with all “Our App’s” features. To process your Personal Data for our marketing purposes, we rely either on legitimate interest or your consent basis, as the case may be.

Device Details. When you use a mobile device to access “Our App”, some details about your device are reported subject to your privacy choices as provided by iOS functionality. For example, device identifiers and other metadata. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, uniquely identifying your mobile device (but not your personality). Device identifier enables generalized reporting and analytics. In this regard, the following information may be collected and processed:

• Information about the device itself: type of your device, type of operating system, and its version, model, and manufacturer.
• Information about the internet connection: mobile carrier, IP address, timestamp, and duration of sessions.
• Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, and time zone.
• Device identifiers and technical identifiers (e.g. IDFA).
• Information about the app: name, API key (identifier for application), version, and app properties can be reported for automated processing and analysis.
• Cookies and similar technologies. When you use “Our App”, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information downloaded to your device when you access “Our App”. The text file is sent back to the server each time you use “Our App”. This enables us to operate “Our App” more effectively. For example, we will know how many users access specific areas or features within “Our App” and which links they clicked on. We use this aggregated information to understand and optimize how “Our App” is used, improve our marketing efforts, and provide content and features that interest you. We may ask advertisers or other partners to serve ads or services to “Our App”, which may use cookies or similar technologies.
• Log file information. Log file information is automatically reported each time you request to access “Our App”. It can also be provided when “Our App” is installed on your device. When you use “Our App”, analytics tools automatically record certain log file information, including the time and date when you start and stop using “Our App” and how you interact with “Our App”.
• In-app events. When you use “Our App”, analytics tools automatically record in-app information (tutorial steps, leveling up, payments, in-app purchases, custom events, progression events, etc.).

Please remember that some services are engaged in personal data profiling and may obtain information related to your personality and/or your device by using technologies that do not belong to our scope of responsibility. For example, when your user ID is linked to your Facebook account, Facebook may use your device information in association with categorized data already recorded in its databases (e.g. your age, gender or other demographic indication). We do not control, supervise or stand surety for how the third parties process your personal data that might be collected by their means (not through “Our App”). Any information request regarding the disclosure of your personal information should be directed to such third parties.

Payment Information. Our e-commerce providers responsible for billing, processing, and charging for in-app purchases and web subscriptions, handle your Personal Data and keep it safe and secure. We cannot access or use your credit or debit card information.

Information received from third parties:

We may also obtain information from third parties, such as:

• Our authorized resellers, distributors, and partners if there is a lawful basis to do so. For example, we get analytic information from the Apple App Store.
• Other third parties, such as email campaigns, marketing partners, and publicly available sources. We may use this information to enhance the information we already maintain about you, in addition to other purposes described in this Privacy Policy.
• Social media and authentication services. We may have access to certain information from a third-party social media or authentication service if you log into “Our App” through the service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party social or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third-party service, you authorize us to access and store your name, email address(es), profile picture URL, and other information that the third-party service makes available to us, and to use and disclose it under this Privacy Policy. You should check your privacy settings on these third-party services to understand and change the information sent to us through these services.

THE LEGAL BASES AND PURPOSES OF PROCESSING YOUR PERSONAL DATA

Without first notifying you, we will not collect or use your Personal Data. We will handle your Personal Data using one or more of the following legal bases, depending on which features of “Our App” you use:

Contract. We use your Personal Data to fulfill our contractual obligations and provide the services to you.

Consent. For example, after installing “Our App” on the welcome screen, we may ask you to permit us to process your Personal Data.

Legitimate interest. We may process your Personal Data in relation to our interests in providing the services to you, our legitimate commercial interests, our interest in protecting the security and integrity of the services, and wider societal benefits, as allowed under the law.

Legal obligations. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.

Our mission is to improve “Our App” and constantly provide new user experiences. As part of this mission, we may use your Personal Data for the following purposes and under the applicable legal basis:

• To make our service available
• To communicate with you and send you system and transactional messages
• To improve, test, and monitor the effectiveness of “Our App”
• To provide you with a personalized experience within “Our App”
• To send promotional communications
• To promote and market “Our App”
• To enable interest-based (behavioral) advertising or other targeted content
• For internal business purposes
• To keep basic data to identify you and prevent further unwanted processing
• To verify your age
• To comply with legal obligations and legal processes and respond to requests from public and government authorities, including public and government authorities outside your country of residence
• To enforce the Terms of Use, protect our operations, protect our rights, privacy, the safety of property, and/or that of you or others, and allow us to pursue available remedies or limit the damages that we may sustain

If we need to process your information for a specific purpose not clearly outlined in this Policy and not concerning our ability to provide you with all requested services and features of “Our App”, or a justified legitimate interest, we will ask you for consent while amending the list of purposes above.

Where required by law, we will only send you marketing communications if you consent to us doing so when you provide us with your Personal Data or if we obtain your consent to receive marketing information separately. You may opt out of receiving such emails by following the instructions in each promotional email we send you or, if this doesn’t work, by contacting us at our email or support. We will continue to contact you via email regarding your use of “Our App” and to respond to your requests only.

SHARING OF YOUR INFORMATION

General principles and prohibitions. We will only share your information with third parties in the ways described in this Privacy Policy. Without your permission, we do not share Personal Data with third parties for their marketing purposes (including direct marketing). We do not share identifiable health data with third parties for marketing and other purposes not related to providing you access to “Our App”. We will not rent or sell your Personal Data to any third parties.

Personnel. We share your Personal Data only with our employees and contractors, agents, and auditors who need to know or otherwise access Personal Data according to their scope of professional responsibilities and who are bound in writing by confidentiality and other obligations sufficient to protect Personal Data under this Privacy Policy.

Protection measures. While integrating external services, we choose service providers that can assure they apply all necessary technical and organizational measures to protect users’ personal data. However, we cannot guarantee the security of any information transmitted from us to any such processor due to technical accidents that may arise out of our reasonable control. Provided that we followed all demands of applicable personal data protection legislation, we are not responsible for any accidental loss or unauthorized access to your Personal Data through the fault of third parties.

Disclosures made by you

Certain features of “Our App” allow you to make some of your measurements public, in which case it will become readily accessible to anyone. We urge you to consider the sensitivity of any data you share at your discretion.

Service providers and subcontractors

Processing to make the app run

We occasionally engage outside businesses to process your Personal Data on our behalf. They are the “processors” of your Personal Data. Processors assist us in managing “Our App”, facilitate our communication with you, and carry out other related tasks. To complete these objectives, they may process specific Personal Data on our behalf, acting under our instructions and subject to demands of applicable data protection laws. To the degree applicable legislation requires, we will execute data processing agreements with our processors and maintain responsibility for their actions.

Processing for marketing and marketing analytics purposes

With your consent, we may share some of your non-health Personal Data with our marketing and promotional service providers. We do this to market “Our App”, to help new users find out about us, and to develop our business by increasing awareness about “Our App”.

These lists may be amended or modified from time to time according to our business needs, on our sole discretion and without giving notice to you, but provided that such extension in sharing of your Personal Data do not require your consent as legal basis for processing. If so, we will ask you for consent while informing you of modifications for further processing.

Third-party websites and social media widgets

“Our App” may contain links to third-party websites/services, or you may login in “Our App” via a third-party service. We are not responsible for the privacy practices of these third-party sites or services linked to or from “Our App”, including the information or content contained within them. “Our App” may also include social media features, such as Twitter, Facebook, and Instagram buttons. These features may collect your IP address and which page you visit on our site and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy statements of the company providing them.

Business transfers, legal requirements, and protection of our rights

We may disclose your personal information if it is needed for objective reasons, due to the public interest, or in other unforeseen circumstances:

• to the extent permitted and as restricted by law, in response to subpoenas, court orders, or legal processes, including to meet national security or law enforcement requirements;
• when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or enforce our agreements, policies, and terms of service;
• if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via prominent notice in “Our App” of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.

Depending on the circumstances, we may rely on legitimate interest or legal obligation as a legal basis for the above processing activities.

Aggregated or anonymized data

We may share aggregated or anonymized information that does not directly identify you with other third parties, not mentioned above, such as our partners and research entities, for statistical, analytic, and scientific purposes. Anonymization and further use of anonymized information are done under our legitimate interest and aimed at contributing scientific value in our activities to increase awareness about heart health and general well-being across society worldwide.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

We work in the cross-border area and provide “Our App” to our users around the world.

We and third-party organizations that provide data processing technologies for “Our App” or our third-party advertising partners may transfer the processed information across borders and from your country or jurisdiction to other countries or jurisdictions worldwide.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction. This means that your personal information can be transferred to a third country, a territory, or one or more specified sectors within that third country or to an international organization where data protection and confidentiality regulations may not provide the same level of personal data protection as your country does.

We try to ensure that the recipient of any personal data provides proper protection of the personal data received, in accordance with the current legislation on protecting such information. By agreeing with this Policy, you agree that we may transfer your personal data to any third country, a territory, or one or more specified sectors within that third country or to the international organization.

For the purposes of data processing, we recourse to the third-party services or the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data – if possible – before sending it to our service providers. Please note that we cooperate only with those service providers that have passed our security and reliability check. If applicable, we are party to data transfer agreements/data processing addendums or equivalent legal instruments with each of our service providers, and we will (i) keep each document up to date with current law and (ii) only engage in personally identifiable information transfers from safeguards area to outside safeguards area in accordance with such an agreement or an alternative means of transfer in compliance with data protection legislation. Where we transfer your Personal Data as described above, we will take steps to ensure that your Personal Data receive adequate security protection where it is processed, and your rights continue to be protected pursuant to the applicable data protection law, including through the use of Standard Contractual Clauses approved by the European Commission.

RETENTION

We generally retain your personal information for as long as is necessary for performing the functional service of “Our App” and to comply with our legal obligations. If you no longer want us to use your Personal Data that we physically access and store, you can uninstall “Our App”.

Even if you requested the erasure or deleted your account or “Our App”, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if the information is necessary to comply with legal obligations (taxation, accounting, audit), or in order to maintain safety and data backup settings, prevent fraud or other malicious acts, or keep your choices about privacy, for example, if you unsubscribed from our marketing communications.

SECURITY

The security of your personal information is highly important to us. Services we use to maintain “Our App” follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Please note that “Our App” is available for download via authorized App Store (Apple App Store) only; if you download a copy of “Our App” via other sources, we cannot guarantee the availability, security and proper functioning of such a product.

We take reasonable and appropriate measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your Personal Data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

If you suspect or become aware of any security incident within “Our App”, please let us know at our support email id or support page.

CHILDREN’S PRIVACY

“Our App” is not intended for children and we do not knowingly collect or solicit any personal information from children under 13. If we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at our support email id or page.

CHANGES TO THE PRIVACY POLICY

This Privacy Policy is updated regularly.

Whenever we change this Privacy Policy, we will post those changes to this Privacy Policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

HOW TO CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us via email at connect.healthtracker@gmail.com or app support page.