Privacy Policy

Introduction
The privacy of our users is very important for us, and we are committed to safeguarding their personal data. This policy will be applicable for European Countries subjected to GDPR. Here we describe the privacy practices for our devices, applications, software, websites, APIs, products, and services (the “Services”). You will learn about the data we collect, how we use it, the controls we give you over your information, and the measures we take to keep it safe.

Our Privacy Principles
We are committed to recognizing and respecting your privacy rights by keeping you informed and processing and protecting your personal data in compliance with applicable data protection laws and regulations (“Data Protection Laws”). Effective May 25th, 2018, if you are subject to European Union Data Protection Laws (“EU Users”), our processing of your personal data will comply with the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (“GDPR”).

1. INFORMATION THAT WE COLLECT FROM YOU
A. Account Information
Some information is required to create an account on our Services, such as your name, username, email address, password, date of birth, gender, height, weight, and in some cases your mobile telephone number. You may also choose to provide other types of information, such as your health and physical characteristics (eating habits, chronic diseases, alcohol consumption, cigarette consumption, nutrition choices, urinalysis (blood, leukocyte, bilirubin, urobilinogen, pH, nitrite, glucose, ketone, protein and specific gravity) advice choices, body type) and any other personally identifiable information you share through the Services.

B. Additional Information
If you contact us or participate in a survey, contest, or promotion, we collect the information you submit such as your name, contact information, and message. If you post information on public areas of the Services, that data may be collected and used by us, other users of the Services, and the public generally, such as reviews, comments, and user content. We strongly recommend that you do not post any information through the Services that allows strangers to identify or locate you or that you otherwise do not want to share with the public.

C. Information from Third-Party Services
If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address, and friend list. You may also choose to grant us access to your exercise or activity data from another service. You can stop sharing the information from the other service with us by removing our access to that other service.

D. Cookies
Vivoo may use cookies or other tracking technologies that are useful in order to assess the performance of the Website, Mobile App, and Services, including as part of Vivoo’s analytic practices or otherwise to improve the content, products or services offered through the Website, Mobile App, and Services. We might also use other third-party services to provide you with Vivoo Services. These services might set up their own cookies to remember you. Please note that we are not responsible for third party services’ cookie policies.

E. Health and Special Category Personal Information
As part of our product’s usage process, you will be required to share with us your urine examples. Additionally, as part of our Services, you may provide us with additional Sensitive Personal Information (“special category personal data”) which is related to your health. Such information may include your gender, height, weight, your health and physical characteristics (eating habits, chronic diseases, period schedule, alcohol consumption, cigarette consumption, nutrition choices, urinalysis (blood, leukocyte, bilirubin, urobilinogen, pH, nitrite, glucose, ketone, protein and specific gravity) advice choices, body type); and Any other personally identifiable health information you share through the Services. You may manually upload your health information to our website or mobile app. To the extent that information we collect is health data or another special category of personal data subject to the European Union’s General Data Protection Regulation (“GDPR”), we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data. By providing sensitive Personal Information to us (e.g. health information), you explicitly consent to the collection, use, and disclosure of your sensitive Personal Information in accordance with this Privacy Policy.

F. Device Information
We may also collect Personal Information from your device (e.g. geolocation data, IP address) and information on your activity on the Services (e.g. pages viewed, online browsing, clicks, actions etc.). You may refuse to disclose certain information, but please bear in mind this may result in preventing you from using our Services to some extent, and in some cases may result in your inability to use our Services.

2. HOW WE USE YOUR INFORMATION
When you allow us with your explicit consent we are processing your data for the following purposes:

A. Improving the Services
We and our service providers may use the data you provide or that is collected through the Services to operate and improve the Services, our other sites, applications, products, and services, to contact you from time to time to provide you with important information and notices relating to the Services, and to carry out obligations arising from any agreements between you and us.

B. Marketing and Promotions
We and our service providers may use the data you provide or that is collected through the Services to provide you with updates, offers, and promotions, where you have chosen to receive these. We may also use your information for marketing our own and our selected business partners’ products and services to you by email and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. If you wish to unsubscribe from receiving marketing communications from us by email, please follow the instructions contained in each email you receive from us describing how you can unsubscribe from receiving further marketing communications from us.

C. Advertising
The Services may be supported through advertising, and we may work with advertisers and advertising networks to provide advertising through the Services. We may provide these advertisers and advertising networks with the ability to collect data about how you interact with the Services and, if applicable, your mobile device. This data may include the unique device or advertising identifier associated with your device and your precise location data, in order to help analyze and serve targeted advertising on the Services and elsewhere (including third-party sites and applications). In addition, the Services may include third-party content and links to other third-party websites. These advertisers, advertising networks, and third parties may use cookies, pixels, and web beacons to track the actions of users online over time and across different websites or platforms in order to deliver targeted electronic advertisements to an individual user. We do not have access to or control over cookies, pixels or web beacons that third-party websites or partners may use. We are not responsible for the privacy practices or the content of these third-party websites. You are encouraged to review the privacy policies of the different websites that you visit.

D. Analytics Services
We may also work with third-party analytics companies to help us understand how the Services are being used, such as data collection, reporting, ad response measurement, website and mobile application analytics, and to assist with delivery of relevant marketing messages and advertisements. We may use Google Analytics, an analytics service provided by Google or other third-party analytics services providers (“Analytics Services”) to collect information about your use of the Services. These Analytics Services may collect information about the content you view and your system information and geographic information. The information generated by the Analytics Services about your use of the Services will be transmitted to and stored by the Analytics Services. The information collected by the Analytics Services allows us to analyze your use of the Services. We encourage you to review your device and Services settings to ensure they are consistent with your preferences, including with respect to the collection and use of information. You may be able to stop further collection of certain data by the Services by updating your applicable device settings, or you may uninstall the Services. In addition, you may choose not to share your location details by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider/carrier or device manufacturer.

E. Purchases and Payment Processors
If you make a purchase through the Services, you may be able to pay using a third-party payment service. All information collected by these third-party payment services for purposes of processing your payments is not available to us unless you have otherwise provided this information to us in connection with your use of the Services. Information collected from you by these third-party payment services is governed by the applicable third-party payment service’s privacy policy. You should review the applicable privacy policy prior to submitting any information to the applicable third-party payment service.

3. HOW WE SHARE YOUR INFORMATION WITH THIRD PARTIES
We may share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

We provide some of our services through contractual arrangements with affiliates, service providers, partners and other third parties. We and our service partners may use your personal information to operate our sites and to deliver their services. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on this site; release your contact information to the third party service provider to activate services that you subscribed to or to administer sweepstakes or third party services which you have entered into or requested, including, but not limited to, participation in promotional programs; and provide order information to third parties that help us provide customer service and to help third parties provide their services to and communicate with you. These affiliates and third-party service providers are not permitted to use personal information for any purposes other than to complete the order, assist you in participating in the particular service or promotional program, and communicating with you. We may disclose information in the aggregate to third parties relating to user behavior in connection with actual or prospective business relationship with those third parties, such as advertisers and content distributors. For example, we may disclose the number of users that have been exposed to, or clicked on, advertising banners.

We may use third-party advertising companies to serve ads when you visit the Vivoo Service. These companies may use information about Your Public Content (not including your name, address, email address, or telephone number) and Activity related to your use of the Vivoo Service to provide advertisements about goods and services of interest to you. We will encourage our service partners to adopt and post privacy policies. However, the use of your personal information by our service partners is governed by the privacy policies of those service partners and is not subject to our control. You acknowledge that we are not responsible for the violations caused by our service partners.

4. YOUR RIGHTS TO ACCESS AND CONTROL YOUR PERSONAL DATA
Please be advised that in case you allow Vivoo to collect and process certain personal data from you, you have the following rights:
Right of Access: You have the right to obtain from us confirmation as to whether or not personal data
concerning you are processed, and, where that is the case, you have the right to request and get access
to that personal data.
Right to Rectification: You have the right to obtain from us the rectification of inaccurate personal data and you have the right to provide additional personal data to complete any incomplete personal data.
Right to Erasure (“Right to be Forgotten”): In certain cases, you have the right to obtain from us the erasure of your personal data.
Right to Restriction of Processing: You have the right to obtain from us restriction of processing, applicable for a certain period and/or for certain situations. Right to Data Portability: You have the right to receive from us in a structured format your personal data and you have the right to (let) transmit such personal data to another controller. Right to Object: In certain cases, you have the right to object to the processing of your personal data, including with regards to profiling. You have the right to object to the further processing of your personal data in so far as such data have been collected for direct marketing purposes.
Right to be Not Subject to Automated Individual Decision-Making: You have the right to not be subject to a decision based solely on automated processing.
Right to Filing Complaint: You have the right to file complaints with the applicable data protection authority on our processing of your personal data.
Right to Compensation of Damages: In case we breach applicable legislation on the processing of your personal data, you have the right to claim damages from us for any damages such breach may cause with you.

5.OUR POLICIES FOR CHILDREN
Our service is not directed to children under thirteen and does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website. If we learn that we have collected personal information of a child under thirteen, we will take the appropriate steps to delete such information from our files as soon as possible. If you learn that a child has provided us with personal information in violation of this Privacy Policy, you can alert us at [email protected]

6. DATA RETENTION
We provide industry-standard physical, electronic, and procedural safeguards to protect personal data we process and maintain. For example, we take reasonable measures to limit access to this data to authorized employees and contractors who need to know that information in order to operate, develop or improve our Services. Please be aware that, although we endeavor to provide reasonable security for data we process and maintain, no security system can prevent all potential security breaches. As a result, we cannot guarantee or warrant the security of any information you transmit on or through the Services and you do so at your own risk. Our retention periods for personal data are based on our business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either irreversibly anonymize the data (and we may further retain and use the anonymized information) or securely destroy the data.

7. TRANSFER OF DATA
We operate internationally and transfer information to the United States and other countries for the purposes described in this policy. If you are located outside of the United States and you choose to use the Services or provide your information to us, your data may be transferred to, processed and maintained on servers, databases or cloud storage facilities located in the United States. Your use of the Services represents your consent and agreement to these practices. If you do not want your data transferred to or processed or maintained in the United States, you should not use the Services. We rely on multiple legal bases to lawfully transfer personal data around the world. These include your consent, the EU-US, and Swiss-US Privacy Shield, and the EU Commission approved model contractual clauses, which require certain privacy and security protections. Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create a Vivoo account and click “I agree” to data transfers, irrespective of which country you live in.

8.UPDATES TO THIS PRIVACY POLICY
Vivoo will occasionally update this Privacy Policy to reflect company and customer feedback. Vivoo encourages you to periodically review it to be informed of how Vivoo is protecting your information. For any questions please contact us at [email protected]

9. YOUR RIGHTS UNDER APPLICABLE DATA PROTECTION LAWS
We acknowledge your right to access and control your personal data in accordance with applicable Data Protection Laws. Accessing, Correcting or Deleting Your Information For EU Users, to request access to or correction of your personal data in accordance with applicable Data Protection Laws, you may send an e-mail to [email protected] Please include your registration information you provided through the Services. We may ask you to provide additional information for identity verification purposes or to verify that you are in possession of an applicable email account. For EU Users, if you’d like us to delete information that you have provided through the Services, please contact us at [email protected] and we will respond in a reasonable time in accordance with applicable Data Protection Laws. Please note that some or all of the information you provided may be required in order for the Services to function properly or may be automatically retained in backup storage or records retention archival storage.

EU USER’s – Portability of Your Personal Data

Data portability is the ability to obtain some of your information in a format you can move from one service provider to another in accordance with applicable Data Protection Laws. Depending on the context and applicable Data Protection Laws, this applies to some of your information, but not to all of your information. For EU Users, should you request it, we will provide you with an electronic file of your basic account information and the information under your sole control in accordance with applicable Data Protection Laws.

California Residents

If you are a California resident under the age of 18 and are a registered user of the Services, you may
request that we remove content or information about you that you posted on the Services by (a) submitting a request in writing to [email protected]; and(b) clearly identifying the content or information you wish to have removed and provided sufficient information to allow us to locate the content or information to be removed. However, please note that we are not required to, and may not be able to, erase or otherwise eliminate content or information if: (i) other state or federal laws require us or a third party to maintain the content or information; (ii) the content or information was posted, stored, or republished by another user; (iii) the content or information is anonymized so that you cannot be individually identified; (iv) you do not follow the instructions posted in this Privacy Policy on how to request removal of your content or information; or (v) you have received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain the applicable content or information.

9.CONTACT US
[email protected]
Vivosens Inc.
316 High Street, Palo Alto CA, US, 94301
For further information see https://ico.org.uk/for-organisations/data-protection-reform/overview-ofthe-gdpr/
In case you like to get in contact with us in relation to any of the above-mentioned rights or any other personal data issues, please email us at [email protected]