May 15, 2023
«User ID», «Personal ID» means unique user identifier created by Mawi system that is used for getting access to user’s personal data;
«Personal data» means any information relating to an identified or identifiable natural person(‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, inparticular by reference to an identifier such as a name, an identification number, location data, anonline identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
«Processing» means any operation or set of operations which is performed on personal data oron sets of personal data, whether or not by automated means, such as collection, recording,organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction,erasure or destruction;
«Processor» means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
2. Personal data we collectWe ask you for certain personal data to provide you with the Service you request. For your comfort, we structured information in following categories:
General Information. This personal data includes:
✓ contact details including name, email;
✓ login and account information, including password and unique user ID;
✓ personal details including gender, date of birth;
✓ Information regarding your use of App and Service and history of requests to our support team;
Special categories of personal data (sensitive data). We also collect information you voluntarily provide to us in relation to your physique in order to provide you with the Service. This personal data may - by itself or in combination - reveal information about your health. The special categories of data include:
✓ data on physical characteristics, including weight (and it’s changes), height and otherbody measurements;
✓ fitness activity data provided by you or generated through App or connected device(time distance, steps amount, calorie count, sleep activities);
3. Why and how do we use your personal data
✓ To provide the features of the App and the Service you request.When you use our App, we will process your personal data to provide the requested Service.If you decide to become a user of our App, we need to process your data to identify you as auser of the App and grant you access to its various functionalities. We only process the personaldata that are strictly necessary to manage or resolve your request based on the App functionalities.
✓ To improve our Service.We may use personal data about how you use our App and Service to enhance your userexperience and to help us diagnose technical and service problems and administer our Apps.
✓ To protect our or others' rights, property or safetyWe may also use your personal data about how you use Apps to prevent or detect fraud,abuse, illegal use, violations of our Terms and Conditions, and to comply with court orders,governmental requests or applicable law.
✓ For general research and analysis purposesWe use data about how Users use our App and Service to understand User preferences. Inaddition, we can use your anonymized data for scientific purposes concerning Service.
4. Your rights as a Data Subject
We undertake to keep your personal data confidential and to ensure that you may exerciseyour rights. In that aspect, you may exercise your rights free of charge by writing us an e-mail to asingle e-mail address (firstname.lastname@example.org), simply informing us of the reason for your request andthe right that you wish to exercise. If we consider this necessary to be able to identify you, we mayrequest you to provide a copy of a document evidencing your identity.You have the following rights:
✓ To request access to your personal data that we hold. We remind you that you canrealized this right through the section “Settings” of App.
✓ To request that we rectify the personal data that we hold. Please bear in mind that youmay also change or update your personal data in the relevant section of App. In any case, pleasetake into account that you guarantee that your data is true and accurate and you undertake to notifyto us any change or modification of your data by updating your Profile data in App. Pleaseremember that, as a general rule, you must provide us only with your own data, not with those ofthird parties.
✓ To request the portability of your personal data. This means that you will have theright to receive the personal data that you made available to us in a structured, commonly used andmachine-legible format, to be able to transmit them to another entity directly without impedimentson our part.
✓ To request that we cancel or limit the processing of your personal data, which entailsthat in certain cases you can request us to temporarily suspend the processing of the data or that wekeep them longer that necessary. Please note, that in this case you could not use App.
✓ To erasure (also known as the right to be forgotten). We erase your personal data tothe extent that it’s no longer necessary for the purpose for which we need to keep processing it orwhen we are no longer legally permitted to process it or if you withdraw consent. You can exercisethis right either by contacting us or by clicking on the «Delete my account» through the relevantsection of App.
✓ Rights relating to automated decision-making and profiling. We do not, however, useyour personal data in the way, based on automated decision-making which produces legal effects onthe User.Also you have the right to withdraw your consent for processing personal data at any time. Todo so please contact us by email: email@example.com or Delete your account in App.Finally, we inform you that you have the right to file a claim before the responsible dataprotection regulatory authority:http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htmFor more information about our use of your personal data or exercising your rights as outlinedabove, please contact us.
5. Data security
We follow generally accepted industry standards to protect the information submitted to us,both during transmission and once we receive it. We maintain appropriate administrative, technicaland physical safeguards to protect Personal Data against accidental or unlawful destruction,accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any otherunlawful form of processing of the Personal Data in our possession. We use HTTPS technology toencrypt data during transmission through public internet.However, no method of transmission over the Internet, or method of electronic storage, is100% secure. We cannot ensure or warrant the security of any information you transmit to us andyou do so at your own risk. We also cannot guarantee that such information may not be accessed,disclosed, altered, or destroyed by breach of any of our physical, technical, or managerialsafeguards. If you believe your Personal Data has been compromised, please contact us as set forthin the “How to Contact Us” section.
6. How long do we keep your personal data?
We will retain your information for as long as your account is active (not deleted) or asneeded to provide you services or until your consent is not withdrawn. We will retain and use yourinformation as necessary to comply with our legal obligations, resolve disputes and enforce ouragreements.If you wish to delete your account, you can do so using the «Delete My Account» in the App.All personally identifying information is deleted on your request.Please note, that after 30-day period of non-use of the App, your data may be deleted, even ifyou don’t take any action to do so by yourself. We may also choose to irreversibly anonymise datainstead of deletion. Any way, we will inform you before taking such actions.
7. How do we store or/and transfer your Data?
8. How do we share Data? (To whom we disclose information)
Except as described in this Policy and Terms and Conditions, we will not intentionallydisclose the Personal Data that we process to third parties without your consent of the applicableUser.In case your App account is connected with Mawi
Platform, you can give access to yourpersonal data to (share it with) definite users of dashboard (doctor, manager etc). For that reason, itis necessary to disclose your User ID (Personal ID) to such persons.Please note that Mawi solutions takes no responsibility for actions that could be taken with your personal data by such persons unless such persons are employees, contractors or subcontractors of Mawi Solutions.We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
✓ Service Providers.We work with third party service providers who provide application development, hosting,maintenance, and other services for us. These third parties may have access to, or process PersonalData as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and ourcontracts with them require them to maintain the confidentiality of such information. Our contracts with these service providers do not permit use of your information for their own (marketing)purposes. Consistent with applicable legal requirements, we take reasonable steps to require thirdparties to adequately safeguard your personal data and only process it in accordance with our instructions.
✓ Law Enforcement, Legal Process and Compliance.We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to afacially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselvesor others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defendourselves against any third-party claims or allegations, (iv) protect the security or integrity of theApp and any facilities or equipment used to make the App available, or (v) protect our property orother legal rights, enforce our contracts, or protect the rights, property, or safety of others.
✓ Change of Ownership.We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as customernames and email addresses, and other User information related to the Mawi may be among theitems sold or otherwise transferred in these types of transactions. We may also sell, assign orotherwise transfer such information in the course of corporate divestitures, mergers, acquisitions,bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedingsinvolving all or a portion of the company. You will be notified via email and/or a prominent noticeon our Website of any change in ownership or uses of your personal information, as well as anychoices you may have regarding your personal information.
✓ Non Personally Identifiable Information.We may make certain automatically-collected, aggregated, or otherwisenon-personally-identifiable information available to third parties for various purposes, including (i)compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii)analytic and scientific purposes. Provided such information does not identify a particular individual.
9. Children’s privacy
Protecting the privacy of young children is especially important. Our App is not directed to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18 without obtaining parental consent. If you are under 18 years of age, then please do not use or access the App at any time or in any manner. If we learn that Personal Data has been collected from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account, then you may alert us and request that we delete that child’s Personal Data from our systems.
10. Personal Data breach
With regard to Personal Data Breach caused by Mawi, Mawi shall:
✓ In accordance with GDPR Article 33 and 34, notify you without undue delay in the event of Personal Data Breach involving Personal Data;
✓ Use reasonable efforts to identify the cause of such Personal Data Breach and take those steps as Mawi deems reasonably practicable in order to remediate the cause of such PersonalData Breach.
✓ Provide reasonable assistance and cooperation as requested in the furtherance of any correction or remediation of any Personal Data Breach.
12. Data protection officer. How to contact us
If you have any questions regarding the processing of your personal data or this Privacypolicy, please contact the Mawi solutions Data Protection Officer by email: firstname.lastname@example.org«Mawi Solutions OU»Estonia, Harju maakond, Tallinn,Lasnamäe linnaosa, Peterburi tee 47, 11415