隐私政策

移动应用健康 Virtuoso 隐私政策

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Healthy Virtuoso – Mobile App Privacy Policy and Cookies

This application for smartphones and tablets is provided by Healthy Virtuoso Srl, with registered office in Piazza Deffenu 9, 09125 – Cagliari (CA) (Italy), VAT number and tax code: 03737900922 (hereinafter referred to as the “Company” or “Virtuoso”) or “we” or “us”). Once you register, the Application allows you (hereinafter referred to as “User” or “you” or “your”) to use the services it provides.

In order for the application to work properly, it needs to save the information you provided when registering on a remote server. If you do not intend to authorize saving this information on the remote server, do not install the application.

Categories of personal data processed

The personal data you provide are processed through the application: name, nickname, phone number, email address, date of birth and photo.

Once you authorize it, the app will sync with other apps installed on your device – such as the Health app, Google FIT, Garmin Connect, Huawei Health, and Health Connect. You must enable synchronization so that the application can use the information present on your device (e.g. height and weight, number of steps, minutes of sleep, time spent in physical activity, calories burned, distance reached ) in order to calculate the number assigned to you Earn credits , climb the rankings, challenge other users, participate in dedicated competitions, redeem rewards, achieve personal daily goals, join missions, upgrade levels or join your dedicated company section and interact with your colleagues and friends. After initial activation and your authorization, the app will access the Health App, Google FIT, Huawei Health, Health Connect and Garmin Connect for the past 30 days.

In addition to the data you provide to complete your profile, we will also collect and process the following data through the Application: (i) number of steps taken, (ii) physical activities performed (e.g. running, cycling, etc… ), (iii) sleep duration, (iv) weight & height detection, (v) calories burned, (vi) distance reached, (vii) user level and ranking, and (vii) data related to your location, these Data is collected by Health App , Google FIT, Huawei Health , Health Connect and Garmin Connect and shared with Healthy Virtuoso App.

If information about your health can be inferred from the collected information or from a combination of the same specific data, you must expressly consent to the processing of these data.

使用从 Health Connect 收到的信息将遵守 Health Connect 权限政策,包括限制使用要求。

In addition, data provided anonymously will be used jointly for statistical analysis purposes and to provide information that enables the Company and our technology providers to improve the services provided through the Application.

All your data will be managed and encrypted in a secure manner via AWS hosting, adhering to all major security and compliance standards in the market (AWS KMS, AES-GCM, AES-256, KMS HMAC)

Purpose and legal basis

Your personal data will be processed for the following purposes:

a) Manage your registration request in the Application and allow you to use its features, in particular allowing you to select and redeem level-related coupons or rewards; the legal basis for such processing is, in accordance with Article 1, prior to the execution of the contract or contractual measures. 6. c. 1. Let. b) GDPR or, if the processing involves health-related data, with your consent in accordance with Article 1. 9. c. 2. Let. a) GDPR. The Data Controller cannot guarantee the use of the Application without your consent;

b) To carry out strictly functional technical assistance activities to ensure the correct functioning of the App and to provide the necessary support for its use; also in this case, the legal basis for processing, in accordance with Article 1, is the execution of pre-contractual or contractual measures. 6. c. 1. Let. b) GDPR or, if the processing involves health-related data, with your consent in accordance with Article 1. 9. c. 2. Let. a) GDPR. Without your consent, the Data Controller cannot guarantee the correct functioning of the Application or the technical assistance that may be required;

c) To fulfill legal obligations under Article 1. 6. c. 1. Let. c) GDPR;

d) To conduct analysis and market research through surveys made available to users on the “News” page of the Application. According to Article 1, the legal basis for such processing is the legitimate interests of the data controller. 6. c. 1. Light up. f) GDPR;

e) To send commercial/sales notifications about the Company’s products and services by you, on the basis of voluntary consent, by email, SMS, MMS, fax or similar means, and/or by the postal service or by speaking to an operator in accordance with Art. provided and freely revoked at any time. 6. c. 1. Let. a) The provisions of the GDPR or, insofar as the processing involves health-related data, in accordance with Article 1. 9. c. 2. Let. a) GDPR;

f) Define your profile and provide products and services directly to you through SDK technology based on this profile; in accordance with Article 1, based on your voluntary consent which can be freely revoked at any time. 6. c. 1. Let. a) The provisions of the GDPR or, insofar as the processing involves health-related data, in accordance with Article 1. 9. c. 2. Let. a) GDPR.

 

SDK

Virtuoso uses SDK (Software Development Kit) technology to improve your application experience. SDKs are blocks of code provided by our business partners that are installed in an application and allow us to understand how you interact with it and serve you advertising tailored to your interests.

To carry out this activity, Virtuoso jointly processes your personal data but does not provide our business partners with data that directly or indirectly identifies you.

Data retention

We will retain your personal data for as long as necessary to fulfill the purposes specified in this Privacy Policy, and in particular during the entire time you use the Application and during the limitation periods for which the Company may exercise its rights, and where applicable.

Refer to the purpose under sub-heading. e) and f) The processing activities will be carried out and the related data will be stored for 24 (twenty-four) months and 12 (twelve) months respectively.

provide personal data

Providing your personal data for the above purposes. a), c) in the paragraph “Purpose and Legal Basis” of the band are optional but necessary for the fulfillment of legal and contractual obligations. In these cases, failure to provide data will prevent Virtuoso from allowing you to register for the Application and use its features. Provide your personal data for the purposes mentioned in the letter. d) is in any case optional; if not provided, the data controller will not be able to pursue its legitimate interests.

The data provided for points d) and, e) are optional, but failure to provide the relevant personal data and/or failure to consent to its processing will result in the Company being unable to carry out the activities mentioned in this Privacy Policy.

Communication and Disclosure Data

For the purposes stated above and within the limits strictly related thereto, the data may be accessed, known or communicated to the following persons designated by the Company, as the case may be, as responsible persons or persons authorized to process the data or as autonomous persons: Holder:

– the natural or legal person whom the Company uses to carry out activities that contribute to the achievement of the above purposes or to whom the Company is required to transfer data under legal or contractual obligations;

– Company shareholders and stakeholders.

If you participate in a corporate wellness program and are ranked high, we may communicate to your company general data related to your participation in the program (name and prizes collected or to be collected), which your company will treat as autonomous data controller. If you wish, this will enable you to participate in moments of recognition organized directly by your company.

Nonetheless, your personal data will not be disclosed.

Personal data will not be transferred outside the EU and/or European Economic Area

Data Controller, Data Processor, Data Protection Officer (DPO)

The data controller is Healthy Virtuoso Srl, with registered office at Piazza Attilio Deffenu 9 – 09125 Cagliari (Italy), email: privacy@healthyvirtuoso.com. The updated list of processors is available upon request by writing to: privacy@healthyvirtuoso.com . The Data Controller has appointed a Data Protection Officer, who can be contacted at the email address privacy@healthyvirtuoso.com.

Data subject rights

As a data subject, you can request access to your personal data, correction or deletion of this data, restriction of processing and portability of your data through the application functions or via the email address : privacy@healthyvirtuoso. com. You can also prevent the processing of your data for legitimate purposes or marketing purposes. Your right to prevent the processing of your data, exercised by email, also extends to sending advertising via the postal service or making phone calls to the operator, but does not affect the possibility to exercise this right only partially, for example, to prevent your data from being processed by automated communication system for processing. If the processing of your personal data requires your consent, you may also revoke the consent provided at any time, without affecting the lawfulness of the data processed based on the consent provided before you revoked your right. Furthermore, if you believe that your rights under the current personal data protection legislation have been infringed, you may lodge a complaint with the Italian Data Protection Authority according to the methods indicated on the website of the Italian Data Protection Authority, accessible at: www.garanteprivacy.it.

Data deletion:

As a data subject, you may request the deletion of your personal data via (i) the “Profile” span, encoded_tag_close “Account” “Delete>” section of the application; (ii) via a dedicated page on our website (i ii) by sending an email To: p rivacy@healthyvirtuoso.com . All requests will be processed within the timeframes stipulated in the current public norms regarding data management and personal privacy under the GDPR

Read information about the processing of my data

I allow my personal data to be used for marketing purposes. d) This Privacy Policy Statement.

​I allow my personal data to be used for profile information purposes in accordance with the letter. e) This Privacy Policy Statement.