PRIVACY POLICY

WHY DOES THIS MATTER?

At ChiKeey, we take data protection seriously.

We are working on developing products and applications that enable you to track your lifestyle choices, mood, energy, and stress to impact your quality of experiences. We feel that data does not get much more personal than this, and thus respect your privacy. Safety of your data is of paramount importance to us. We therefore hope that you take a moment to review this policy.

ABOUT THIS POLICY

This Privacy Policy has been put together to provide users (“Users” or “you”), as well as our partners, with transparent information about the privacy of how we use our data to develop and refine our initial prototype. This Privacy Policy aims to answer the following questions:

  • What personal data we collect from partners as well as users
  • How we store and process the data
  • Users and partners’ legal rights and how to exercise them

Please note that this privacy policy only applies to the processing of personal data carried out by ChiKeey’s a data controller. The App Store privacy guidelines have been taken into account in the drafting of this Privacy Policy.

This Privacy Policy may be updated from time to time. We will not make substantial changes without prior notice. You can determine when this Privacy Policy was last revised by referring to the “LAST UPDATE” date at the top of this page.

WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?

We process the following general account data as inserted by you:

  • E-mail address
  • Gender
  • Birth date and year
  • Height and weight
  • Activities
  • Notes and tags

We track and collect the following data through a wearable device and the technology platform used:

  • Heart rate
  • Movement data
  • Temperature data
  • IP address and high-level location
  • User ID (randomly generated)
  • Metadata regarding website/app/technology use

This information is used to produce evaluation data regarding the quality of your mood, stress, energy, and stress level.

DATA SOURCES

Measurement data is collected automatically by the tracking functions through a wearable device. Data is sourced from the wearable devices through partnerships and via an API.

Data is also produced by combining the data listed above and by calculating evaluation data regarding mood, energy, and stress level.

PURPOSES AND LEGITIMATE GROUNDS FOR PROCESSING OF PERSONAL DATA

To develop the product to provide you the service
We process personal data in the first place to develop the product that will be able to offer the service to our Users.

Legal grounds for processing
We process personal data on the basis of a user contract, which is formed in connection with the creation of an account and acceptance of our terms and conditions. We may also process certain information to comply with legal obligations, such as consumer protection legislation.

Furthermore, we process the personal data to pursue our legitimate for aggregated analytics and trend detection. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy.

Measurement data or any data derived from measurement data is used for advertising only subject with your explicit consent.

SHARING YOUR PERSONAL DATA

We may share data with our group companies, subsidiaries and affiliates. Otherwise we do not share personal data with third parties outside of our organization unless one of the following circumstances applies:

It is necessary for the purposes set out in this Privacy Policy
To the extent that third parties need access to personal data to enable the offering of the service, ChiKeey has taken appropriate contractual and organizational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.

For legal reasons
We may share personal data with third parties outside ChiKeey’ organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests or safety of ChiKeey or our Users in accordance with the law. Where possible, we will inform Users about such transfer and processing.

To our authorized service providers
We may share personal data to authorized service providers who perform services for us (including data storage, sales, marketing and other support function services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy. Please bear in mind that if you provide personal data directly to a third party, such as through a link on our website, the processing is typically based on their policies and standards.

For other legitimate reasons
If ChiKeey is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all Users concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.

With your explicit consent
We may share personal data with third parties outside ChiKeey organization for other reasons than the ones mentioned before, when we have the User’s explicit consent to do so. The User has the right to withdraw this consent at all times.

ANONYMIZED DATA

We may aggregate and anonymize data collected through partnerships and wearable devices and applications. Such data will be anonymous and cannot be connected to an individual User, therefore no longer qualifying as personal data. We may use this type of anonymous data for analytics, statistics, research, communications and PR purposes as well as for trend detection and for benchmark data.

HOW LONG DO WE KEEP YOUR DATA?

ChiKeey does not store personal data longer than is legally permitted and necessary for the purposes specified above. The storage period generally depends on the duration of the development lifecycle, unless data has been deleted upon request.

Backups are deleted as soon as reasonably possible, typically within 6 months.

SAFEGUARDING YOUR DATA

We do our best to keep your data safe and secure.

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures may include, for example, where appropriate, encryption, pseudonymization and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data. We regularly test our Service, systems, and other assets for security vulnerabilities.

We will take all reasonable precautions to ensure that our staff and employees who have been specifically granted access to information about you have received adequate training to ensure that they process that information only in accordance with this policy and with our obligations under applicable legislations.

Should despite of the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you and relevant authorities as required by applicable data protection laws.

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