Privacy Policy

Effective as of January 31, 2019

This Privacy Policy (“Privacy Policy”) explains how LLC Viv Dev (“Company” or “we” or “us”) collects, stores, uses, and discloses personal data from our users (“you”) in connection with its mobile applications and related services (collectively, the “App”).

1. ACCEPTANCE OF PRIVACY POLICY. CHANGES TO PRIVACY POLICY

This Privacy policy is an integral part of Terms of use. By accepting Terms of use, you also accept this Privacy Policy. In some cases, we may ask you to explicitly accept this Privacy Policy.

We reserve the right to and may periodically change, amend, or update this Privacy Policy. We will notify you by email, through the App, or by presenting you with a new version of Privacy policy for you to accept if we make modifications that materially change your rights. Your continued use of the App after the effective date of an updated version of this Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, we may ask you to explicitly accept the updated Privacy Policy.

2. INFORMATION WE COLLECT ABOUT YOU

When you download, install, and use the App, we may collect inter alia the following personal information about you:

  • Name and surname;
  • Email address;
  • Age;
  • Cellphone number;
  • Symptoms and data about your physical activities;
  • Data collected through surveys (related to habits, physical activities, etc.);
  • Data imported from Health Kit.

3. INFORMATION WE COLLECT AUTOMATICALLY

When you download, install, and use the App, we may automatically collect the following information:

  • Information about your device including type of hardware, operating system and its version, UDI, settings, etc.
  • Information that is gathered about your use of the App (frequency of use, experienced problems, etc.) via cookies or similar technologies (for instance, through third party services like Appsee). We need such information in order to improve App’s functionality and technical stability. This section may include information about your interaction with Third-party services as defined in Terms of use).

If the information covered by Sections 2 and 3 is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. To the extent information covered by this Section is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection laws, it is referred to in this Privacy Policy as “Personal Data.” We use pseudonymization for particular types of Personal Data. Please bear in mind that provisions of Section 6 do not apply to pseudonymized Personal Data.

4. YOUR CONSENT

By using the App, you explicitly consent that:

WE MAY STORE AND PROCESS YOUR PERSONAL DATA YOU PROVIDE THROUGH THE USAGE OF THE APP SOLELY FOR THE PURPOSE OF PROVIDING SERVICES TO YOU, TO IMPROVE OUR SERVICE FEATURES AND OTHER PURPOSES INDICATED IN SECTION 5 OF THIS PRIVACY POLICY. SUCH SERVICES MAY INCLUDE SENDING YOU INFORMATION AND REMINDERS THROUGH THE APP OR TO THE EMAIL ADDRESS YOU PROVIDED TO US.

WE WILL NOT TRANSMIT ANY OF YOUR PERSONAL DATA TO THIRD PARTIES, EXCEPT IF IT IS REQUIRED TO PROVIDE THE SERVICE TO YOU (E.G. TECHNICAL SERVICE PROVIDERS), UNLESS WE HAVE ASKED FOR YOUR EXPLICIT CONSENT.

5. HOW WE USE YOUR INFORMATION

We use all information collected about you and your use of the App to improve the App and deliver better experience. Among others, we may use your Personal Data to:

  • analyze, operate, maintain and improve the App, to add new features and services to the App;
  • provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders;
  • customize product and service offerings and recommendations to you, including third-party products and offerings;
  • send you technical notices, updates, security alerts and support and administrative messages;
  • monitor and analyze trends, usage and activities in connection with our App;
  • for any other purposes disclosed to you at the time we collect Personal Data or any other purposes indicated in this Privacy Policy.

We may also need your Personal Data in order to delete, forbid or block any Content (as defined in Terms of use) that violates the present Privacy Policy and Terms of use, or investigate any illegal or suspicious use of our App.
We may contact you from time to time via email to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you. You can always opt out of receiving emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting-out of these emails will not end transmission of important service-related emails that are necessary to your use of the App.

We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you in accordance with Section 2-5 of this Privacy Policy or collect any Personal Data that is not required for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amount and type of Personal Data that is strictly required for the purposes mentioned in this Section of the Privacy Policy (“data minimization principle”).

6. YOUR RIGHTS

Modification, correction and erasure. You are able to modify, correct, erase, and update your Personal Data by using the App settings or writing us at support@viv.health.

Access. You have a right to access your Personal Data you leave in the App and ask us about what kind of Personal Data we have about you. You can do this by using the App settings or by writing us at support@viv.health.

7. HOW WE STORE AND SHARE YOUR INFORMATION

All your Personal Data are collected on our servers for the purposes indicated in Section 5. We host and process all your Personal Data in data hosting service providers in the United States.

We do not share your Personal Data with any third parties except as specified by this Privacy Policy. We use a couple of third-party services like Appsee to see and analyze how you navigate through the App, what features you prefer the most, and how to improve your experience with the App.

BY USING THE APP, YOU CONSENT THAT WE MAY USE COOKIES AND THIRD-PARTY SERVICES, AND COLLECT YOUR USAGE DATA UNDER A UNIQUE IDENTIFIER, FOR THE PURPOSES OF TRACKING, ANALYSIS, AND IMPROVEMENT OF THE APP.

You may choose to share your Content using our proprietary or third-party services. Please note that any such third-party services are not governed by this Privacy Policy. When you access and use Third-party services via the App, we are not responsible for these Third-party services and we do not endorse or make any warranties and representations about such Third-party services.

8. DATA RETENTION AND SECURITY

If you choose to delete the App, we may retain your Personal data for as long as your account is active and within reasonable period thereafter in case you decide to re-activate the App. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve the App. Where we retain information for App improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

We take all reasonable and appropriate measures to protect all collected Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process. Among others, we utilize the following information security measures to protect your Personal Data:

  • Pseudominization and tokenization of certain categories of your Personal Data;
  • Encryption of your Personal Data in transit and in rest;
  • Systematic vulnerability scanning and penetration testing;
  • Protection of data integrity;
  • Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.
  • Conducting periodical data protection impact assessments in order to ensure that the App fully adheres to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake privacy audit in case of Company’s merger or takeover.

Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach.

9. LEGAL REQUESTS AND DISCLOSURE OF INFORMATION

We may preserve and share your Personal Data in response to a legal request from a competent authority (search warrant, subpoena, court order). We may also preserve and share your Personal Data when we have a good belief that that is necessary for a legitimate purpose: like detecting fraudulent behavior in the App, in order to protect security of the App, and in other cases.

10. CHILDREN’S PRIVACY

We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 13 years old under requirements of COPPA. The App does not collect Personal Data from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the App, please contact us at support@viv.health and we will take required steps to delete such information and (or) delete her account.

11. CONTACT US

If you have any questions or concerns about your privacy, any provisions of this Privacy Policy or any of your rights, you may contact us at:

LLC Viv Dev
22010 Republic of Belarus, Minsk, Kirov str. 8, office 19
Email: support@viv.health