PRIVACY POLICY

Last modified: August 2023

We are committed to respecting your data privacy and providing transparency about our data practices. This Privacy Policy (the “Agreement” or “Policy”) explains what information of yours will be collected when you download, install, access, or use our applications (the “App” or “Software” or “Services”), and how such information will be used and shared. It also explains choices you have to control the collection, correction and/or deletion of such information. By using the Software, you consent to the Policy and to the collection, processing, disclosure and use of your information as described in this Policy.

Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to explicitly accept changes to Privacy Policy to continue using the App. We encourage you to periodically review our website for the latest information on our data privacy practices. If you do not accept the terms of the Privacy Policy, we ask that you do not use the App. Please exit the App immediately and delete it if you do not agree to the terms of this Privacy Policy.

1.Data We Collect

If you access our Services or App, your device will automatically send information to our server and temporarily stores it in a log file. The following information is collected without your intervention and stored until it is automatically or manually deleted in the log file.

1.1 Usage data

We may use Xcode API to access your mobile device and query the about usage data when you interact with the Services. For example, we collect information about which features you’ve used, how you’ve used them. Our purpose is to customize your experience. We use your usage data to tailor the Services contents and make offers to your personal preferences. Processing of usage data for this purpose is based on: 6.1. f) GDPR (“processing is necessary for compliance with a legal obligation to which the controller is subject”).

1.2 Device and Location data

We and our service providers may use Xcode API to access your mobile device and query the about device and location data which will be transferred to us automatically. Examples of data that may be collected and used include: language settings, time zone, type of device, device settings, operating system, ISP or your mobile carrier, hardware ID. Our service providers may help us approximate your location. They may, for example, use an IP address received from your device to determine approximate location or collect location information from device in accordance with the consent provided by your device.

Our purpose is to provide you with better Service. This includes use of personal data to support delivery of the Service under Terms of Service, to ensure that content provided by App is presented in the most effective manner, to prevent or address service errors or technical issues. Processing of device and location data for this purpose is based on: 6.1. b) of GDPR ("processing is necessary for the performance of a contract to which the data subject is party") and 6,1 c) GDPR ("processing is necessary for compliance with a legal obligation to which the controller is subject").

1.3 Registration Related data

We may use our API to access your Registration Related data when you register on the Software and use the Services (if applicable), such as name, e-mail address. The purposes of the registration related information is: (i) to improve and customize the Software and Services; and/or (ii) to maintain and improve the quality and operation of the Software and Services; and/or (iii) to notify you of Software and Services updates; and/or (iv) to provide you with support and handle your complaints and/or feedback.

1.4 Advertising data

We may use third party SDK (Kochava) to collect your Apple Identifier for Advertising (IDFA) or Google Advertising ID (AAID), and use these data to recognize your device and support activities on advertising of our Service. These number values are not permanently tied to your device and, depending on your operating system, you can reset them through your device settings.

Our purpose is to optimize advertising. We and our partners may use your advertising data to inform, optimize and serve advertising based on your past use of this App. This activity is performed by tracking Usage data and by using other information that is transferred to the partners that manage the remarketing and behavioral targeting activity. You may opt out of these practices following the information here. Processing of personal data for this purpose is based on: 6.1. f) GDPR ("processing is necessary for the purposes of the legitimate interests pursued by the controller"), and more specifically, we wish to provide you useful or interesting information about the App, special offers and other our features that we think you might be interested in.

1.5 Analytical data

We use third party analytics tools and third party SDK to help us measure traffic and usage trends for the Service. These tools may record data, such as: how often you use the App, referring/exit pages and URLs, device identifiers, events that occur within the App, aggregated usage, performance data. Our purpose is to perform research and analysis about your use of the App. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design and develop the App and our new products. We also use such data for statistical analysis purposes to test and improve our offers. Processing of personal data for this purpose is based on: 6.1. b) GDPR ("processing is necessary for the performance of a contract to which the data subject is party") and .1. f) GDPR ("processing is necessary for the purposes of the legitimate interests pursued by the controller"), more specifically, research and analysis about how you use the Service helps us to enable you to enjoy the use of, and easily navigate Application, and/or better understand your needs and interests.

1.6 Other data

Our Service is dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data, we may modify, update and publish this Policy in the App. Please continue to play close attention to this Policy. If you restrict certain data from being collected automatically, we may be unable to provide the Service.

2.How We Use Your Information

The main reason we use your information is to deliver and improve the Service. Read on for a more detailed explanation of the various reasons we use your information:

– to operate and update the Software and the Service, and provide you with existing and new functionality and features;

– to improve and customize the Software and the Service;

– to maintain, test, monitor and improve the quality and operation of the Software;

– to take any action in case of a dispute involving you in connection with the Software and the Service;

– to comply and satisfy any applicable law regulation, legal process or enforceable governmental request.

If any new purposes for processing your information arise we will let you know we start to process information on that other purpose by introducing the corresponding changes to this Privacy policy.

3.Sharing of Your Information

Your personal data may be shared as follows:

We will share your information with third parties only in the ways that are described in this Privacy Policy. We share your Personal Data only with our employees and contractors, agents, and auditors who need to know or otherwise access Personal Data under this Privacy Policy and who are bound in writing by confidentiality and other obligations sufficient to protect Personal Data in accordance with this Privacy Policy.

Please note that while integrating external services, we choose third parties that can assure they apply all necessary technical and organizational measures to protect users` personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party. Provided that we followed all demands of applicable personal data protection legislation, we are not responsible for any accidental loss or unauthorized access to your personal data through the fault of third parties.

We will not rent or sell your personal data to any third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic and other data processing technologies for the App.

4.How Long We Use Your Personal Data

We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.

However, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if information is necessary to comply with legal obligation (taxation, accounting, audit) or in order to maintain safety and data backup settings, prevent fraud or other malicious acts.

5.Medical Disclaimer

Our APP is a non-medical product and not a clinical pulse oximeter, It cannot be used for medical purposes, it is intended for informational and educational purposes only. We cannot guarantee the accuracy, security or completeness of the information and data. Our apps are not responsible for any personal injury or other damages resulting from the use or misuse of the service. If knowing your pulse rate is critical to your health, you further need to have your pulse taken by a medical professional.

Heart Rate Monitor is a private publishing App with some information and guidance, based on a machine learning model. We are not responsible for your physical and/or mental health.

When you use our App, the result of measurements and other functions will be displayed back to you. Certain features of our App allow you to make some of your measurements public, in which case it will become readily accessible to anyone. We urge you to consider the sensitivity of any data you share at your discretion.

6.Security

The security of your personal information is highly important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.

We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your personal data to be encrypted with proper and strong encryption algorithms, including hashing where possible.

Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We do our best to protect your personal data, nevertheless, we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law.

If you have any questions about the security of our App, you can contact us.

7.Children’s Privacy

Our App is not intended for children under the age of 18. Therefore, we do not knowingly collect or solicit any personal information from children under 18. No one under age 18 may provide any personal information to the App. If you are under 18, do not use or provide any information on this App or through any of its features. Do not provide any information about yourself, including your email address. If we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

8.Push Notifications/Alerts

We may send push notifications or alerts to your device. You can deactivate these messages at any time by changing the notification settings on your device.

9.Changes to the Privacy Policy

This Privacy policy is updated regularly. Whenever we change this Privacy policy, we will post those changes to this Privacy policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.

10.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 via [email protected].