An Innovative platform designed for Behavioral Change

Privacy Statement

Virtusan AG (“Virtusan”, “we”, “us” or “our”) will protect your data and is committed to respecting your privacy in connection with your use of the Virtusan’s mobile application as described below.

This privacy statement (the “Privacy Statement” or the “Privacy Policy”) describes the type of information, including personal information, collected and processed through Virtusan’s mobile application (the Virtusan App), and how Virtusan treats such information. For questions about this Privacy Statement or pertaining to your personal information, please contact *[email protected]*.

The Virtusan App allows you to track and improve your well-being and to reduce stress by following the guidance provided by the Virtusan App, which is based on an intelligent analytics platform that works, learns and improves with data input and analysis. The Virtusan App and its analytics platform allow you to access evidence-based interventions and exercises to improve your health and well-being in the attempt to reduce stress (the “Services”).

Informed Consent

By using the Virtusan App, you consent to the collection, use, and sharing of your information as described in this Privacy Policy. Health data tracking, calendar data tracking as well as user location data tracking will only be performed if you agree to such tracking in the Virtusan-App.

Collected Data, Uses made of the Data, Data Erasure

When you use the Services, we collect personal data. During the on-boarding process you will be required to enter your email address.

We will use your Data, to provide our Services and to improve our Services as well as to better understand certain user groups on an anonymized basis (for example based on their geographic location).

Except for aggregated and anonymized data, which we will need and use to improve our algorithms and Services, we will store your Data (including your profile as well as your email address) only for as long as it is necessary to provide the Services to you. Subject to the previous sentence and subject to data required for legal protection or as required by applicable laws and regulations, we will delete your individual Data (including your profile and email address) latest three months after cancellation of your Virtusan account but not without at least advising you once in advance that you have the possibility to download your individual Data.

As you proceed with the onboarding you will be required to enter a password and may choose nickname. To increase anonymity, you should choose a nickname that does not allow a direct or indirect inference to yourself

There are processes in place to secure the anonymity of your personal data. At no time will your email be linked unencrypted to your personal data. Your email address and your nickname (if any) are both hashed, which means that the original data is masked with another value. Communication will occur between the encrypted unique values or identifications only. Your email address will be deleted in accordance with Article 1.3 below if you decide to stop using the Services and delete your account.

During the process of on-boarding or later we will ask your permission to use/access data of certain other applications on your phone or your smart watch, such as location tracking, calendar data (only date and time entries), apple health data (e.g. steps/day, heartbeats/minute, etc.). We also collect data that you provide by using the Services. This data allows us to better understand your habits and to optimize the Services (the “Data”).

The Service automatically collects technical data such as browser, operating system, device specifications, usage times, and publicly accessible information related to WLAN connections and we may use common tools for Service optimization, such as event-based triggers.

1.1 TrueDepth API

The App also makes use of automatically collected information using the device camera and the TrueDepth API provided by Apple. This data is used to measure the light intensity of the environment and is powering the Light Meter feature. None of the information collected by the TrueDepth API is shared with third parties, saved remotely, or used for purposes other than the use of the app.

Security

We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information. We will store all your personal information on our secure and encrypted (password and firewall protected) servers.

Data confidentiality and security is of utmost importance to us.

Disclosure of Data

Virtusan may use personal data only to the extent that is required in order to provide the Services. Currently we may disclose data to Alfred Intelligent Inc. (an analytics company who is providing analytics and project management services); data disclosed to Alfred Intelligent Inc. are always anonymized, will not be downloaded and access is granted to a very limited number of employees in a secure environment. Alfred Intelligent SRL a company located in the European Community is currently providing technical services and maintenance as well as analytics services. For those purposes we may share personal data with them. Access to data is granted to a very limited number of employees in a secure environment. Alfred Intelligent SRL will not download personal data. Virtusan will update this Privacy Policy should personal data be shared with other third parties.

Where required by applicable law Virtusan may disclose certain data (for example in criminal proceedings) to authorities.

Virtusan may, on occasion, share anonymized and aggregated data and analysis results with third parties to further analyze and improve the Services.

Where your data are stored

Personal identification data of users are stored on servers in the EU. It is your responsibility to keep your passwords confidential and at a safe place. Transmission of data via the internet is not completely secure. Transmission of data is at your risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.

Your Data Rights

We are required to and will comply with all applicable data protection regulations applicable to our users. The General Data Protection Regulation (”GDPR”) of the European Union gives certain rights to applicable individuals.

Such rights include: (i) Transparency over how we use your personal information (right to be informed); (ii) The ability to request a copy of the information we hold about you, which will be provided to you within one month (right of access); (iii) Update or amend the information we hold about you if it is wrong (right of rectification); (iv) Ask us to stop using your information (right to restrict processing); (v) Ask us to remove your personal information from our records (right to be ‘forgotten’); (vi) Object to the processing of your information for marketing purposes (right to object); (vii) Obtain and reuse your personal information for your own purposes (right to data portability); (viii) Not be subject to a decision when it is based on automated processing (automated decision making and profiling).

Should you wish to exercise one of these rights you may contact us by email to <[email protected]>. We will respond to your request as soon as possible and in accordance with applicable law. You may also contact us via the tools provided in the preferences section of the App.

Virtusan Terms & Conditions

This Privacy Statement is part of the Virtusan Terms & Conditions which you can find **here**. The Virtusan Terms & Condition shall apply to this Privacy Statement.

Your use of the Services

We are committed to help you to make best use of the Services. However, you are responsible for using the Services exclusively in compliance with the Virtusan Terms & Conditions and in compliance with applicable law in your jurisdiction.

GDPR Representative (art. 27 GDPR; if Services are provided in the EEA or the UK)

We have the following data protection representative pursuant to art. 27 GDPR in the European Economic Area (EEA) including the European Union (EU) and the Principality of Liechtenstein as an additional point of contact for supervisory authorities and data subjects for requests in connection with the General Data Protection Regulation (GDPR):

Virtusan Intelligent SRL, Romania.

Name and Contact Details of the Controller (art. 4 Section 7 GDPR)

Virtusan AG

St. Niklausenstrasse 19

6005 St. Niklausen LU

Switzerland

Telephone: +41 44 594 81 47.

Email: [email protected]

Amendments to this Privacy Policy

Virtusan reserves the right to amend this Privacy Statement at any time, and only the current Privacy Statement may be deemed effective. Regardless of later updates or changes to our privacy notice, we will never use the information you submit under our current privacy notice in a new way without first providing you an opportunity to opt-out or otherwise prevent that use. When we post changes to this policy, we will revise the date and version number at the bottom of this privacy statement.