Overview

We are happy that you have shown interest in our company and products. Data protection is of high priority for us. The use of the Internet pages of the Exakt Health GmbH is possible without any indication of personal data; however, to use some of our services, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain the users consent .

The processing of personal data, such as the name, address, e-mail address, or telephone number of a user shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Exakt Health GmbH. By means of this data protection declaration, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. We also inform them about the rights to which they are entitled.

As the controller, we have implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.

Definitions

The data protection declaration of the Exakt Health GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

Personal data Personal data means any information relating to an identified or identifiable natural person (“user”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

User User is any identified or identifiable natural person, whose personal data is processed by us

Processing Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

Profiling Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymisation Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific user without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Third partyThird party is a natural or legal person, public authority, agency or body other than the user, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

ConsentConsent of the user is any freely given, specific, informed and unambiguous indication of the users wishes by which they, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them.

Name and Adress of the Controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Exakt Health GmbH

Ebersstraße 18 c/o Billaudelle

10827 Berlin

Germany

Email: info@exakthealth.com

Website: www.exakthealth.com

Rights of the User

You have the following rights concerning your personal data: right of access according to Art. 15 GDPR, right of rectification according to Art. 16 GDPR, right to erasure according to Art. 17 GDPR, right to restriction of the processing according to Art. 18 GDPR, right of revocation according to 21 GDPR, as well as the right to data portability according to Art. 20 GDPR. Please note, that the restrictions of sec. 45, 35 BDSG apply to the right of access and the right to erasure. In addition to that, according to Art. 77 GDPR and sec. 19 BDSG you have the right to appeal the German Data Protection.

Please address any requests in written form to:

Exakt Health GmbH

Ebersstrase 18

10827 Berlin

E-mail: service@exakthealth.com

Cookies

Our website uses cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of users from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, Exakt Health GmbH can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system.

The user may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the user deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

General Data and Information collected on the Website

The website of the Exakt Health GmbH collects a series of general data and information when a user or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, the Exakt Health GmbH does not draw any conclusions about the user. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Exakt Health GmbH analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a user.

Subscription to our Newsletter

On our website, users can subscribe to our newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as the start of the subscription.

We inform our users and business partners regularly by means of a newsletter about our offering. The newsletter may only be received by the user if (1) they have a valid e-mail address and (2) they subscribed to the newsletter. A confirmation e-mail will be sent to the e-mail address entered by the user when they subscribe, for legal reasons, in the double opt-in procedure.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the user at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a user at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. The subscription to our newsletter may be terminated by the user at any time. The consent to the storage of personal data, which the user has given for sending the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter or it can be communicated to us directly by email.

For registering new subscribers and sending the newsletter we use the functions of the online marketing platform Mailchimp operated by The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States. Mailchimp acts as a data processor on our behalf. Mailchimp will receive your personal information such as name, email address and expressed newsletter interests as indicated when subscribing to the newsletter. When you interact with an email campaign that you receive from us, mailchimp will automatically collect information about your device and interaction with the email. Further information about mailchimp and its privacy practices can be found here: https://mailchimp.com/legal/privacy/.

This automatic newsletter tracking is based on so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the we may see if and when an e-mail was opened by a user, and which links in the e-mail were called up by users. Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by us in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the user.

Users are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. We automatically regard a withdrawal from the receipt of the newsletter as a revocation.

Contact form on our website

Our website contains a contact form that allows direct communication with us, which also includes a general e-mail address. If a user contacts the controller by e-mail or via a contact form, the personal data transmitted by the user are automatically stored. Such personal data transmitted on a voluntary basis by a user to the data controller are stored for the purpose of processing or contacting the user. We use the services of Google workspace operated by Google Ireland Limited to receive and answer your requests.

External services used by Exakt Health

Branch.io

As part of our Analytics, Exakt Health uses Branch on our website and application. This service allows us to better understand our end users’ application experiences, and derive additional insights into how our Users download and utilize our application.

More specifically, we use the Universal Ads Module inside Branch which allows us to track ad conversions across every device and platform to understand our true campaign ROI. Branch itself has no direct relationship with Users. In order to work with Branch, “Branch Mechanisms” is installed which captures User action. Using the information collected from these Branch Mechanisms, Branch uses a variety of attribution techniques to connect User actions across different channels and platforms. Some of these attribution techniques include a direct pass-through of identifiers from platform to platform, creating and storing identifiers unique to the Branch platform to connect User actions and identifiers together, and predictive modeling algorithms using real-time and historical data parameters observed from User interactions where there are no shared identifiers available, as well as using historical connections Branch has derived over time using their technology. In some cases, these connections are made without the use of cookies.

Information collected by Branch as a result of URLs used by us and pixels placed on our Website include but are not limited to your IP address, Engagement Data, Cookies and Referer.

Collected data is limited to what is strictly required by Branch in order to provide good results. Names, email addresses, physical addresses or SSNs are types of personal data not collected by Branch. Branch also only shows us actual User data. Which means an end User must visit the Website or download the App before Exakt Health receives data on the customer’s advertising identifier. Data collected by Branch is also not sold or made available to any other entity except for its customer, in this case Exakt Health. Data acquired from Users can also be requested to be deleted at any time by the User.

Website Analytics with Google Analytics

We are using the component of Google Analytics (with the anonymizer function) on our website. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the user is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the user. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the user will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the user, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the user. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the user, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The user may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the user. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the user has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the user must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the user is later deleted, formatted, or newly installed, then the user must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the user or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://google.com/policies/privacy/ and under http://google.com/analytics/terms. Google Analytics is further explained under the following Link https://google.com/analytics/.

Mobile Analytics with Google Analytics and Crashlytics

We are using Google Analytics and Crashlytics for Firebase in our mobile applications.

Google Analytics for Firebase collects user and event data during the use of the mobile application that helps us understand how the App is being used and how we can improve the overall In-App experience as well as user acquisition. Firebase collects the information using identifiers for mobile devices and utilizes technologies similar to cookies. The following type of information is collected during the process: number of users and App session, session duration, operating systems, device models, geography, first App launch, App opens and App updated. The full list of events captured in our implementation can be found here. You can find a full list of user-dimensions collected here. All data on an individual level is deleted latest after 14 months after it has been collected.

Firebase Crashlytics allows us to collect technical data about App crashes and monitor the technical stability of the App. The collected data consists of a crashlytics installation ID and crash traces when an App crash occurs. The data will be deleted after 90 days.

The operator of the Google Analytics and Crashlytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland. Find more information about the privacy and security measures in Firebase to protect your data here.

You are able to object to a collection of data generated by Google Analytics and Crashlytics for Firebase. Go to the settings page of the App and move the respective toggle for Google Analytics and Crashlytics to Off.

Use of Google-AdWords

We are using Google AdWords on our website. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.

The operating company of Google AdWords is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.

If a user reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the user through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the user. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.

The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the user.

The conversion cookie stores personal information, e.g. the Internet pages visited by the user. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the user, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The user may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the user. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.

The user has a possibility of objecting to the interest based advertisement of Google. Therefore, the user must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.

Further information and the applicable data protection provisions of Google may be retrieved under https://google.com/policies/privacy/.

OneSignal

We are using the services of OneSignal that allow us to send you in-app messages and mobile push notifications. With In-App messages we can inform you about new product features or collect your feedback about the App via surveys. If you allow notifications, we will send you push notifications as reminders to help you stay on track with your training program. You can disable push notifications at any time via the settings of your mobile device.

In order to use OneSignal’s services we share information such as the device information ,a push token, language, country and last time of app open with them.

You can find further information and applicable data protection provisions of OneSignal under: https://onesignal.com/privacy_policy

RevenueCat

The Exakt Health Premium subscription uses RevenueCat. RevenueCat’s platform allows us to integrate with Apple’s App Store and Google’s Play Store and offer you our Premium content as a convenient In-App Subscription. In order to create and manage your subscription with the mobile stores we share an anonymous ID, mobile device and country information of the user with RevenueCat. In addition, RevenueCat collects anonymous purchase history limited to Exakt Health subscriptions only, for the purpose of managing access to the paid content of Exakt Health.

We don’t share any sensitive personal identifiable data with them. RevenueCat does not collect payment information from users and they are obligated not to disclose or use any information for any other purpose.

You can find further information and applicable data protection provisions of RevenueCat under: https://www.revenuecat.com/privacy/

Legal basis for Processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the user is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the user or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the user which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the user is a client of the controller (Recital 47 Sentence 2 GDPR).

Storage Period

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

Changes

Exakt Health reserves the right to, at any time, amend this agreement. Users will be informed in a timely manner before the changes come into effect. You are encouraged to review the updated Terms & Conditions to safeguard yourself from any liability that you may face as a direct result of changes being made to this agreement.

Please note that your continued use of our Services will serve as your acceptance to our updated Terms & Conditions.

We may also provide updates to our app which would include bug fixes, new plans and/or other things to improve the functionality of the app and provide a better experience to our users. Users are encouraged to keep their App updated either by enabling automatic updates or by manually updating the App in their mobile system to ensure that the App keeps working in the manner intended.

Contact

If you have any queries, comments or requests relating to our Privacy Policy please email us at service@exakthealth.com or write to us at:

Exakt Health GmbH

c/o Billaudelle

Ebersstraße 18

Germany

10827 Berlin