Disclosure:

“Onar’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.”

Privacy Policy

Version: 29/06/2023

PLEASE READ THE FOLLOWING DOCUMENT CAREFULLY AS IT CONTAINS IMPORTANT INFORMATION ABOUT THE HANDLING OF YOUR PERSONAL DATA.

Onar, is an application developed by Raivotech company (thereafter: “we”, ”us”) and is focused on improving the health status and life quality of the subject-user (thereafter as: ”you”, “user”) using various computational techniques (thereafter: ”Analysis”) and the data collected by your wearables, smart devices or other devices. This document describes what kind of information is collected from you while registering at our application, website, and related services (thereafter ”Services”), how this information is collected and how it is going to be used. Raivotech is responsible for the collection, safe storing, anonymisation, analysis and finally deletion of the data. Raivotech is responsible for providing you with the Services.
Our company is following the EU Data Protection Ordinance (GDPR).
No personal data that is not needed for our analysis, your doctors, for improvement of our Services or to contact you and provide you with our Services is collected.
Website Usage and Analytics Information can be used for advertising purposes.
For our Analysis we follow GDPR compliant pseudonymisation of your data, meaning 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 (GDPR Article 4).
By accessing our site, using our application, or registering for our Services, you acknowledge that you have read, understood, and agreed to the following Privacy Policy and Terms of Use.

1. Consent

By registering for the use of our Services, you give consent to us to use the collected data as described in this Privacy Policy. You can withdraw your consent at any time; however, this may result in your inability to use part of or all our Services.

2. How we collect data

The collection of data of the user is performed in the following ways.
2.1. On the website:
• When you voluntarily contact us using the embedded Contact field. By choosing to contact us, your details will be stored for the processing of the enquiry and for any possible follow-up questions.
• By using or viewing our website via your browser’s cookies.
• User Personal Information is shared with third party service providers who process it on our behalf to provide or improve our Service. All third-party service providers follow the GDPR.
2.2. On the application:
• By registering for our services through our application and by creating a user account and profile, either by using an email address or one of your Social Network Site (“SNS”) user accounts
• By connecting the user account to an existing user profile of a collaborating application (such as but not limited to Google Fit, Garmin, Fitbit etc.). With your consent, Onar will then receive data from the selected application.
• Data is automatically collected by the application by the connection and synchronisation with third party applications, such as Google Fit or Apple’s HealthKit API. Data can be collected by the device the application is installed on or any other compatible and synchronised with the application device, including but is not limited to, smartwatches, heart rate monitors, blood pressure monitors, and smart scales.
• In regular time intervals you will be prompted to respond to various questionnaires regarding your health status, daily activity, sleep patterns, daily diet and more. You may reject answering and interacting with the questionnaires; however, this may restrict the functionality of the application and the quality of the provided Services.

3. Data collected

3.1. Website
Usage and Analytics Information will be collected while browsing our website via the use of information-gathering tools, such as cookies, log files, and Web beacons.
You may reject the use and storing of information-gathering tools; however, this may restrict the functionality of the website.
The collected information can include:
• Website preferences
• Browser type and language
• Information regarding your device, operating system
• Your location
• Internet Protocol (“IP”) address
• Information about the website use, such as: links clicked, web pages viewed, time spent on website.
3.2. Application
For our application to provide the advertised features we ask for and collect information about you. This includes contact information, device information, biometric data and data concerning health.
3.2.1. Automatically collected information about the user contains information about the details of your devices:
• Device type and model
• Operating system
• Language
3.2.2. Contact Information is either provided by you when you create a new account or automatically collected by the SNS you choose to register with.
• Username and password for your account
• Email address
3.2.3. Personal Information can be provided by you or from the SNS you chose to register with, depending on the privacy settings of your SNS account. This information is necessary for our Analysis.
• Sex
• Date of birth
• Height
• Weight
3.2.4. Biometric Data and health related information, which can be collected by your devices and includes, but is not limited to:
• Heart rate
• Step count
• Blood pressure
• Weight
• Activities, such as: type of activity, duration, location data, other data provided by your device.
• Other sensor data, such as: VO2max, body fat and muscle percentage, heart rate variability, stress levels
• Other data, such as: sleep patterns and habits
• Your replies to the questionnaires
3.2.5. Medical History: You have the option to voluntarily disclose information regarding any chronic, periodic, or intermittent medical conditions you may be experiencing. This information is important to ensure accurate and reliable Services by Raivotech, for the participation in research studies, or can be useful to the medical professional of your choice. Examples include, but are not limited to:
• Insomnia
• Apnoea
• Diabetes
• Respiratory issues (cold, flu, COVID-19)
• Seasonal allergies
3.2.6. Optional Information that can be provided but is not necessary for the Analysis. You can upload, edit, update, or delete the following at any time without restriction of the available to you Services. You have the right to maintain an anonymous account by not providing us with your first and last name.
• First and last name
• Gender
• Profile photo

4. How we will use your information

4.1. Website:
• Analytics Information from the website will be collected and will be used by us for statistical evaluation and improvement of our Services.
4.2. Application
• The collected by Onar data will then be pseudonymised by assigning a unique and safe user key. Finally, all information related to you as a user will be separated from the collected data.
• Your data will be analysed using the computational methods that the team of Raivotech is developing.
• Your contact information will be used to notify you for your user account details (such as but not limited to password recovery), Raivotech and Onar news and updates, Onar blog posts, and to provide you with our Services.
• Your data will additionally be used by Raivotech and Onar for internal purposes such as but not limited to improving our Services.
4.3. Medical and research purposes
• With additional and explicit consent, you can share your data and the results of our Analysis with a medical professional of your choice, who has established an agreement with Raivotech. You can find more information in Section 6 of this document.
• With your explicit consent, your data may be used for research purposes. More information can be found in Section 7 of this document.

5. Storing of Information

By synchronising or connecting your Raivotech account with an SNS account or third-party application such as Google Fit, you allow the transfer of information from the servers of these SNS, which may be in other countries to the servers of Raivotech. For more information you should consult the Privacy Policies of the corresponding SNS.
To delete all your information from our servers, you must explicitly make an erasure request when you delete your account.
In case your account remains for more than one (1) year inactive, we will send you an email asking you, whether you want to continue to use our Services. If you do not reply or choose to not use our Services any longer:
1. You will be asked to answer a few questions about the use of our Services.
2. The answers to the questionnaire and data about the ways you used your account will be collected and stored. Personal information that can lead to you will not be collected or stored.
3. Your account will be deleted. You can, therefore, create a new account using the same email address.
4. The collected health-related data will be deleted.
All your data is securely stored by providers who explicitly follow the GDPR. Your information may be stored outside EU and EEA and all transfers comply with the European Commission approved standard contractual clauses for data transfers from data controllers in the EU to data processors and/or controllers established outside the EU or European Economic Area (EEA). More information can be found at:
https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en .

6. Cooperation with Professionals

With your explicit consent and agreement, you can share your data and the results of our analysis of your data with a medical professional, physician, clinic, or other professionals. The medical professional must have an active cooperation with Raivotech and must have ensured the safety and protection of the patients’ data.
The medical professionals can have access to their patients’ records through a dedicated platform, ensuring the doctor-patients confidentiality.
The cooperation with medical professionals can have two goals:
1. To provide your medical professional with more information about you and your health.
2. For research purposes. For more information about Research, please refer to the respective section.

7. Research

Raivotech may perform research studies in cooperation with other research institutions such as Universities or hospitals. At the beginning of any research project, you will be prompted to select whether you want to participate in the research project. By accepting the research project terms, your de-identified biometric, health-related, and demographic data, such as heart rate, fitness activity, sleep patterns, age, sex and others will be used for the research purposes.
The results may be published in academic settings such as: scientific journals, conferences, or other .
You can always opt-out from use of your data in any research project by changing the settings in your account.
For each research project we will provide additional terms and policies, which you will have to read, understand, and explicitly agree, in order to participate in the research project.
Nevertheless, participation in any research project is OPTIONAL and by denying or withdrawing your participation:
7.1. Functionality of the application will NOT be compromised. Data will continue to be collected from your devices and analysed to provide you with our regular Services.
7.2. The collected data and the results from the Analysis will NOT be used for any research purposes.

8. Marketing

We will use your Contact Information to notify you about updates, new features, and special offers regarding our Services, via email and in-app notifications. You can also choose to subscribe to our newsletter regarding new research, health habits and tips, and seasonal warnings and advice. By subscribing to the newsletter, you agree to the use and the statistical evaluation of data such as, links clicked on. This information will only be used by us to adjust and improve the newsletter services. You can change your subscription status about these email notifications at any time without restriction to the features of the app.
You can use features and Widgets from various SNS, such as: “Facebook Connect”, “Facebook Like” and “Share”, and “Google Sign-in”. These features may collect information from you. Please read the respective Terms of Use and Privacy Policy documents for more information. Raivotech is not responsible for the information collected by these features.
You will be notified about major changes in the Terms of Use, the Privacy Policy or any other legal information, regardless of whether you are subscribed to the regular email notifications either email or a pop-up notice when accessing the application. Raivotech will not notify the users about minor corrections or small clarifications in the Terms of Use or the Privacy Policy. You are responsible to carefully read and understand these documents. Please check regularly for any updates, changes or modifications made in our Privacy Policy. Accessing and using our website and/or application you acknowledge that you have read, understood, and agreed to any updates, changes or modifications.

9. Advertising

No health-related data or information that can be used to identify you will be used for advertising uses.
For advertising purposes, we use Facebook, Google and other advertising and marketing tools. Please carefully read the privacy policy of these service providers at the following websites:
https://www.facebook.com/policies/ads#
https://policies.google.com/technologies/ads
For these reasons:
9.1. Information-gathering tools, such as cookies and Web beacons can be used for targeted advertisements, in the application and the website. Biometric and health-related data are excluded from advertising purposes.
9.2. Usage and Analytics Information will be collected but only used by Raivotech for statistical evaluation and improvement of our Services.

10. Your rights

Based on the conditions laid in the GDPR you are entitled to a range of rights regarding the protection of your Personal Data such as:
• The right to be informed.
• The right of access.
• The right to rectification.
• The right to erasure.
• The right to restrict processing.
• The right to data portability.
• The right to object.
• Rights in relation to automated decision making and profiling.
More information can be found at:
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679

11. Contact us

By choosing to contact us, your details will be stored for the processing of the enquiry and for any possible follow-up questions.
In case you have any comments, questions, suggestions, complaints or require additional information you can contact:
info@raivotech.com