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FetoLife’s Privacy Policy

Last updated and effective: November 17, 2020
Please read this privacy policy carefully before using Our Service.
The Company does not permit those under 18 to use Our Service.

Welcome to FetoLife

Welcome to FetoLife Science GmbH ("us", "our" or "we"), or the FetoLife mobile health app ("App")! Together with our Terms & Conditions, our Cookie Policy, and any other documents referred therein, this privacy policy ("Privacy Policy") serves as a foundation for the processing of any personal data we track.

To better understand what kind of personal data we track, how we process it, under which circumstances we will share it with third parties, and your rights, we recommend you to read this Privacy Policy carefully. This agreement does not apply to information collected offline or by third parties not affiliated with FetoLife that our website www.fetolife.com ("Website") may link to ("Third Party Sites"). Please note that if you follow a link to any of those Third Party Sites with their own privacy policies, we do not accept any responsibility or liability for their policies. It is your responsibility to check these policies before submitting any personal data to such Third Party Sites.

FetoLife is owned and operated by FetoLife Science GmbH, a company formed under Austria's laws with domicile in Vienna, Austria. We are aware of the importance of processing personal data for you as a data subject, and the protection of your privacy is of the utmost importance to us. It is of utmost importance to us to adhere to Article 4(1) of the General Data Protection Regulation (EU) 2016/679 ("GDPR") and to protect our customers' ("users") (personal) data and their privacy when using our Services.

When using our Services through our App, or accessing our website or any service and/or product we may provide you (Website together with the App, and any of our product and services, the "Services"), you will be asked to indicate your acknowledgment of, and where applicable, give your consent to the practices described in this policy.

This Privacy Policy applies to any personal data processed by

FetoLife Science GmbH

Vorgartenstraße 217

1020 Vienna, Austria

Registered Corporate Headquarters: Vienna, Austria

Vienna District Court Corporate Registration Number: FN 521323 b

VAT Number: ATU75080948

and its affiliates are the data controller (as defined under Article 4(7) GDPR) of all processing activities connected with the Services.

Questions, comments, and requests regarding this Privacy Policy are welcome and should be addressed to legal@fetolife.com. Our data protection officer is Julian Molitor.

1. Overview of Data We Collect

When tracking and processing (personal) data, we differentiate between those you provide to us as input data and those we collect about you.

In terms of (personal) data that may provide to us, you may be asked to share the following information with FetoLife: your name, password, passcode, ID (for support and data requests, if required), gender preference, date of birth, email address, phone number, symptoms of your illness, potential causes of your illness symptoms, health, and well-being (i.e., weight, blood pressure, glucose level), data on your baby(ies) (i.e., fetal activity), healthcare-relevant lifestyle information (i.e., activity, sleep, nutrition), health insurance, medical history, any allergies you have, any medication you may take, or further information required to verify your identity. As stated in chapter 3, you may opt to integrate FetoLife with third-party services (e.g., Apple Health or Google Fit App Database) to import your personal health and activity data. Such personal health and activity data may be blood pressure and glucose, birth date. However, before processing this kind of data, we will explicitly ask for your consent on the registration screen.

In terms of (personal) data that we may collect about you, we may track the following information during your Website and/or App visits:

We may track usage-related data such as technical information about your device (e.g., device-specific data, details of Website, and/or App visits). We may track analytics-related data such as your IP address, time zone, browser type, and operating system; app store from which you downloaded our App; visit duration per page, and page interaction information. We may send cookies to your mobile device or computer or engage other tracking technologies to collect this information. For more information, please read our Cookie Policy. We may partner with third-party providers like Amplitude that provide us some of your attribution data that we further utilize to customize and personalize your App experience. We may also use such data for statistical purposes and analytics.

We do not accept any responsibility or liability if you share third party data with us. It is your responsibility to obtain clear permission from the individuals. Any reference in this Privacy Policy to “your data” shall include data about other individuals you have provided us with.

2. Data Processing Activities

After having outlined what kind of data we may collect and process, this chapter summarizes all our data-related processing activities by highlighting what kind of data we may process and for which purposes.

When you use our Website:

When using our website, we may process the IP address of the requesting device, date and time of access, name and URL of the requested file, Website from which access is obtained (“Referrer URL”), browser used, and, where applicable, your device’s operating system and the identity of your access provider. We use that data to grant you access to our Website, which needs to establish an internet connection and ensure the system’s security and stability. We also use that data for additional administrative purposes.

When you register a user account in our App:

When registering a user account in our App, we may process data such as email address and password, user ID, device ID, profile name, gender, date of birth, pregnancy due date, expected number of babies, general data about your health (optional), date and time of registration. We use that data to create a user account and grant you access to our Services. We use your health data to deliver our health risk assessment evaluation. Please note that it is impossible to access our Services if the required data are not provided.

When you register a user account with Apple or Google Log in:

When registering a user account with Apple or Google login, we may process your Apple/Google ID, email (if provided), time, and login date. If you choose to use and log in with Apple or Google, we will receive the data listed above from Apple or Google with your approval to populate your user data in the App and to verify your identity. Please note that if you use the Apple or Google login, Apple or Google will also process your data (login). We are not responsible for this data processing.

When you use our App:

When using our App, we may process your profile name and related personal health data (i.e., illness symptoms, potential causes of illness symptoms, risk factors, relevant and/or related medical history, and time and date of assessment) for the risk assessment evaluation. We use that data to provide you with our Services, for example but not limited to, our pregnancy risk level evaluation.

Analysis of risk-related information:

When analyzing risk-related information, we may process your FetoLife account ID (when applicable), profile ID (when applicable), geographic location of the assessment, time and date of assessment, data provided in an assessment (e.g., age, gender, risk factors, relevant and/or related medical history), assessment result, and data related to software and hardware (such as version numbers, operating system, and device ID). We use that data to ensure high quality and safety standards of our Services. For our health risk evaluation, it is relevant to review the quality of the evaluation results. However, whenever possible, we only use pseudonymized data and, when applicable, aggregated data to evaluate the health risk assessment results. Based on the outcomes, we determine if any improvement is needed for our risk assessment evaluation system and any medical product we develop to meet the highest quality and safety standards.

Use of health data for statistical and research purposes:

When conducting statistical- and research-related studies, we may process your FetoLife account ID (when applicable), case ID, profile ID (when applicable), gender, age, location, health risk level, potential causes of risk level, risk factors, evaluation results including medical history, illness symptoms, time and date of evaluation, and possibly other health data that you may have provided us. We use that data to conduct pseudonymized and aggregate statistics and research studies. We may share the results as summarized statistics with our partners on an irreversibly anonymized basis.

Direct marketing for our own similar products and services:

When advertising our own similar products and services, we may process your profile name, date of birth, gender preference, phone number, email address, location, health risk level, symptoms, potential causes of risk level, health and well-being (i.e., weight, blood pressure, glucose level), data on your baby(ies) (i.e., fetal activity), healthcare-relevant lifestyle information (i.e., activity, sleep, nutrition), medical history, health insurance, any allergies you have, any medication you may take. We use that data to communicate with you directly and provide you with only the information we may think are of interest in your individual case. Of course, you can adjust your marketing preferences by changing your settings at the bottom of each marketing email.

Provide safer services by monitoring App usage:

When monitoring the app usage, we may process your FetoLife account ID (when applicable), profile ID (when applicable), IP address, device ID, date of birth, gender preference, phone number, email address, location, health risk level, symptoms, potential causes of risk level, risk factors, assessment results, medical history, any allergies you have, health insurance, any medication you may take. We use that data to provide safer services, analyze usability, and ensure the highest safety and security standards. We also aim to improve the general functionality of our App. However, whenever possible, we only use pseudonymized usage data that we collect through our third-party service providers (e.g., Amplitude Inc.), which is not linkable with your personal data. Please note that your personal data will be transmitted and stored on the servers of Amplitude Inc. You can find further information in Amplitude's privacy policy: https://amplitude.com/privacy.

Monitor usage to ensure and improve functioning, proper use, and maintenance of our services: When monitoring usage, we may process your IP address, device ID, browser type and operating system, visit duration per page, and page interaction data (e.g., time and date, finger gestures, scrolling, mouse-overs, clicks). We use that data to ensure and improve our Services' functioning, proper use, and maintenance.

Feedback/Surveys:

When sending out feedback/surveys, we may process your email address (optional), feedback text, and data provided in the health risk assessment evaluation. We use that data to understand your perception of and experience with FetoLife’s products and Services (i.e., level of satisfaction). Based on the results, we aim to improve our offering and actions to meet your needs better and ensure our offering's high quality and safety standards.

3. Apple Health App Integration

You may opt to integrate FetoLife with Apple's Health Kit. If you grant FetoLife access to Apple's Health App Kit, FetoLife will access and transfer your data from the Health App Database into our App in certain circumstances, such as to aid you in tracking health data. However, unless you grant us access to your Apple's Health Kit, FetoLife cannot read from or write to the Health App Database. Data accessed from Apple's Health Kit will never be shared with third parties, such as third-party service providers and/or advertisers.

FetoLife is in no way responsible for the protection of the Personal Data and/or other information stored within Apple's Health App Databases. Please note that you and Apple are solely responsible for protecting Apple's Health Kit's information. We recommend you to review Apple's applicable policies and procedures before syncing and backing up your Personal Data and/or other information with the Health App Database.

4. Cookies and Tracking on our Website

Based on your consent (where required by law) or on legal regulation, our Website and our App use so-called "cookies" or other tracking technologies (all technologies are referred to "cookies" in this policy). Cookies are sent to your computer, tablet, mobile device, or other technologies. Cookies collect data on our Website and App (e.g., IP addresses, place, and time of the users' visit). All data collected are pseudonymized and are not stored together with other personal data.

If you want to find out more about our user tracking and the cookies-related technologies we use, the reasons why we use them, and to manage your Cookie preferences, see our Cookie Policy.

5. Data Storage Location

The personal data that we collect from you through our mobile app is stored on HIPAA compliant Cloud Servers of Amazon Web Services (AWS) in Ohio, United States.

If you would like further details on the specific safeguards applied to your personal data export, please contact us via legal@fetolife.com.

6. Data Storage Duration

We will store the collected and processed data outlined in chapters 1, 2, 3, and 4 for as long as it is necessary to provide you with the Services and respond to any specific issues that may arise or, otherwise, as required by law or by any relevant regulatory body.

Your data is irreversibly anonymized (and cannot be associated with a specific natural person) when you request deleting your account or delete your account in the App yourself. Please note that if your account is inactive for more than 24 months, we will reach out to you to check whether you wish to continue using our Services. If you leave your user account unused for another 12 months, we will delete your account and anonymize your data (it will no longer be possible to associate those anonymized data with a specific natural person)

7. Disclosure of Your Personal Data

We use third-party solutions to provide our Services, which act as our processors based on a data processing agreement. Here is a full list of our third-party processors processing your personal data on our behalf and strictly according to our Privacy Policy:

Amazon Web Services, Inc.

Segment

Amplitude Inc.

Mailchimp

iTechArt

MailGun

PubNub

Protected health information (PHI) will only be processed in a HIPAA compliant setting. All 3rd parties processing PHI need to have a Business Associate Addendum (BAA) in place with FetoLife.

We ensure that we only select those technical service providers outside the EEA (a technical service provider from a third country) that has received a European Commission decision on the appropriateness or suitable guarantees for this third country. Except for the purposes below, we do not transfer your personal data to third parties.

In case we sell or buy any business or assets, we may share personal data with a prospective seller or acquirer of such business or assets.

In case we or, substantially, all of our assets are acquired by a third party, our users' personal data will be one of the transferred assets.

In case we are required based on EU law or a Member State's law to disclose or share your personal data.

In case we conduct a statistical- or research-related study on behalf of a partner, we may disclose anonymized and aggregated data to this partner.

If you use our mobile app, we may disclose certain data to the partner that hosts the mobile app if necessary, for the performance of a task carried out in the public interest, and always comply with applicable laws (e.g., including but not limited to GDPR).

8. Your Rights

Under data protection law and with regards to your personal data, you have the right to deletion, information, objection, limitation of data processing, revocation of the declaration of consent, and correction of your personal data for the future. You also have the right Besides, you have the right to assert your claims in court or to file a complaint with the responsible data protection authority. All of these rights can be exercised by sending us an e-mail to legal@fetolife.com.

We will exercise your rights within 30 days after receipt. In some cases (e.g., for full erasure of your Personal Data stored in our backup systems), it may take us up to 90 days to execute on your rights. We will let you know if we need more time and explain the reasons for the delay.

9. Privacy Information for California Residents

The California Consumer Privacy Act ("CCPA") (active since January 1st, 2020) supplements this Privacy Policy by providing additional information with regards to your rights concerning your "personal information". It applies solely to all residents, users, and visitors consuming FetoLife's Services in the State of California. FetoLife does not and will not sell or transfer your personal data to any external third-party organization without providing you the right to opt out. To fulfill the processing objectives outlined in chapter 3, we may transfer some of your personal data to third-party service providers with whom we have a data protection agreement in place.

Under CCPA, Californian consumers have the following rights:

Under Article (1798.100) (a) CCPA and Article 1798.110 (a) CCPA), Californian consumers have the right to access any personal information we collected (e.g., the categories and specific pieces of personal information incl. their sources, the purpose of the collection, and categories of third-party service providers with whom we shared this information).

Under Article (1798.105) CCPA, Californian consumers have the right to delete any personal information that we have collected in the past. Upon verifying your request, we will delete your personal information from our records and ask any third-party service provider to process your personal information to delete their records of your data. However, when Article 1798.105 (d) CCPA is applicable, we might not delete your personal information to comply with a legal obligation, to ensure the provision of our Services, to identify and repair errors that impair existing intended functionality of the App, to detect security incidents, or to engage statistical research in the public interest.

In addition to the possibility to contact us by sending an e-mail to legal@fetolife.com, you can exercise any rights under CCPA.

10. Security Breaches

In case we identify a security breach in our systems, we may either post a notice or attempt to notify you by email. As determined in applicable law and this Privacy Policy, we will take immediate and reasonable steps to remedy our systems' security breach. In case we identify a potential Personal Data breach, we will also undertake immediate and specific actions to remedy the breach (i.e., logging you out from all the devices, resetting a password while also sending a temporary password for you to apply). Besides, we will also perform other reasonably necessary activities and actions. If you want to report a security incident related to the App, please contact us at legal@fetolife.com.

11. Changes to This Policy

Any updates we make to this Privacy Policy in the future will be released on this page, and where appropriate, notified to you by email or notifications via the App. Therefore, we encourage you to review it from time to time to stay informed of how we are processing your data.

12. Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: legal@fetolife.com