Privacy policy

Effective Date: May 14th, 2018

Introduction 
In this Privacy Policy Resilio ApS (“Resilio” or “we”, “us”, and “our”), wants to inform you about how we collect, use and disclose personal data from and about you, when you sign up to or use our application (“the App”).

You can find a table of content and a brief summary of this Privacy Policy in the chart below. For further details with regard to the data processing carried out by Resilio click on the links in each section of the summary.

Summary 

IssueInformation
What and who this Privacy Policy covers?Resilio is the data controller of the personal data we collect from and about you through the App.

This Privacy Policy applies to all users who have registered with or subscribed to the App. 

For further information see section 2.

What kind of personal data do we collect about you?Resilio might collect data from and about you. 

More in particular, Resilio collects (1) registration data, (2) training program and progress (3) pulse (skin) readings (4) breathing pace (5) activity data, and (6) and any other data that you decide to give to us e.g. when answering questions about your health.

Please be aware that the collected data includes sensitive data relating to you. 

For further information see section 3.

Failure to provide any of the data can entail the impossibility to offer you to use the App.

How do we use your personal data?The main reason why we collect data about you is to make it possible for you to get the full function out of the App and to make it possible for you to use our digital training programmes.

In addition, and with your prior consent, we can send you offers promotions and marketing communications, also based on your personal preferences and habits.

We may also use your personal data for other reasons- For further information see section 4.

On what ground do we use your personal data?Your personal data is mainly collected in order to provide you with the possibility of using the App and the digital training programmes, which is a legal basis for processing. 

When your personal data is processed for marketing purposes, the processing will be based on our legitim interest. However, we do not send you any marketing without asking you first.  

Some of your personal data is also necessarily collected to comply with certain legal obligation or to protect the legitimate interest of the Resilio.

When processing sensitive data, we will in most cases need your explicit consent. Therefore, a separate consent-form will be made available to you.

For further information see section 4.

How do we process your personal data?The security of your data is a priority for us. For this purpose, Resilio has implemented adequate administrative, technical and physical measures designed to safeguard your personal data against loss, theft and unauthorized use, disclosure of modification. 

For further information see section 5.

Who can access to your personal data?Resilio might share your personal data with (i) service providers, (ii) national authorities, when allowed by the applicable laws.

For further information see section 6.

Is your personal data transferred abroad?Your personal data might be transferred to other countries within or outside the European Economic Area. In any case, we always make sure that appropriate and suitable safeguards compliant with applicable laws are in place to protect your personal data. 

For further information see section 7.

What are your rights with regard to your personal data?You have among others the right to access, complete, update, amend and delete your personal data.

For further information see section 8.

Retention period applying to your personal dataIn general we will retain your data only for the period necessary to fulfill the purposes for which the data was collected as outlined in this Privacy Policy. 

For further information see section 9.

Updates to this Privacy PolicyThe Resilio may modify or update this Privacy Policy also in order to comply with applicable law. 

Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. 

For further information see section 10.

How can I contact you with regard to the processing of my personal data?You can contact us at support@resiliohq.com.

For further contact information see section 11.

 

1. About Resilio
At Resilio we believe that extraordinary, intuitive and research based technology can help millions of people prevent and prevail over stress.

Therefore we have developed digital training programs that effectively improves the user’s stress resilience. The product is offered to users through app stores, enterprises and partners in the health insurance sector.

When you use our training programs and the App Resilio will collect and process certain personal data about you as further described in this Privacy Policy.

Personal data means any information relating to you including information which can either directly or indirectly tell us who you are (e.g. your full name or email address, information about your health, your mobile device and so on).

We are the data controllers of the personal data we collect from and about you through the App.

This Privacy Policy apply to all users who have registered with or subscribed to the App.

2. What type of personal data do we collect about you?
We collect (1) registration data, when you sign up to the App, (2) information about the training program you choose and your progress in the such training programs (3) information about your pulse through skin readings (4) information about your breathing pace, and (5) activity data when you access and interact with the App.

More in particular, Resilio collects the following types of data from and about you:

  • Registration data is the information you submit to register for the App. Registration Information may include, for example, name, surname, email address, gender, country, postcode, birthday date and association.
  • Training program is information about which of our training programs you are or have been using and your progression through these programs.
  • Pulse skin readings is data about the microscopic changes in your fingers skin color due to your heart beat. These changes enable us to calculate your heart rate through a standard technique called photoplethysmography and enables us to give you feedback during training as well as improve our algorithms and app.
  • Breathing pace is your individually calculated optimal pace for breathing during training.
  • Activity Data is when you access and interact with the App, we may collect certain information about those interactions. For example, in order to permit your use of the App our servers receive and record information about your device, including potentially your IP address, browser type, and other software or hardware information, and maybe including a unique device identifier assigned to that device. We may also collect and store information about your usage of the App, such as features you have used, content you have viewed and similar.

3. For what purposes do we use your personal data?
We use the personal data we collect from and about you to:

  • Administrate the App
  • Provide the App and its features (including training programs) to you;
  • Measure and improve the App and its features;
  • Improve your experience with the App by delivering content you will find relevant and interesting;
  • Provide you with user support and to respond to inquiries;
  • Protect the rights of Resilio and others: more in particular there may be instances when Resilio may use your personal data, including situation where Resilio has a good faith belief that such processing is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Resilio or our employees, agents, contractors, licensors and suppliers (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the App or members of the public; (iii) protect Resilio, as well as other third parties involved, such as our suppliers, against fraud or for risk management purposes;
  • Comply with the law or legal process; or respond to requests from public and government authorities;
  • Complete a corporate transaction, such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Company business, assets or stock (including in connection with any bankruptcy or similar proceedings). For example if Resilio  is  involved in a merger or transfer of all or a material part of its business, Resilio may transfer your information to the party or parties involved in the transaction as part of that transaction;
  • Upon your prior consent, send to you - via email, SMS, telephone, chat and social media - offers, promotions and other marketing communications regarding the App and/or third parties services / products operating in the following sectors [*], including group companies and co-branded services or features, such as contests or other promotions arranged together with a third party or Company Affiliate that may be hosted on the App or on Resilio Affiliate or third party's services;

We may use anonymized personal data or information that does no longer identify you personally, even indirectly (e.g. statistics) for additional purposes or share it with third parties.

4. On what legal basis do we process your personal data?
We only process your personal data if such processing can take place in accordance with the rules laid down in the current data protection law applicable at all times.

On the 25 May, the EU General Data Protection Regulation 2016/679 (the “Privacy Regulation”) takes effect.

The processing of your not sensitive data is based on the following legal bases of the Privacy Regulation:

  • The processing is necessary for the provision of the App and therefore it is mandatory since otherwise the services could not be provided cf. the Privacy Regulation article 6(1)(b);
  • The processing is mandatory as it is requested under applicable laws cf. the Privacy Regulation article 6(1)(c); our
  • The processing of your personal data is performed on the basis of the legitimate interest of Resilio or of our counterparties which is adequately balanced with your interest cf. the Privacy Regulation article 6(1)(f). This data processing activity is not mandatory and you can object at any time through the modalities as per Section 8 of this Privacy Policy.

The processing of your sensitive data is based on the following legal basis’s

  • The processing is based on your explicit consent cf. the Privacy Regulation article 9(2)(a). Please be aware that without your consent, it is impossible for Resilio to make the training programs in the App available to you. You can revoke your consent to the processing of your personal at any time by sending a communication to support@resiliohq.com.
  • Processing is necessary for the establishment, exercise or defence of legal claim cf. the Privacy Regulation article 9(2)(f).

5. How do we process your personal data?
With regard to the above-mentioned purposes, the data is processed through electronically and by manual means, and is protected through adequate security measures, taking into account the state of art, the costs of implementation and the nature, scope, context and purpose of processing as well as the risk of varying likelihood and severity for the rights and freedoms of individuals.

With this regards, Resilio uses appropriate administrative, technical, personnel and physical measures to safeguard personal data in its possession against loss, theft and unauthorized use, disclosure or modification.

6. Who have access to your data?
For purposes consistent with the purposes as per Section 3 of this Privacy Policy, Resilio may share your personal data to the following categories of recipients located within the European Union or outside of the European Union in compliance and within the limits of the provisions of Section 7 below:

Third parties service providers entrusted with processing activities and duly appointed as processors when required by applicable laws, e.g. cloud service providers, other entities of the group, providers of services instrumental to or supporting the App - and thus, by way of example and without limitation, companies that provide IT services, experts, consultants and lawyers - companies resulting from possible mergers, demergers, or other transformations, and

Competent national authorities in order to comply with applicable laws.

7. Is your personal data transferred abroad?
Your personal data may be transferred to countries within and outside the European Economic Area, in particular in the USA

If your personal data is transfers to a country outside the European Economic Area we will make sure, that appropriate and suitable safeguards designed to protect your personal data is put in place.

Some of the companies which we transfer data to, are certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks mechanism, and are therefore obligated to comply with special data protection requirements when processing personal data.

In any other case where personal data is transferred to a country outside the European Economic Area we will put in place appropriate and suitable safeguards designed to protect your personal data and the transfer of your personal data in compliance with applicable data protection laws, such as standard contractual clauses adopted by the European Commission as per Articles 45 and 46 of the Privacy Regulation.

8. What are your rights with regard to your personal data?
You have the right, at any given time, to be informed of what personal data we process about you, to verify its accuracy or request rectification, update or amendments of your personal.

To some extent you also have the right to request us to limit the processing of your personal data, to object to the processing and to request the erasure of your personal data

When the personal data is processed by automatic means and the processing is either (i) based upon your consent or (ii) the fact that the processing is necessary for the provision of the App, you have the right to receive an electronic copy of your personal data, which you have provided to us (“data portability”).

We give you also choices regarding our use and disclosure of your personal data for marketing purposes. You may revoke your consent, in any given time, for receiving electronic communications from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the unsubscribe instructions in our communications. You may also send a request to the address of Section 11 of the Privacy Policy. In any case Resilio may continue to send you administrative communications related to the provision of the App.

When you make a request to us please include your email address, username, name, address, and telephone number and specify clearly what information you would like to access, change, update, suppress or delete.

In all the above cases, we may contact you and ask you for more information, that are necessary to properly handle your request.

You also have the right to lodge a complaint with a supervisory authority in your Member State. In Denmark, the supervisory authority is the Danish Data Protection Agency:

The Danish Data Protection Agency
Borgergade 28, 5.
DK-1300 Copenhagen K
+45 33 19 32 00
dt@datatilsynet.dk

9. Retention period applying to your personal data
We will retain your data only for the period necessary to fulfil the purposes for which the data was collected as outlined in this Privacy Policy.

Data collected will as a main rule be retained until you cancel your account, or if you ask us to delete your personal data.

Remember that even after you cancel your account, or if you ask us to delete your personal data, copies of some information from your account may remain viewable in some circumstances where, for example, when retention of such copies is necessary to comply with legal obligation or legal defense.

We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, to comply with applicable law or legal defense.

At the end of the retention period your personal data will be either cancelled, anonymized or aggregated.

10. Update to this Privacy Policy
Resilio may modify or update this Privacy Policy for any reason (including, but not limited to, changes in applicable law and interpretations, decisions, opinions and orders relating to such applicable law). Please look at the Effective Date at the top of this Privacy Policy to see when it was last revised.

Any changes to this Privacy Policy will be notified in advance by posting the revised Privacy Policy on in the App.

If we make material chances to this Privacy Policy that change the nature or processing or expand our rights to use the personal data we have already collected from you, we will notify you in advance and provide you with a choice about our future use of the personal data, as may be required by applicable law.

11. Contact Us
If you have questions about this Privacy Policy, please contact Resilio at:

Resilio
Fiskerivej 2K, 1.
DK-8000 Aarhus C
+45 61 67 22 61
CVR 38136976
support@resiliohq.com