Privacy Policy
Legal Information
Adopted as of August 2023
Heartify LLC, a company registered and acting under the laws of the United States with registration number 001466554, having its registered office at 50 Milk St, 18th Floor, Boston, MA, United States (“Company”, ”we, “us”, or “our”), takes your privacy seriously. This Privacy Policy (the “Policy”) explains our data protection commitment and practices and describes the types of information we may process when you install and use Stress Monitor software application for mobile devices (”the App”, “our App”).
When we refer to personal data (or personal information), we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data or to an identification number (“Personal Data”).
Our Privacy Policy applies to all users and others who access the App (”Users”). We also refer to such persons by “you” in the text. The reference to the App features also includes the “Services”.
For the General Data Protection Regulation (EU) 2016/679 and applicable national legislation implementing the GDPR and, if applicable, the UK Data Protection Act 2018 and the UK GDPR (hereinafter collectively the “GDPR”), we are the data controller, unless otherwise stated. We compiled this Privacy Policy and adjusted our processes towards Personal Data in compliance with GDPR as the highest standard for protecting our users` personal data rights.
PLEASE READ THE FOLLOWING PRIVACY POLICY FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED CAREFULLY.
When we refer to personal data (or personal information), we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data or to an identification number (“Personal Data”).
Our Privacy Policy applies to all users and others who access the App (”Users”). We also refer to such persons by “you” in the text. The reference to the App features also includes the “Services”.
For the General Data Protection Regulation (EU) 2016/679 and applicable national legislation implementing the GDPR and, if applicable, the UK Data Protection Act 2018 and the UK GDPR (hereinafter collectively the “GDPR”), we are the data controller, unless otherwise stated. We compiled this Privacy Policy and adjusted our processes towards Personal Data in compliance with GDPR as the highest standard for protecting our users` personal data rights.
PLEASE READ THE FOLLOWING PRIVACY POLICY FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED CAREFULLY.
This Privacy Policy applies to Personal Data obtained through your use of the App, or when you otherwise interact with us.
The App may contain links to websites not under our control. We are not responsible for other websites' information practices or content. You should always review the policies of third-party products and services to make sure you are comfortable with how they collect and use your information.
The App may contain links to websites not under our control. We are not responsible for other websites' information practices or content. You should always review the policies of third-party products and services to make sure you are comfortable with how they collect and use your information.
Several categories of information can be processed. Your privacy is our high priority, so we prefer, to the maximum possible extent, using instruments that disable the collection of clearly identifiable information and provide us with information in aggregated, encrypted, anonymized, and/or pseudonymized (non-identifiable) form. However, we understand that some categories of such information may be deemed Personal Data, in particular, for the purposes of GDPR. With regard to such Personal Data, the rules set out in this Privacy Policy are always strictly followed.
3.1. Information that you submit
You may provide personal information directly when you use our App. This information is necessary for the adequate performance of the contract between you and us. Without such information, it is impossible to provide the complete App functionality and perform the requested services. Depending on the App's functionality, the following information can be processed:
General Information. You may fill it in when you choose to track physical parameters for your convenience, and/or share by connecting the other app to our App:
Contact Information. You may share it when you contact us via email:
Health and well-being. The App may estimate various metrics such as:
These indicators are based on RR intervals and other metrics the App collects when executing a measurement. You may also allow us to connect to third-party services, such as Apple HealthKit, to enable us to import Personal Data about your health and activities into the App, as provided by its features. When you choose to have this data imported, you are subject to Apple Health privacy policies and practices.
For measuring, the App technically accesses your camera required as a light sensor to estimate your stress level. During a measurement, images from the camera feed are processed locally on your device and deleted immediately afterward. We cannot collect, store or use the data contained in your camera roll.
The health and well-being information you submit is stored locally on your device and may be transferred to our server storage and/or service providers as necessary to provide services to you. This information is never disclosed to third parties (except our authorized service providers) unless you share it yourself.
You can remove or alter your personal information at any time. Once you uninstall App, your personal information (including Personal Data) will be stored and used for a period needed to achieve the purposes set out in Section 4 of this Policy.
Other data you may submit to us. Also, we may collect other data that you submit to us as you participate in any interactive features of our App, participate in a survey, contest, promotion, sweepstakes, activity, or event, request customer support, communicate with us via third-party social media sites or otherwise communicate with us.
Other persons` Personal Data. If you are providing information (including Personal Data) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Data as described in this Privacy Policy.
3.2. Information collected automatically
When you use the App, some information about your device and user behavior may be collected and processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in de-identified or aggregated form. We process this information based on the contract between you and us or our legitimate interest in improving our App and giving our users the best experience. If we do not access such data, we may not be able to provide you with all the App's features.
Device Details. When you use a mobile device to access our App, some details about your device are reported, including device identifiers and other metadata. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, uniquely identifying your mobile device (but not your personality). Device identifier enables generalized reporting and analytics and is used to enhance or supplement existing user information, including to customize and personalize your experience and for statistical purposes and analytics. In this regard, the following information may be collected and processed:
3.3. Information received from third parties
We may also obtain information from third parties, such as:
3.1. Information that you submit
You may provide personal information directly when you use our App. This information is necessary for the adequate performance of the contract between you and us. Without such information, it is impossible to provide the complete App functionality and perform the requested services. Depending on the App's functionality, the following information can be processed:
General Information. You may fill it in when you choose to track physical parameters for your convenience, and/or share by connecting the other app to our App:
- Gender;
- Date of birth or age;
- Weight;
- Height.
Contact Information. You may share it when you contact us via email:
- Name;
- E-mail address, and any other content included in the email.
Health and well-being. The App may estimate various metrics such as:
- Heart rate;
- Heart rate variability;
- Physical stress level.
These indicators are based on RR intervals and other metrics the App collects when executing a measurement. You may also allow us to connect to third-party services, such as Apple HealthKit, to enable us to import Personal Data about your health and activities into the App, as provided by its features. When you choose to have this data imported, you are subject to Apple Health privacy policies and practices.
For measuring, the App technically accesses your camera required as a light sensor to estimate your stress level. During a measurement, images from the camera feed are processed locally on your device and deleted immediately afterward. We cannot collect, store or use the data contained in your camera roll.
The health and well-being information you submit is stored locally on your device and may be transferred to our server storage and/or service providers as necessary to provide services to you. This information is never disclosed to third parties (except our authorized service providers) unless you share it yourself.
You can remove or alter your personal information at any time. Once you uninstall App, your personal information (including Personal Data) will be stored and used for a period needed to achieve the purposes set out in Section 4 of this Policy.
Other data you may submit to us. Also, we may collect other data that you submit to us as you participate in any interactive features of our App, participate in a survey, contest, promotion, sweepstakes, activity, or event, request customer support, communicate with us via third-party social media sites or otherwise communicate with us.
Other persons` Personal Data. If you are providing information (including Personal Data) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Data as described in this Privacy Policy.
3.2. Information collected automatically
When you use the App, some information about your device and user behavior may be collected and processed automatically. This information is generally non-personal, i.e. it does not, on its own, permit direct association with any specific individual, and we may access it only in de-identified or aggregated form. We process this information based on the contract between you and us or our legitimate interest in improving our App and giving our users the best experience. If we do not access such data, we may not be able to provide you with all the App's features.
Device Details. When you use a mobile device to access our App, some details about your device are reported, including device identifiers and other metadata. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, uniquely identifying your mobile device (but not your personality). Device identifier enables generalized reporting and analytics and is used to enhance or supplement existing user information, including to customize and personalize your experience and for statistical purposes and analytics. In this regard, the following information may be collected and processed:
- Information about the device itself: type of your device, type of operating system, and its version, model, and manufacturer.
- Information about the internet connection: mobile carrier, IP address, timestamp, and duration of sessions.
- Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or device, language setting, and time zone.
- Device identifiers and technical identifiers (e.g. IDFA).
- Information about the App: name, API key (identifier for application), version, and App properties can be reported for automated processing and analysis.
- Cookies and similar technologies. When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information downloaded to your device when you access the App. The text file is sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access specific areas or features within our App. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that interest you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.
- Log file information. Log file information is automatically reported each time you request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including the time and date when you start and stop using the App and how you interact with the App.
- In-app events. When you use our App, analytics tools automatically record in-app information (tutorial steps, leveling up, payments, in-app purchases, custom events, progression events, etc.).
3.3. Information received from third parties
We may also obtain information from third parties, such as:
- Our authorized resellers, distributors, and partners if there is a lawful basis to do so. For example, if you purchase access to the App through one of these partners.
- Other third parties, such as email campaigns, marketing partners, and publicly available sources. We may use this information to enhance the information that we already maintain about you and to improve the accuracy of our records, in addition to other purposes described in this Privacy Policy.
We will handle your Personal Data using one or more of the following legal bases, depending on which features of our App you use:
Purpose of processing:
To make our service available
Legal basis for processing:
Contract
Example:
We use functional information and information that is processed automatically to provide you with all requested services
Purpose of processing:
To communicate with you and send you system and transactional messages
Legal basis for processing:
Contract, legitimate interest
Example:
We use your contact and device information to send you system notifications, and reminders, inform you about our policies and terms, and send you billing information, if applicable. We may use push notifications, which you can disable anytime in your device settings or from within the App using the consent toggle screens, if any. We also use your information to respond to you when you contact us, to provide you with user support, and to respond to your comments, questions, and requests related to your use or intention to use our App
Purpose of processing:
To improve, test, and monitor the effectiveness of our App
Legal basis for processing:
Consent, legitimate interest
Example:
We use your Personal Data to understand user behavior and trends better, detect potential outages and technical issues, operate, protect, improve, and optimize our App. We also use some automatically collected data for content performance and features testing (A/B testing).
Purpose of processing:
To send promotional communications
Legal basis for processing:
Consent, legitimate interest
Example:
We use the contact information you provided to us to inform you about services, features, surveys, newsletters, offers, promotions, contests, and events and send updates about our App, provide other news or information about our selected partners and us that may be interesting to you, including by email, push notification or otherwise, as permitted by law. In cases when we cannot refer to the legitimate interest basis according to applicable law, we will send you marketing communications only after you give us explicit consent to do so.
Purpose of processing:
To customize the content you see in the App
Legal basis for processing:
Consent
Example:
We or our service providers may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). Service providers we use may provide personalized content and information to you, including online ads or other forms of marketing. We don`t share your health data for this purpose.
Purpose of processing:
For our promotional and marketing purposes
Legal basis for processing:
Consent
Example:
We use information (including Personal Data) processed automatically to build our marketing strategy and advertise our App. The information we use and share for this purpose generally does not include personally identifiable information.
Purpose of processing:
For internal business purposes
Legal basis for processing:
Consent, legitimate interest
Example:
We use the information you submitted to us, information collected automatically, and information we obtained from third parties for data analysis, audits, conducting research, analysis, studies or surveys, and identifying usage trends solely for internal business purposes. If the results of such activities contain your Personal Data, we will anonymize or aggregate it prior to disclosing them.
Purpose of processing:
To keep basic data to identify you and prevent further unwanted processing
Legal basis for processing:
Legitimate interest
Example:
If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfill your request
Purpose of processing:
To comply with legal obligations and legal processes and respond to requests from public and government authorities, including public and government authorities outside your country of residence
Legal basis for processing:
Legal obligation
Example:
We may share your Personal Data to comply with our legal obligations when we are lawfully requested to do so
Purpose of processing:
To enforce the Terms of Use, protect our operations, protect our rights, privacy, the safety of property, and/or that of you or others, and allow us to pursue available remedies or limit the damages that we may sustain
Legal basis for processing:
Legitimate interest
Example:
We may process your Personal Data according to our legitimate interest when we need to protect our rights and fulfill our obligations before other people and entities
If we need to process your information for a specific purpose not clearly outlined in this Policy, we will ask you for consent while amending the list of purposes above.
Where required by law, we will only send you marketing communications if you consent to us doing so when you provide us with your Personal Data or if we obtain your consent to receive marketing information separately. You may opt out of receiving such emails by following the instructions in each promotional email we send you or by updating your user settings (where applicable). In addition, if you wish not to receive future communications or wish to have your name deleted from our mailing lists, please contact us at privacy@heartify.io. We will continue to contact you via email regarding the provision of our services and to respond to your requests only.
- Consent. For example, after installing the App on the welcome screen, we ask you to give us permission to process your Personal Data.
- To fulfill our contractual obligations to provide the Services to you.
- Legitimate interest. We may process your Personal Data in relation to our interests in providing the Services to you, our legitimate commercial interests, our interest in protecting the security and integrity of the Services, and wider societal benefits;
- Legal obligations. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.
Purpose of processing:
To make our service available
Legal basis for processing:
Contract
Example:
We use functional information and information that is processed automatically to provide you with all requested services
Purpose of processing:
To communicate with you and send you system and transactional messages
Legal basis for processing:
Contract, legitimate interest
Example:
We use your contact and device information to send you system notifications, and reminders, inform you about our policies and terms, and send you billing information, if applicable. We may use push notifications, which you can disable anytime in your device settings or from within the App using the consent toggle screens, if any. We also use your information to respond to you when you contact us, to provide you with user support, and to respond to your comments, questions, and requests related to your use or intention to use our App
Purpose of processing:
To improve, test, and monitor the effectiveness of our App
Legal basis for processing:
Consent, legitimate interest
Example:
We use your Personal Data to understand user behavior and trends better, detect potential outages and technical issues, operate, protect, improve, and optimize our App. We also use some automatically collected data for content performance and features testing (A/B testing).
Purpose of processing:
To send promotional communications
Legal basis for processing:
Consent, legitimate interest
Example:
We use the contact information you provided to us to inform you about services, features, surveys, newsletters, offers, promotions, contests, and events and send updates about our App, provide other news or information about our selected partners and us that may be interesting to you, including by email, push notification or otherwise, as permitted by law. In cases when we cannot refer to the legitimate interest basis according to applicable law, we will send you marketing communications only after you give us explicit consent to do so.
Purpose of processing:
To customize the content you see in the App
Legal basis for processing:
Consent
Example:
We or our service providers may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). Service providers we use may provide personalized content and information to you, including online ads or other forms of marketing. We don`t share your health data for this purpose.
Purpose of processing:
For our promotional and marketing purposes
Legal basis for processing:
Consent
Example:
We use information (including Personal Data) processed automatically to build our marketing strategy and advertise our App. The information we use and share for this purpose generally does not include personally identifiable information.
Purpose of processing:
For internal business purposes
Legal basis for processing:
Consent, legitimate interest
Example:
We use the information you submitted to us, information collected automatically, and information we obtained from third parties for data analysis, audits, conducting research, analysis, studies or surveys, and identifying usage trends solely for internal business purposes. If the results of such activities contain your Personal Data, we will anonymize or aggregate it prior to disclosing them.
Purpose of processing:
To keep basic data to identify you and prevent further unwanted processing
Legal basis for processing:
Legitimate interest
Example:
If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfill your request
Purpose of processing:
To comply with legal obligations and legal processes and respond to requests from public and government authorities, including public and government authorities outside your country of residence
Legal basis for processing:
Legal obligation
Example:
We may share your Personal Data to comply with our legal obligations when we are lawfully requested to do so
Purpose of processing:
To enforce the Terms of Use, protect our operations, protect our rights, privacy, the safety of property, and/or that of you or others, and allow us to pursue available remedies or limit the damages that we may sustain
Legal basis for processing:
Legitimate interest
Example:
We may process your Personal Data according to our legitimate interest when we need to protect our rights and fulfill our obligations before other people and entities
If we need to process your information for a specific purpose not clearly outlined in this Policy, we will ask you for consent while amending the list of purposes above.
Where required by law, we will only send you marketing communications if you consent to us doing so when you provide us with your Personal Data or if we obtain your consent to receive marketing information separately. You may opt out of receiving such emails by following the instructions in each promotional email we send you or by updating your user settings (where applicable). In addition, if you wish not to receive future communications or wish to have your name deleted from our mailing lists, please contact us at privacy@heartify.io. We will continue to contact you via email regarding the provision of our services and to respond to your requests only.
General principles and prohibitions. We will share your information with third parties only in the ways described in this Privacy Policy. Without your permission, we do not share Personal Data with third parties for their marketing purposes (including direct marketing). We do not share identifiable health data with third parties for marketing and other purposes not related to providing you access to our Services. We will not rent or sell your Personal Data to any third parties.
Personnel. We share your Personal Data only with our employees and contractors, agents, and auditors who need to know or otherwise access Personal Data under this Privacy Policy and who are bound in writing by confidentiality and other obligations sufficient to protect Personal Data under this Privacy Policy.
Protection measures. While integrating external services, we choose third parties that can assure they apply all necessary technical and organizational measures to protect users` personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party due to technical accidents that may arise out of our reasonable control. Provided that we followed all demands of applicable personal data protection legislation, we are not responsible for any accidental loss or unauthorized access to your Personal Data through the fault of third parties.
5.1. Disclosures made by you
When you use our App, the result of measurements and other functions will be displayed back to you. Certain features of our App allow you to make some of your measurements public, in which case it will become readily accessible to anyone. We urge you to consider the sensitivity of any data you share at your discretion.
5.2. Service providers and subcontractors
We occasionally engage outside businesses to process your Personal Data on our behalf. They are the “processors” of your Personal Data. Processors assist us in managing the App, facilitate our communication with you, and carry out other related tasks. To complete these objectives, they may process specific Personal Data on our behalf, acting under our instructions and subject to demands of applicable data protection laws. To the degree applicable legislation requires, we will execute data processing agreements with our processors and maintain responsibility for their actions.
We may engage the following third-party service providers to provide us with the necessary infrastructure for the delivery and improvement of our services:
Processor`s name and location:
Firebase (Google LLC); EU, USA
Services:
Hosting, storage, and technical management services
Privacy statement and Data Processing Addendum:
Privacy Policy | Cloud Data Processing Addendum | Firebase Data Processing and Security Terms
Personal data collected/shared:
All Personal Data
Purpose of sharing:
Storage of all Personal Data when you use the App, cloud computing to perform the App`s functionality
Processor`s name and location:
App Store Connect (Apple Inc.), USA
Services:
Technical, payment processing, and analytics services
Privacy statement and Data Processing Addendum:
App Store & Privacy | App Analytics & Privacy
Personal data collected/shared:
Payment and banking information, personal identifiers
Purpose of sharing:
To collect and process payments for subscription to the App. Note that we do not access your banking information or payment requisites when you purchase subscriptions in the App.
Processor`s name and location:
OneSignal, Inc., USA, EU
Services:
Push notifications and analytics service
Privacy statement and Data Processing Addendum:
Privacy Policy | Data Processing Addendum - to be provided on data subject`s demand, if applicable
Personal data collected/shared:
Device identifiers, external user IDs, and in-app events
Purpose of sharing:
To enable reminders and push notification as part of our App`s functionality and Services
Processor`s name and location:
Amplitude, Inc., USA
Services:
Analytical tools
Privacy statement and Data Processing Addendum:
Privacy Notice | Data Processing Addendum
Personal data collected/shared:
App usage data
Purpose of sharing:
To understand how you use the App and the Services, engage with particular features and what you like or dislike the most to engineer product experiences
Processing for marketing and marketing analytics purposes
With your consent, we may share some of your non-health Personal Data with our marketing and promotional service providers. We do this to market our App and Services, to help new users find out about us, and to develop our business by increasing awareness about the Services.
These are processors we engage for the above purpose:
Processor`s name and location:
AppsFlyer (AppsFlyer, Inc), USA
Services:
Marketing services
Privacy statement and Data Processing Addendum:
Services Privacy Policy | Data Processing Addendum
Personal data collected/shared:
— Technical identifiers: IP address (which may also provide general location information), User agent, IDFA (Identifier for advertisers), Customer-issued user ID and other similar unique technical identifiers;
— Your subscription status;
— The fact of application launch.
Purpose of sharing:
To analyze and obtain reports of how to optimize our marketing campaigns; for analytical purposes. In order to discover you or users who are similar to you on other platforms, including social networking websites, AppsFlyer may provide your Personal Data to some of its integrated partners (such as Pinterest, Google Ads, Apple Search Ads, FB marketing network, and others). These partners review your Personal Data to display pertinent information about [Stress App`s name] to those who might be interested in it or prompt you to use the App again if you haven't in a while.
You can withdraw your consent or opt-out from the sharing of your Personal Data with AppsFlyer for marketing and promotional purposes anytime by adjusting your device settings.
Processor`s name and location:
Facebook (Meta), USA
Services:
Analytics / ad management services
Privacy statement and Data Processing Addendum:
Privacy Policy | Data Processing Addendum
Personal data collected/shared:
Technical identifiers and raw data, namely, event status, event revenue and currency, event source, campaign ID, site ID, region, country, city, IP address, AppsFlyer ID, Customer User ID, Advertising ID, IDFA, IDFV; data about your device, namely, device category, platform, OS version, App version, and ID.
Purpose of sharing:
To promote our Services and obtain marketing analytics data
Processor`s name and location:
Mintegral North America Inc., USA
Services:
Marketing services
Privacy statement and Data Processing Addendum:
Privacy Policy and Data Protection Addendum
Personal data collected/shared:
Technical identifiers and raw data, namely, event status, event revenue and currency, event source, campaign ID, site ID, region, country, state, city and postal code, IP address, AppsFlyer ID (if applicable), Advertising ID, IDFA, IDFV; data about your device, namely, device category, platform, OS version, App version, and ID.
Purpose of sharing:
To promote our App and place ads on the Internet
Processor`s name and location:
TikTok Pte. Ltd, Singapore
Services:
Analytics / ad management services
Privacy statement and Data Processing Addendum:
Privacy Policy | Data Processing Addendum
Personal data collected/shared:
Personal information accessed or collected in connection with an event on TikTok inventory and properties, including a user’s non-intentional interaction with our ads, including hovering over, muting, pausing, or closing our ads; and any derivations or combinations of such personal information
Purpose of sharing:
To promote our App and place ads on Tik Tok platform
Processor`s name and location:
Unity Technologies S.F., 30 3rd Street, San Francisco, CA 94103
Services:
Analytics / ad management services
Privacy statement and Data Processing Addendum:
Privacy Policy | Data Processing Addendum
Personal data collected/shared:
— End Users data including voice (if applicable), advertising identifiers or device IDs (e.g. IDFA GAID), User IDs, IP address, gameplay, in-app purchase, and device data, including device identifiers,
— Information related to the ad content or attribution data sent by Heartify or Heartify`s agent
Purpose of sharing:
To promote our App and place ads on Tik Tok platform
Processor`s name and location:
Apple Search Ads platform (Apple Inc.), USA
Services:
Analytics / ad management services
Privacy statement and Data Processing Addendum:
Privacy Policy | General Apple Privacy Policy
Personal data collected/shared:
To ensure delivering the most relevant ads, Apple Search Ads may use the following:
— Account Information. This includes the information a customer includes in their Apple ID account (is not shared with Heartify).
— App Store Data. This includes information provided by developers to define and categorize their apps. It also includes insights derived from non-personal historical search terms, App Store downloads, App Store browsing activity, and in-app purchases made through the App Store.
— App Transaction Data. This includes historical information about users’ transactions on the App Store, including apps they’ve downloaded and in-app purchases they’ve made.
— Contextual Information. This includes a user`s device type, iOS version, time of day, device location, search query, and information about the page they’re viewing, or app they're downloading.
Purpose of sharing:
To promote our App and place ads on Apple Search Ads platform
Processor`s name and location:
ironSource Mobile Ltd.
Services:
Analytics / ad management services
Privacy statement and Data Processing Addendum:
Privacy Policy | Data Protection Addendum
Personal data collected/shared:
Device ID, IP address, Online unique identifiers, User ID, if provided by us
Purpose of sharing:
To promote our App and place ads on ironSource platform
These lists may be amended or modified from time to time according to our business needs, on our sole discretion and without giving notice to you, but provided that such extension in sharing of your Personal Data do not require your consent as legal basis for processing. If so, we will ask you for consent while informing you of modifications for further processing.
How to opt-out from tracking in the App
If you don't want third-party service providers to personalize ads on the basis of your interests, please follow the instructions below:
1. Open the Settings app on your phone
2. Go to Privacy & Security
3. Tap Tracking
4. Tap Allow Apps to Request to Track to turn it off.
You can also disable Tracking for Stress Monitor in the Settings app on your phone.
Remember that when you opt out of certain interest-based advertising, you may still receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.
Our App does not track your precise location data.
5.3. Third-party websites and social media widgets
Our App may contain links to third-party websites/services, or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them. Our Services may also include social media features, such as Facebook and Instagram buttons. These features may collect your IP address and which page you visit on our site and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy statements of the company providing them.
5.4. Business transfers, legal requirements, and protection of our rights
We may disclose your personal information if it is needed for objective reasons, due to the public interest, or in other unforeseen circumstances:
5.5. Aggregated or anonymized data
We may share aggregated or anonymized information that does not directly identify you with other third parties, not mentioned above, such as our partners and research entities, for statistical, analytic, and scientific purposes. Anonymization and further use of anonymized information are done under our legitimate interest and aimed at contributing scientific value in our activities to increase awareness about health and general well-being across society worldwide.
Personnel. We share your Personal Data only with our employees and contractors, agents, and auditors who need to know or otherwise access Personal Data under this Privacy Policy and who are bound in writing by confidentiality and other obligations sufficient to protect Personal Data under this Privacy Policy.
Protection measures. While integrating external services, we choose third parties that can assure they apply all necessary technical and organizational measures to protect users` personal data. However, we cannot guarantee the security of any information transmitted from us to any such third party due to technical accidents that may arise out of our reasonable control. Provided that we followed all demands of applicable personal data protection legislation, we are not responsible for any accidental loss or unauthorized access to your Personal Data through the fault of third parties.
5.1. Disclosures made by you
When you use our App, the result of measurements and other functions will be displayed back to you. Certain features of our App allow you to make some of your measurements public, in which case it will become readily accessible to anyone. We urge you to consider the sensitivity of any data you share at your discretion.
5.2. Service providers and subcontractors
We occasionally engage outside businesses to process your Personal Data on our behalf. They are the “processors” of your Personal Data. Processors assist us in managing the App, facilitate our communication with you, and carry out other related tasks. To complete these objectives, they may process specific Personal Data on our behalf, acting under our instructions and subject to demands of applicable data protection laws. To the degree applicable legislation requires, we will execute data processing agreements with our processors and maintain responsibility for their actions.
We may engage the following third-party service providers to provide us with the necessary infrastructure for the delivery and improvement of our services:
Processor`s name and location:
Firebase (Google LLC); EU, USA
Services:
Hosting, storage, and technical management services
Privacy statement and Data Processing Addendum:
Privacy Policy | Cloud Data Processing Addendum | Firebase Data Processing and Security Terms
Personal data collected/shared:
All Personal Data
Purpose of sharing:
Storage of all Personal Data when you use the App, cloud computing to perform the App`s functionality
Processor`s name and location:
App Store Connect (Apple Inc.), USA
Services:
Technical, payment processing, and analytics services
Privacy statement and Data Processing Addendum:
App Store & Privacy | App Analytics & Privacy
Personal data collected/shared:
Payment and banking information, personal identifiers
Purpose of sharing:
To collect and process payments for subscription to the App. Note that we do not access your banking information or payment requisites when you purchase subscriptions in the App.
Processor`s name and location:
OneSignal, Inc., USA, EU
Services:
Push notifications and analytics service
Privacy statement and Data Processing Addendum:
Privacy Policy | Data Processing Addendum - to be provided on data subject`s demand, if applicable
Personal data collected/shared:
Device identifiers, external user IDs, and in-app events
Purpose of sharing:
To enable reminders and push notification as part of our App`s functionality and Services
Processor`s name and location:
Amplitude, Inc., USA
Services:
Analytical tools
Privacy statement and Data Processing Addendum:
Privacy Notice | Data Processing Addendum
Personal data collected/shared:
App usage data
Purpose of sharing:
To understand how you use the App and the Services, engage with particular features and what you like or dislike the most to engineer product experiences
Processing for marketing and marketing analytics purposes
With your consent, we may share some of your non-health Personal Data with our marketing and promotional service providers. We do this to market our App and Services, to help new users find out about us, and to develop our business by increasing awareness about the Services.
These are processors we engage for the above purpose:
Processor`s name and location:
AppsFlyer (AppsFlyer, Inc), USA
Services:
Marketing services
Privacy statement and Data Processing Addendum:
Services Privacy Policy | Data Processing Addendum
Personal data collected/shared:
— Technical identifiers: IP address (which may also provide general location information), User agent, IDFA (Identifier for advertisers), Customer-issued user ID and other similar unique technical identifiers;
— Your subscription status;
— The fact of application launch.
Purpose of sharing:
To analyze and obtain reports of how to optimize our marketing campaigns; for analytical purposes. In order to discover you or users who are similar to you on other platforms, including social networking websites, AppsFlyer may provide your Personal Data to some of its integrated partners (such as Pinterest, Google Ads, Apple Search Ads, FB marketing network, and others). These partners review your Personal Data to display pertinent information about [Stress App`s name] to those who might be interested in it or prompt you to use the App again if you haven't in a while.
You can withdraw your consent or opt-out from the sharing of your Personal Data with AppsFlyer for marketing and promotional purposes anytime by adjusting your device settings.
Processor`s name and location:
Facebook (Meta), USA
Services:
Analytics / ad management services
Privacy statement and Data Processing Addendum:
Privacy Policy | Data Processing Addendum
Personal data collected/shared:
Technical identifiers and raw data, namely, event status, event revenue and currency, event source, campaign ID, site ID, region, country, city, IP address, AppsFlyer ID, Customer User ID, Advertising ID, IDFA, IDFV; data about your device, namely, device category, platform, OS version, App version, and ID.
Purpose of sharing:
To promote our Services and obtain marketing analytics data
Processor`s name and location:
Mintegral North America Inc., USA
Services:
Marketing services
Privacy statement and Data Processing Addendum:
Privacy Policy and Data Protection Addendum
Personal data collected/shared:
Technical identifiers and raw data, namely, event status, event revenue and currency, event source, campaign ID, site ID, region, country, state, city and postal code, IP address, AppsFlyer ID (if applicable), Advertising ID, IDFA, IDFV; data about your device, namely, device category, platform, OS version, App version, and ID.
Purpose of sharing:
To promote our App and place ads on the Internet
Processor`s name and location:
TikTok Pte. Ltd, Singapore
Services:
Analytics / ad management services
Privacy statement and Data Processing Addendum:
Privacy Policy | Data Processing Addendum
Personal data collected/shared:
Personal information accessed or collected in connection with an event on TikTok inventory and properties, including a user’s non-intentional interaction with our ads, including hovering over, muting, pausing, or closing our ads; and any derivations or combinations of such personal information
Purpose of sharing:
To promote our App and place ads on Tik Tok platform
Processor`s name and location:
Unity Technologies S.F., 30 3rd Street, San Francisco, CA 94103
Services:
Analytics / ad management services
Privacy statement and Data Processing Addendum:
Privacy Policy | Data Processing Addendum
Personal data collected/shared:
— End Users data including voice (if applicable), advertising identifiers or device IDs (e.g. IDFA GAID), User IDs, IP address, gameplay, in-app purchase, and device data, including device identifiers,
— Information related to the ad content or attribution data sent by Heartify or Heartify`s agent
Purpose of sharing:
To promote our App and place ads on Tik Tok platform
Processor`s name and location:
Apple Search Ads platform (Apple Inc.), USA
Services:
Analytics / ad management services
Privacy statement and Data Processing Addendum:
Privacy Policy | General Apple Privacy Policy
Personal data collected/shared:
To ensure delivering the most relevant ads, Apple Search Ads may use the following:
— Account Information. This includes the information a customer includes in their Apple ID account (is not shared with Heartify).
— App Store Data. This includes information provided by developers to define and categorize their apps. It also includes insights derived from non-personal historical search terms, App Store downloads, App Store browsing activity, and in-app purchases made through the App Store.
— App Transaction Data. This includes historical information about users’ transactions on the App Store, including apps they’ve downloaded and in-app purchases they’ve made.
— Contextual Information. This includes a user`s device type, iOS version, time of day, device location, search query, and information about the page they’re viewing, or app they're downloading.
Purpose of sharing:
To promote our App and place ads on Apple Search Ads platform
Processor`s name and location:
ironSource Mobile Ltd.
Services:
Analytics / ad management services
Privacy statement and Data Processing Addendum:
Privacy Policy | Data Protection Addendum
Personal data collected/shared:
Device ID, IP address, Online unique identifiers, User ID, if provided by us
Purpose of sharing:
To promote our App and place ads on ironSource platform
These lists may be amended or modified from time to time according to our business needs, on our sole discretion and without giving notice to you, but provided that such extension in sharing of your Personal Data do not require your consent as legal basis for processing. If so, we will ask you for consent while informing you of modifications for further processing.
How to opt-out from tracking in the App
If you don't want third-party service providers to personalize ads on the basis of your interests, please follow the instructions below:
1. Open the Settings app on your phone
2. Go to Privacy & Security
3. Tap Tracking
4. Tap Allow Apps to Request to Track to turn it off.
You can also disable Tracking for Stress Monitor in the Settings app on your phone.
Remember that when you opt out of certain interest-based advertising, you may still receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.
Our App does not track your precise location data.
5.3. Third-party websites and social media widgets
Our App may contain links to third-party websites/services, or you may access the App from a third-party site. We are not responsible for the privacy practices of these third-party sites or services linked to or from our App, including the information or content contained within them. Our Services may also include social media features, such as Facebook and Instagram buttons. These features may collect your IP address and which page you visit on our site and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy statements of the company providing them.
5.4. Business transfers, legal requirements, and protection of our rights
We may disclose your personal information if it is needed for objective reasons, due to the public interest, or in other unforeseen circumstances:
- to the extent permitted and as restricted by law, in response to subpoenas, court orders, or legal processes, including to meet national security or law enforcement requirements;
- when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or enforce our agreements, policies, and terms of service;
- if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.
5.5. Aggregated or anonymized data
We may share aggregated or anonymized information that does not directly identify you with other third parties, not mentioned above, such as our partners and research entities, for statistical, analytic, and scientific purposes. Anonymization and further use of anonymized information are done under our legitimate interest and aimed at contributing scientific value in our activities to increase awareness about health and general well-being across society worldwide.
We are committed to giving you extensive privacy rights in relation to your Personal Data, regardless of the nation or region you are from. This includes all individuals in the EEA, the UK and/or Switzerland.
Please refer to Section 4 of this Policy to discover legal bases and specific purposes for processing of your Personal Data.
Please refer to Section 4 of this Policy to discover legal bases and specific purposes for processing of your Personal Data.
We work in the cross-border area and provide our App and Services to our users around the world.
We and third-party organizations that provide data processing technologies for the Services or our third-party advertising partners may transfer the processed information across borders and from your country or jurisdiction to other countries or jurisdictions worldwide.
If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction. This means that your personal information can be transferred to a third country, a territory, or one or more specified sectors within that third country or to an international organization where data protection and confidentiality regulations may not provide the same level of personal data protection as your country does.
We try to ensure that the recipient of any personal data provides proper protection of the personal data received, in accordance with the current legislation on protecting such information. By agreeing with this Policy, you agree that we may transfer your personal data to any third country, a territory, or one or more specified sectors within that third country or to the international organization.
For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check. If applicable, we are party to data transfer agreements/data processing addendums or equivalent legal instruments with each of our service providers, and we will (i) keep each document up to date with current law and (ii) only engage in personally identifiable information transfers from safeguards area to outside safeguards area in accordance with such an agreement or an alternative means of transfer in compliance with data protection legislation. Where we transfer your Personal Data as described above, we will take steps to ensure that your Personal Data receive adequate security protection where it is processed, and your rights continue to be protected pursuant to the applicable data protection law, including through the use of Standard Contractual Clauses approved by the European Commission.
We and third-party organizations that provide data processing technologies for the Services or our third-party advertising partners may transfer the processed information across borders and from your country or jurisdiction to other countries or jurisdictions worldwide.
If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction. This means that your personal information can be transferred to a third country, a territory, or one or more specified sectors within that third country or to an international organization where data protection and confidentiality regulations may not provide the same level of personal data protection as your country does.
We try to ensure that the recipient of any personal data provides proper protection of the personal data received, in accordance with the current legislation on protecting such information. By agreeing with this Policy, you agree that we may transfer your personal data to any third country, a territory, or one or more specified sectors within that third country or to the international organization.
For the purposes of data storage, we recourse to the services of the hosting organizations. We take your privacy seriously and, therefore, encrypt your personal data - if possible - before sending it to the hosting organizations for the purposes of its storage. Please note that we cooperate only with those hosting organizations that have passed our security and reliability check. If applicable, we are party to data transfer agreements/data processing addendums or equivalent legal instruments with each of our service providers, and we will (i) keep each document up to date with current law and (ii) only engage in personally identifiable information transfers from safeguards area to outside safeguards area in accordance with such an agreement or an alternative means of transfer in compliance with data protection legislation. Where we transfer your Personal Data as described above, we will take steps to ensure that your Personal Data receive adequate security protection where it is processed, and your rights continue to be protected pursuant to the applicable data protection law, including through the use of Standard Contractual Clauses approved by the European Commission.
We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your Personal Data that we physically access and store, you can request that we erase your personal information and close your account. Unless you demand us otherwise, we will retain your Personal Data for a period of 3 years in case you decide to re-activate the Services or re-install the App.
Even if you requested the erasure or deleted your account or the App, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if the information is necessary to comply with legal obligations (taxation, accounting, audit), or in order to maintain safety and data backup settings, prevent fraud or other malicious acts, or keep your choices about privacy, for example, if you unsubscribed from our marketing communications.
Even if you requested the erasure or deleted your account or the App, some data may still be stored for a certain time period (but no longer than the storage purpose requires) if the information is necessary to comply with legal obligations (taxation, accounting, audit), or in order to maintain safety and data backup settings, prevent fraud or other malicious acts, or keep your choices about privacy, for example, if you unsubscribed from our marketing communications.
The security of your personal information is highly important to us. Services we use to maintain the App follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
We take reasonable and appropriate measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.
We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your Personal Data to be encrypted with proper and strong encryption algorithms, including hashing where possible.
Please notice that by avoiding unauthorized access to your mobile device, you can help keep your information secure. Unfortunately, no method of transmission over the Internet or method of electronic storage is 100% secure. We do our best to protect your personal data, but we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law. We will also take specific steps to address the breach as necessary in the given situation.
If you suspect or become aware of any security incident within the Services, please let us know at stress@heartify.io.
We take reasonable and appropriate measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.
We implement appropriate technical and organizational measures, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the processing. We seek your Personal Data to be encrypted with proper and strong encryption algorithms, including hashing where possible.
Please notice that by avoiding unauthorized access to your mobile device, you can help keep your information secure. Unfortunately, no method of transmission over the Internet or method of electronic storage is 100% secure. We do our best to protect your personal data, but we cannot guarantee its absolute security. In the event that your personal information is compromised as a breach of security, we will promptly notify you in compliance with applicable law. We will also take specific steps to address the breach as necessary in the given situation.
If you suspect or become aware of any security incident within the Services, please let us know at stress@heartify.io.
General limitation. The Services are not intended for children and we do not knowingly collect or solicit any personal information from children under 13. If we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at stress@heartify.io .
Limitations for users from the European Economic Area and the United Kingdom. The use of the Services by residents of EEA or the UK younger than 16 years old is prohibited. If you know that a person under 16 is using the Services, please contact us at stress@heartify.io and we will take measures to delete such information and/or delete the child’s account.
Limitations for users from the European Economic Area and the United Kingdom. The use of the Services by residents of EEA or the UK younger than 16 years old is prohibited. If you know that a person under 16 is using the Services, please contact us at stress@heartify.io and we will take measures to delete such information and/or delete the child’s account.
This Privacy Policy is updated regularly.
Whenever we change this Privacy Policy, we will post those changes to this Privacy Policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.
Whenever we change this Privacy Policy, we will post those changes to this Privacy Policy and other places that we consider appropriate. Additional forms of notice of modifications or updates as appropriate under the circumstances may be provided to you.
If you have any questions about this Privacy Policy, please feel free to contact us via email at privacy@heartify.io.