1. About
this Policy
This Privacy Policy (hereinafter “Policy”) is meant to inform you about the processing of your personal data (hereinafter “Personal Data”) by ReMark International B.V. (hereinafter “ReMark”, also referred to as “us”, or “we”, or “our”). When you use Biological Age Model BAM application (hereinafter “App”), you explicitly agree to be bound by and accept the terms of this Policy.
We respect your privacy. Therefore, we
process, handle and protect your Personal Data with the utmost care. While
processing Personal Data, we comply with the requirements imposed by laws and
regulations. Read this Policy carefully so that you know what your rights and
obligations are.
ReMark (Netherland Trade Registration Number: 34122876) is a private limited company established and existing under the laws of The Netherlands with its registered office at World Trade Center, 26th floor, Zuidplein 214, 1077 XV Amsterdam. Questions about this Policy can be submitted via security@remarkgroup.com.
ReMark may process the following Personal
Data:
·
E-mail address
·
Date of Birth
·
Gender
·
Reward points
·
User ID and
password (User ID and
password provided by you via the App are not stored on the App and/or the servers, but are used to request a token to be issued by the
Licensee for authentication purposes.
·
Insurance policy information: policy status
·
App data (including but not limited to avatar,
steps, height, weight) provided or uploaded by you either manually or generated
by the App or through a third party wearable platforms
such as Garmin Connect or Apple HealthKit.
Additionally, ReMark may also process certain data, such as your URL, your IP address and language preferences, and the data and time when you use the App.
ReMark may collect Personal Data, because you provide your Personal Data to ReMark or because Personal Data is collected as you use the App.
ReMark may therefore process your Personal Data for the following purposes:
|
Purpose of processing |
Legal basis for the purpose of processing |
|
·
To provide the products and/or
services to you |
·
Performance of a
contract ·
Legitimate interest |
|
·
To execute marketing and related activities |
·
Consent ·
Legitimate interest |
|
·
To send you (electronic) commercial messages (newsletters) with information about the products and/or services |
·
Consent ·
Legitimate interest |
|
·
To analyze, maintain, secure and optimize the App
and associated technologies |
·
Legitimate interest |
|
· To comply with
relevant laws and regulations |
·
Compliance with legal obligations ·
Legitimate interest |
Legitimate interests of ReMark are, inter alia, improving and providing the products and services, and informing you about the use of (new) products and services, marketing and sales activities.
If and in so far as ReMark relies on the legitimate interest legal basis, ReMark has undertaken a balancing test between the legitimate interests pursued by ReMark as a controller and your interests and fundamental rights and freedom, which require protection of Personal Data, to justify our reliance on this legal basis.
6.
Third parties
ReMark respects the privacy of all its App users and ensures that the confidential nature of the Personal Data you provide us will be maintained. ReMark may transfer your Personal Data to the following third parties:
•
ReMark’s parent company and affiliates (including
but not limited to SCOR SE) and third-party service providers, contractors and
agents, for the purposes of providing the products and/or services to you.
•
The Licensee shall process
Personal Data, such as User ID, data of birth, gender, reward points,
insurance
policy information and data generated by the App or through a third
party wearable platforms.
•
Google Ireland Limited (cloud provider and
processor) shall process Personal Data, such as date of birth, policy
information, gender, number of steps, active calorie count, resting heart rate,
sleep hours (if available), weight and height.
Google Ireland Limited
ReMark will not make your Personal Data available to other third parties, unless it is required to do so by virtue of mandatory rules, a binding decision from a government agency or an order to do so by a competent court.
The App may contain hyperlinks to third-party websites. ReMark is not responsible for the content of any third-party website.
In accordance with the applicable laws and regulations, ReMark has taken adequate technical and organizational measures to safeguard the security of your Personal Data. ReMark stores Personal Data on a secure database that is protected by technical access controls and periodically reviews the information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to our systems. Your Personal Data shall not be stored/transferred in/to so-called non adequate countries outside the European Economic Area (“EEA”), without appropriate safeguards.
Our App is not intended to be used by children under 20 years old. You represent and warrant that you are at least 20 years of age. If you are under age 20, you may not use the App.
You are entitled to exercise certain rights, such as:
•
The right of access, which means you can make a
request to obtain access to the Personal Data concerning you;
•
The right to rectification or correction of your
Personal Data if it is inaccurate or incomplete;
•
The right to erasure of the Personal Data that
relates to you. Please note that there may be circumstances in which we are
required to retain your Personal Data in order to meet our legal and regulatory obligations;
•
The right to restrict the collection, processing, or use;
•
The right to object the collection, processing, or use;
•
The right to data portability, which means that you
have the right to receive your Personal Data in a structured, commonly used and
machine-readable format, and that you have the right to transmit that data to
another controller
•
The right to object to profiling
•
The right to lodge a complaint with a supervisory authority.
If you wish to exercise (one of) these rights, please send an e-mail to security@remarkgroup.com. ReMark will respond within four weeks, or such shorter period as required by applicable laws and regulations, to your request. We may prohibit or otherwise restrict your use or access to the App or prevent or restrict you from accessing certain functions on the App if you choose not to provide your Personal Data or not to agree to our continued collection, processing, or use of your Personal Data as set out in this Policy. If ReMark denies your request, ReMark will explain why and inform you on your rights.
If you are
not satisfied with the way your request has been handled or the way ReMark
processes your Personal Data, you can raise a complaint with your local Data
Protection Authority.
ReMark keeps your Personal Data or other data that you provide to us, whether or not provided via the App, for as long as necessary for the purposes indicated above, or to comply with our legal obligations such as (statutory) retention periods. After expiry of such a retention period, ReMark will destroy all copies containing Personal Data or anonymize such data.
ReMark may change this Policy at any time and without notice. Such modified Policy will take effect from the time it is placed on the App.
This Privacy is written in both Chinese
language and English language. In the event of any discrepancy between the
Chinese version and the English version, the English version shall prevail.
Last updated: September 2019