Kaia | Privacy Statement for our Apps (EU and non-US countries)

This Privacy Policy explains nature, scope, and purpose of the processing of personal data (hereinafter: "Data") in connection with the operation of our app. As for the terminology used, e.g. "processing" or "controller," we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Controller

kaia health software GmbH,

Infanteriestraße 11a,

80797 Munich
E-Mail: info@kaia-health.com

Managing Directors: Konstantin Mehl and Manuel Thurner

Impressum

Contact Data Protection Officer:

Jonas Duss

jonas@kaia-health.com

If you have questions about our privacy policy, processing in general, or the processing of your data, please contact us as above.

Definitions

Terms such as "personal data," "processing,"
"pseudonymisation," "profiling," "controller," "processor" as well as any other terms according to Art. 4 GDPR have the same meaning as defined in the GDPR.

Legal basis for processing:

When processing your personal data in the context of the purposes set out in this Policy, we may, depending on the circumstances, rely on one or more of the following legal bases:

· We have previously obtained your explicit consent to processing (this legal basis will be used only in relation to processing that is entirely voluntary - it will not be used for processing that is in any way necessary or compulsory);

· The processing is necessary in connection with a contract you conclude with us;

  • The processing is required by law;

· The processing is necessary to protect the vital interests of a person; or

· We have a legitimate interest in carrying out the processing for the purpose of managing, operating, or promoting our business and this legitimate interest will not be invalidated by your interests, fundamental rights, or freedoms.

Types of processed personal data:

- User data (e.g. names, addresses).

- Contact data (e.g. e-mail, phone numbers).

- Content data (e.g. text entries, photos, videos).

- Usage data (e.g. visited websites, interest in content, access times).

- Meta/communication data (e.g. device information, IP addresses, browsing history on website).

- Payment data (payment processing of the subscription).

Special categories of personal data processed:

Health data, processing based on Art 9 (2) (h) GDPR necessary for health or social care or treatment.

Categories of data subjects

Visitors and users of the app (hereinafter, data subjects in general will also be called "Users").

Purpose of processing

- Create an account in the app

- Provision of the app as well as the respective functions and contents

- Answering contact inquiries and communication with users

- Range measurement/marketing

- Security measures

- Processing of the payment for the product

- Answering support requests

- Establishment, execution and termination of purchase or service contracts

- Internal anonymous aggregated studies

Processing of special personal data

We will not attempt to collect or otherwise process your special personal information except when:

· the processing is required or permitted by law (e.g. to fulfill our reporting obligations on diversity);

· the processing is necessary for the detection or prevention of crime (including the prevention of fraud, money laundering, and terrorist financing);

· the processing is necessary to establish, exercise, or defend rights; or

· we have previously, in accordance with applicable law, obtained your explicit consent to processing (as mentioned above, this legal basis is used only in relation to processing that is entirely voluntary - it is not used for processing that is in any way necessary or compulsory).

Special categories of personal data are processed in detail

- to adapt the therapy to the patient

- to remind the patient to carry out the therapy

- to store the progress within the therapy

- Individualization of the therapy

- Improvement of the product

Sources of data collection

All data is collected directly from the end user about the use of the app. When filling out feedback or self-test forms or at the end of an exercise, this information is transmitted to the Kaia server via an encrypted TLS connection and stored in an appropriately secured database.

Further information about the app

With your permission, our app can use GPS tracking to provide you with location-based features, and the app can also access the photos and videos you store on your mobile device to allow you to upload videos and photos for use within the apps. Finally, our app can use push notifications to send you notifications. When you use the app for the first time, you will be asked if you want to activate these functions in your settings menu. If you do not enable or later disable these features, you may not be able to take full advantage of the app.

The information you provide when setting up your account in the app may include your name, user name, email address and gender, country of residence and telephone number. When you register for an account with us, you also have a unique password with which you can access your account.

Alternatively, you can create an account for our app with your Facebook, Twitter or Google+ credentials.

Security measures

We have taken appropriate technical and organizational security measures in accordance with Art. 32 GDPR, taking into account the state of technology, implementation costs as well as nature, scope, circumstances and purposes of the processing and the different likelihood and severity of any risks to the rights and freedoms of natural persons, to protect your personal data against unintentional or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and any other unlawful or unauthorized forms of processing under applicable law.

Such measures include in particular, ensuring confidentiality, integrity and availability of data by controlling physical access to the data, as well as the relevant access, input, disclosure, security of availability and its separation. In addition, we have established procedures that ensure the exercise of the rights of data subjects, deletion of data and reaction to data risks. In addition, we take into account the protection of personal data when developing or selecting the hardware, software and procedures in line with the principle of data protection through technology design and data protection-friendly presettings (Art. 25 GDPR).

Cooperation with processors and third parties

If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit data to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission, if you have given consent, if this is required by law or based on our legitimate interests (e.g. when involving third parties to host the servers, deliver e-mail contact forms as well as response to enquiries through the form).

If we commission third parties with the processing of data based on a so-called "processing contract," this will be done on the basis of Art. 28 GDPR.

Transmission into third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosure or transmission of data to third parties, this will only be done to fulfill our (pre-)contractual obligations, based on your consent (with corresponding precise information and specifying those third countries), if required by law or based on our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR are fulfiled. This means that the processing is carried out e.g. on the basis of specific guarantees, such as the officially recognized level of data protection corresponding to that of the EU (e.g. for the US through the 'Privacy Shield') or compliance with officially recognized special contractual obligations (so-called 'standard contractual clauses').

Please note that the level of data protection of such third countries is lower than the level of protection of the European Union.

Rights of data subjects

You have the right to request confirmation as to whether relevant data are being processed and to request information about such data as well as further information and a copy of the data pursuant to Art. 15 GDPR.


Pursuant to Art. 16 GDPR you have the right to request completion of the data concerning you or correction of any incorrect data concerning you.


Pursuant to Art. 17 GDPR, you have the right to request that the relevant data will be deleted immediately or, alternatively, pursuant to Art. 18 GDPR, to request a restriction of the processing of data.


You have the right to request provision of the data concerning you that you have provided to us pursuant to Art. 20 GDPR and to request their transfer to other controllers.

You also have the right to file a complaint with the competent supervisory authority pursuant to Art. 77 GDPR.

Contact – Bavarian Data Protection Authority

Bavarian Data Protection Authority (BayLDA)

Promenade 27

91522 Ansbach, Germany

Phone: +49 (0) 981 53 1300

Fax: +49 (0) 981 53 98 1300

Email: poststelle@lda.bayern.de

Homepage: https://www.lda.bayern.de/de/kontakt.html

Right to withdraw

If certain data processing is based on your consent, you have the right to withdraw your consent at any time pursuant to Art. 7 (3) GDPR with effect for the future. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Right to object

You may object to the future processing of your data at any time pursuant to Art. 21 GDPR. Such objection may be made in particular against processing for direct marketing purposes (see also below).

Direct marketing

We use your information to communicate with you and to keep you informed about our activities and events and those of third parties in which you may be interested, and to make suggestions and recommendations to you and other users of our website and app about products or services that may interest you or them (direct marketing). We provide this information to you by email (subject to your prior consent, if required by law), push notifications on our app, targeted ads on our app and third-party platforms, text, social media or telephone.

Cookies and right to object in case of direct marketing

'Cookies' are small files that are stored on the users' computers. Different types of information can be stored by such cookies. A cookie is primarily used to store the information about a user (or the device where the cookie is stored) during or after his/her visit to an online offer. Temporary cookies, or 'session cookies' or 'transient cookies' are cookies that are deleted after a user has left a online offer and closes his/her browser. Such a cookie may store e.g. the contents of a shopping cart in an online store or a login jam. Cookies are 'permanent' or 'persistent' if they remain stored even after the browser has been closed. For example, the login status can be saved if users visit again after several days. Similarly, such a cookie can also store the users' interests, which are used for range measurement or marketing purposes. 'Third-party cookie' refers to cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if only their cookies are used, they are called 'first-party cookies').


We hereby explain in this Privacy Policy that we may use temporary and permanent cookies.


If users do not want cookies stored on their computer, they are asked to disable the relevant option in their browser's system settings. Stored cookies can be deleted in the browser's system settings. However, the exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes is possible for a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU site www.youronlinechoices.com/ . Furthermore, the storage of cookies can be achieved by switching them off in the browser's settings. Please note that in this case it may not be possible to use all features of this online offer.

Deletion of data

The data processed by us will be deleted pursuant to Art. 17 and 18 GDPR or their processing will be restricted. Unless explicitly stated in this Privacy Policy, the data stored by us will be deleted once they are no longer required for their intended purpose and unless the deletion conflicts with any legal storage requirements. If the data are not deleted because they are required for other and legitimate purposes, their processing will be restricted. This means that the data will be blocked and not processed for any other purposes. This applies for example to data that must be kept for commercial or tax reasons.


Hosting

We use hosting services for the purpose of providing the following services: infrastructure and platform services, computing capacity, storage and database services, security services and technical maintenance services, which we use to operate this app.


We or our hosting provider process user data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this app, based on our legitimate interests in the efficient and secure provision of this app pursuant to Art. 6 (1) (f) GDPR in conjunction with Art. 28 GDPR (conclusion of processing agreement and ensuring that our hosting provider – DigitalOcean LLC with seat in the USA, is EU-US Privacy Shield-certified).

In particular, databases and static resources are hosted on servers of the following providers for the following purposes:

Amazon Web Services, Inc.

P.O. Box 81226, Seattle, WA 98108-1226, United States of America

DPA is available

EU-US-Privacy-Shield: https://www.privacyshield.gov/participant?id=a2zt000000000TOWQAA4

Disclosure of first name, number of active days, payment status and e-mail address for sending e-mails to:

ActiveCampaign LLC

150 North Michigan Avenue Suite 1230, Chicago, IL 60601, United States of America

DPA is available

EU-US-Privacy-Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnH6AAK

Passing on of payment data to:

Apple, Inc.

1 Infinite Loop, Cupertino, CA 95014, United States of America

DPA is not yet available, Apple is working on its deployment: https://www.apple.com/legal/privacy/en-ww/governance/

APEC-Privacy-Shield fulfilled: https://www.apple.com/legal/privacy/de-ww/

Passing on Push Token, Device ID and IP for sending Push Notifications to:

Apple Inc.

1 Infinite Loop, Cupertino, CA 95014, United States of America

DPA is not yet available, Apple is working on its deployment: https://www.apple.com/legal/privacy/en-ww/governance/

APEC-Privacy-Shield fulfilled: https://www.apple.com/legal/privacy/de-ww/

Google LLC

1600 Amphitheatre Parkway Mountain View, CA 94043, United States of America

DPA is available

EU-US-Privacy-Shield: https://www.privacyshield.gov/participant?id=a2zt00000000001L5AAI

OneSignal

2194 Esperanca Avenue, Santa Clara, CA 95054, United States of America

DPA is available

Measures have been taken not to transfer or store personal information to OneSignal: https://onesignal.com/blog/product-policy-updates-for-gdpr/

Passing on Device ID or IP for analysis and improvement of the product or marketing to:

Google LLC

1600 Amphitheatre Parkway Mountain View, CA 94043, United States of America

DPA is available

EU-US-Privacy-Shield: https://www.privacyshield.gov/participant?id=a2zt00000000001L5AAI

AppSee

54 W. 40th St. New York, NY 10018

DPA is available

EU-US Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TSUAAA4

Branch Metrics, Inc.

1400 Seaport Blvd, Building B, 2nd Floor, Redwood City, CA 94063, United States of America

Collection of access data and log files

Based on our legitimate interests within the meaning of Art. 6 (1) (f) GDPR, we or our hosting provider collect data on every access to the server where this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification about successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address, and the requesting provider.


Data that need to be retained further for evidence purposes are exempted from deletion until final clarification of the respective incident.

Contact

When contacting us (for example, by contact form, e-mail, telephone, or via social media), the user's information will be processed to process the contact request pursuant to Art. 6 (1) (b) GDPR. The user's information may be stored in a customer relationship management system ('CRM System') or a comparable request organization.

We delete inquiries once they are no longer required. We check the necessity every two years; in addition, the legal archiving obligations apply.

Integration of services and contents of third parties

Based on our legitimate interests (i.e. interest in analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) (f) GDPR), we use content or services offered by third-parties in our online offer in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as 'content').

This always requires that the third-party providers of such content can detect the users' IP address as they could not send the content to their browser without the IP address. The IP address is therefore required for the display of this content. We endeavor to use only those contents whose providers use the IP address solely for the delivery of the contents. Third party providers may also use so-called pixel tags (invisible graphics, also referred to as 'web beacons') for statistical or marketing purposes. 'Pixel tags' may be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymized information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, time of visit and other information regarding the use of our online offer, or be linked to such information from other sources.

Data collection by payment service providers based on our legitimate interests (i.e. interest in secure, efficient and practicable payment processing)

PayPal

kaia uses the service of the payment service provider PayPal, which is operated by PayPal, PayPal (Europe) S.à r.l. & Cie, S.C.A., 5th floor, 22-24 Boulevard Royal, L-2449, Luxembourg (hereinafter collectively "PayPal") to process payments or credits on the kaia websites. When using PayPal for payment on the kaia websites, personal data (in particular data concerning your PayPal account) is transmitted to PayPal. In addition, PayPal may collect personal information (such as credit card numbers) when you register with the PayPal app. PayPal is solely responsible for the processing of these data. Use of the PayPal service is fully subject to PayPal's Privacy Policy and Terms of Use. For details on PayPal's handling of your data and your rights and setting options to protect your personal data, please visit: https://www.paypal.com/de/cgi-bin/webscr?cmd=p/gen/ua/policy_privacy-outside.

Please note that your contractual relationship with PayPal is independent of your contractual relationship with kaia.

braintree

kaia uses the service of the payment service provider braintree. braintree is a company of PayPal, Inc. which processes credit card payments. Your personal data will only be passed on to "Braintree" for the purpose of processing the online order. The data protection regulations are identical to those of Paypal. Details on data protection at Braintree can be found here:

https://www.paypal.com/us/webapps/mpp/ua/privacy-full

Other third party service providers and the purpose of the transmission of personal data

- Apple Inc. for Payment Processing (IAP) and Push Notification Delivery (APNS).

- Google Inc. for Push Notification Delivery (GCM), Range Analysis (Crashlytics, Answers) and Authorization.

- Onesignal for push notification delivery.

- Mailjet, ActiveCampaign and Mailbox.org for the delivery of transactional e-mails and newsletters.

- Adjust for range analysis and tracking of marketing channels.

- AppSee for range analysis and product improvement.

- Hetzner for the provision of server resources.

- Amazon to provide server resources.

Kaia | Privacy Statement for our Website (EU and non-US countries)

This Privacy Policy explains nature, scope, and purpose of the processing of personal data (hereinafter: "Data") in connection with the operation of our website. As for the terminology used, e.g. "processing" or "controller," we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Controller

kaia health software GmbH,

Infanteriestraße 11a,

80797 Munich
E-Mail: info@kaia-health.com

Managing Directors: Konstantin Mehl and Manuel Thurner

Impressum

Contact Data Protection Officer:

Jonas Duss

jonas@kaia-health.com

If you have questions about our privacy policy, processing in general, or the processing of your data, please contact us as above.

Definitions

Terms such as "personal data," "processing,"
"pseudonymization," "profiling," "controller," "processor" as well as any other terms according to
Art. 4 GDPR have the same meaning as defined in the GDPR.

Legal basis for processing

When processing your personal data in the context of the purposes set out in this Policy, we may, depending on the circumstances, rely on one or more of the following legal bases:

· We have previously obtained your explicit consent to processing (this legal basis will be used only in relation to processing that is entirely voluntary - it will not be used for processing that is in any way necessary or compulsory);

· The processing is necessary in connection with a contract you conclude with us;

  • The processing is required by law;

· The processing is necessary to protect the vital interests of a person; or

· We have a legitimate interest in carrying out the processing for the purpose of managing, operating, or promoting our business and this legitimate interest will not be invalidated by your interests, fundamental rights, or freedoms.

Types of processed data

- User data (e.g. names, addresses).

- Contact data (e.g. e-mail, phone numbers).

- Content data (e.g. text entries, photos, videos).

- Usage data (e.g. visited websites, interest in content, access times).

- Meta/communication data (e.g. device information, IP addresses, browsing history on website).

Categories of data subjects

Visitors and users of the website (hereinafter, data subjects in general will also be called "Users").

Purpose of processing

- Provision of the website as well as the respective functions and contents

- Responding to contact requests and communicating with Users

- Security measures

- Reach measurement/marketing

Processing of special personal data

We will not attempt to collect or otherwise process your sensitive personal information except when:

· the processing is required or permitted by law (e.g. to fulfill our reporting obligations on diversity);

· the processing is necessary for the detection or prevention of crime (including the prevention of fraud, money laundering, and terrorist financing);

· the processing is necessary to establish, exercise, or defend rights; or

· we have previously, in accordance with applicable law, obtained your explicit consent to processing (as mentioned above, this legal basis is used only in relation to processing that is entirely voluntary - it is not used for processing that is in any way necessary or compulsory).

Sources of data collection

We collect data directly from the user of the website, based either on the information actively sent to kaia or through the website visit as such or through voluntary self-declarations in an online form.

Security measures

We have taken appropriate technical and organizational security measures in accordance with Art. 32 GDPR, taking into account the state of technology, implementation costs as well as nature, scope, circumstances and purposes of the processing and the different likelihood and severity of any risks to the rights and freedoms of natural persons, to protect your personal data against unintentional or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and any other unlawful or unauthorized forms of processing under applicable law.

Such measures include in particular, ensuring confidentiality, integrity and availability of data by controlling physical access to the data, as well as the relevant access, input, disclosure, security of availability and its separation. In addition, we have established procedures that ensure the exercise of the rights of data subjects, deletion of data and reaction to data risks. In addition, we take into account the protection of personal data when developing or selecting the hardware, software and procedures in line with the principle of data protection through technology design and data protection-friendly presetting’s (Art. 25 GDPR).

Cooperation with processors and third parties

If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit data to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission, if you have given consent, if this is required by law or based on our legitimate interests (e.g. when involving third parties to host the servers, deliver e-mail contact forms as well as response to enquiries through the form).

If we commission third parties with the processing of data based on a so-called "processing contract," this will be done on the basis of Art. 28 GDPR.

Transmission into third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosure or transmission of data to third parties, this will only be done to fulfill our (pre-)contractual obligations, based on your consent (with corresponding precise information and specifying those third countries), if required by law or based on our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR are fulfilled. This means that the processing is carried out e.g. on the basis of specific guarantees, such as the officially recognized level of data protection corresponding to that of the EU (e.g. for the US through the 'Privacy Shield') or compliance with officially recognized special contractual obligations (so-called 'standard contractual clauses').

Please note that the level of data protection of such third countries is lower than the level of protection of the European Union.

Rights of data subjects

You have the right to request confirmation as to whether relevant data are being processed and to request information about such data as well as further information and a copy of the data pursuant to Art. 15 GDPR.


Pursuant to Art. 16 GDPR you have the right to request completion of the data concerning you or correction of any incorrect data concerning you.


Pursuant to Art. 17 GDPR, you have the right to request that the relevant data will be deleted immediately or, alternatively, pursuant to Art. 18 GDPR, to request a restriction of the processing of data.


You have the right to request provision of the data concerning you that you have provided to us pursuant to Art. 20 GDPR and to request their transfer to other controllers.

You also have the right to file a complaint with the competent supervisory authority pursuant to Art. 77 GDPR.

Contact – Bavarian Data Protection Authority

Bavarian Data Protection Authority (BayLDA)

Promenade 27

91522 Ansbach, Germany

Phone: +49 (0) 981 53 1300

Fax: +49 (0) 981 53 98 1300

Email: poststelle@lda.bayern.de

Homepage: https://www.lda.bayern.de/de/kontakt.html

Right to withdraw

If certain data processing is based on your consent, you have the right to withdraw your consent at any time pursuant to Art. 7 (3) GDPR with effect for the future. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Right to object

You may object to the future processing of your data at any time pursuant to Art. 21 GDPR. Such objection may be made in particular against processing for direct marketing purposes (see also below).

Direct marketing

We use your information to communicate with you and to keep you informed about our activities and events and those of third parties in which you may be interested, and to make suggestions and recommendations to you and other users of our website and app about products or services that may interest you or them (direct marketing). We provide this information to you by email (subject to your prior consent, if required by law), push notifications on our app, targeted ads on our app and third-party platforms, text, social media or telephone.

Cookies and right to object in case of direct marketing

'Cookies' are small files that are stored on the users' computers. Different types of information can be stored by such cookies. A cookie is primarily used to store the information about a user (or the device where the cookie is stored) during or after his/her visit to a website. Temporary cookies, or 'session cookies' or 'transient cookies' are cookies that are deleted after a user has left a website and closes his/her browser. Such a cookie may store e.g. the contents of a shopping cart in an online store or a login jam. Cookies are 'permanent' or 'persistent' if they remain stored even after the browser has been closed. For example, the login status can be saved if users visit again after several days. Similarly, such a cookie can also store the users' interests, which are used for range measurement or marketing purposes. 'Third-party cookie' refers to cookies that are offered by providers other than the person responsible for operating the website (otherwise, if only their cookies are used, they are called 'first-party cookies').


We hereby explain in this Privacy Policy that we may use temporary and permanent cookies.


If users do not want cookies stored on their computer, they are asked to disable the relevant option in their browser's system settings. Stored cookies can be deleted in the browser's system settings. However, the exclusion of cookies can lead to functional restrictions of this website.

A general objection to the use of cookies used for online marketing purposes is possible for a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU site www.youronlinechoices.com/ . Furthermore, the storage of cookies can be achieved by switching them off in the browser's settings. Please note that in this case it may not be possible to use all features of this website.

Deletion of data

The data processed by us will be deleted pursuant to Art. 17 and 18 GDPR or their processing will be restricted. Unless explicitly stated in this Privacy Policy, the data stored by us will be deleted once they are no longer required for their intended purpose and unless the deletion conflicts with any legal storage requirements. If the data are not deleted because they are required for other and legitimate purposes, their processing will be restricted. This means that the data will be blocked and not processed for any other purposes. This applies for example to data that must be kept for commercial or tax reasons.


Hosting

We use hosting services for the purpose of providing the following services: infrastructure and platform services, computing capacity, storage and database services, security services and technical maintenance services, which we use to operate this website.


We or our hosting provider process user data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this website, based on our legitimate interests in the efficient and secure provision of this website pursuant to Art. 6 (1) (f) GDPR in conjunction with Art. 28 GDPR (conclusion of processing agreement and ensuring that our hosting provider – DigitalOcean LLC with seat in the USA, is EU-US Privacy Shield-certified).

Collection of access data and log files

Based on our legitimate interests within the meaning of Art. 6 (1) (f) GDPR, we or our hosting provider collect data on every access to the server where this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification about successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address, and the requesting provider.


Data that need to be retained further for evidence purposes are exempted from deletion until final clarification of the respective incident.

Contact

When contacting us (for example, by contact form, e-mail, telephone, or via social media), the user's information will be processed to process the contact request pursuant to Art. 6 (1) (b) GDPR. The user's information may be stored in a customer relationship management system ('CRM System') or a comparable request organization.

We delete inquiries once they are no longer required. We check the necessity every two years; in addition, the legal archiving obligations apply.

Integration of services and contents of third parties

Based on our legitimate interests (i.e. interest in analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) (f) GDPR), we use content or services offered by third-parties in our online offer in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as 'content').

This always requires that the third-party providers of such content can detect the users' IP address as they could not send the content to their browser without the IP address. The IP address is therefore required for the display of this content. We endeavor to use only those contents whose providers use the IP address solely for the delivery of the contents. Third party providers may also use so-called pixel tags (invisible graphics, also referred to as 'web beacons') for statistical or marketing purposes. 'Pixel tags' may be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymized information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, time of visit and other information regarding the use of our online offer, or be linked to such information from other sources.

Outbrain Inc.

Based on our legitimate interests (i.e. interest in analysis, optimization, and economic operation of our website within the meaning of Art. 6 (1) (f) GDPR), we use the service provider Outbrain Inc., 39 West 13th Street, 3rd floor, New York, NY 10011 with seat in the USA for the purpose of pseudonymized marketing tracking. Outbrain shows performance-based ad contents on partner websites to relevant target groups.


The required pseudonymized information about your use of our website will be stored on a server in the USA. The processed data may be used to create usage profiles of users, which will be used only for analysis purposes and not for advertising purposes. For further information, please see the Privacy Policy of Outbrain Inc. at: https://automattic.com/privacy/ and the explanatory note on Jetpack-Cookies: https://jetpack.com/support/cookies/ .

Facebook Custom Audience

In addition, we may also use Facebook Custom Audience and related Facebook tools to offer you advertising on other websites (including social media networks such as Facebook). Facebook Custom Audience is a tool provided by Facebook that connects a kaia customer/visitor with a Facebook user to advertise on the Facebook platform. To do so, we share your information with such third-party providers (e.g. Facebook) and use cookies or similar technologies on our website to analyze the effectiveness of our advertising on other websites. For more information about the use of data by Facebook, please click on the following link: https://www.facebook.com/ads/about . You may withdraw your consent to the use of your data for such purposes at any time by contacting us by e-mail at support@kaia-health.com.

Facebook

We use the "Conversion Tracking-Pixel" of Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA. This allows users' behavior to be tracked after they have been redirected to the provider's website by clicking on a Facebook ad. This process is designed to evaluate the effectiveness of Facebook ads for statistical and market research purposes and may help to optimize future advertising efforts. The data collected is anonymous to us, so it does not give us any indication of the identity of the users. However, Facebook stores and processes the data so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook Data Usage Guidelines (https://www.facebook.com/about/privacy/). You can allow Facebook and its partners to serve ads on and off Facebook. A cookie may also be stored on your computer for these purposes. Consent to the use of the visitor action pixel may only be given by users who are over 16 years of age. If you are younger, please ask your legal guardian for permission. If you do not wish to consent, we ask you to revoke your consent on the pages of Facebook.

Google Analytics

Based on our legitimate interests (i.e. interest in analysis, optimization, and economic operation of our website within the meaning of Art. 6 (1) (f) GDPR), we use Google Analytics, a web analytics service of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA ('Google'). Google uses cookies. The information generated by the cookie about the use of the website by the users will be as a rule transmitted to a Google server in the USA and stored there.


Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ).

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer, and to provide us with further services related to the use of this online offer and the use of the internet. The processed data may be used to create pseudonymized usage profiles of users.


We use Google Analytics only with activated IP anonymization. This means that the user's IP address will be shortened by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.


The IP address transmitted by the user's browser will not be merged with other Google data. Users can prevent the storage of cookies by selecting the relevant settings in their browser software; users may also prevent Google from collecting of the data generated by the cookie and related to their use of the online offer and processing of such data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de .


For more information about the use of data by Google, settings and objection options, please refer to Google's Privacy Policy ( https://policies.google.com/technologies/ads ) as well as to the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated ).


LinkedIn

Features and contents of the LinkedIn service offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, may be incorporated into our online offer. This may include e.g. content such as images, videos, or text and buttons that users use to express their appreciation of the content, subscribe to the creator of this content or subscribe to our posts. If the users are members of the LinkedIn platform, LinkedIn may assign the retrieval to the aforementioned contents and functions to the profiles of the users. LinkedIn is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active ).

Privacy Policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy.

Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out .