Privacy Policy

Effective Date: 01/10/2024

1. Introduction
Welcome to Health3 (”we,” “us,” or “our”). Your privacy is important to us. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our mobile application (the “App”). By using the App, you agree to the collection and use of information in accordance with this policy.

2. Data Controller Information

Company Name: Health3 AG
Address: Wiesenstrasse 10A, Schlieren 8952, Switzerland
Email: privacy@health3.app

3. Types of Data Collected
Within the app, we collect the following types of personal data:

Health Biomarker Data: Common biomarkers measured with a blood test, as shared by you by using upload functionality within the App.
Personal Identification Information: Email address, date of birth, gender, as shared by you by specifying profile details within the App.
Usage Data: Usage data about the frequency of use of various functionalities within the App and the IP addresses from which the functionalities are accessed. Furthermore, anonymised data is collected when a crash or an error is encountered within the App, to help us identify and address the root cause.

On our website, we collect the following types of data:

Personal Data: When you interact with our website, we may collect personal information such as your name, email address, phone number, and any other information you provide voluntarily.
Usage Data: We may automatically collect certain information about your visit to our website, such as your IP address, browser type, operating system, referral URLs, and pages you viewed.
Cookies and Tracking Technologies: We use cookies and similar tracking technologies to track the activity on our website and hold certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

4. Purpose of Data Processing
We process your data for the following purposes:

Providing Services: To deliver the App’s functionalities, including tracking and analyzing health metrics, we process the biomarker data you share with us.
Personalization: To customize your experience and provide tailored content. To provide most accurate and relevant information in area of reference ranges, we use your personal identifying information about date of birth and gender in order to show you the reference range relevant to you.
Communication: To send you updates, newsletters, and respond to inquiries.
Compliance: To comply with legal obligations and protect our legal rights.
App Maintenance: To help us address any technical issues with the App and its operations, we process the anonymised usage data.
Website Management:
- To provide, operate, and maintain our website and services.
- To improve, personalize, and expand our website.
- To understand and analyze how you use our website.

5. Consent Management

Obtaining Consent: We obtain your explicit consent before collecting or processing your health data and before collecting any analytical cookies.
Withdrawing Consent: You may withdraw your consent at any time via deletion of your account within the App or by contacting us at privacy@health3.app. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

6. Data Sharing and Disclosure
We may share your personal data with:

Service Providers: Third-party companies that assist us in operating the App (e.g. providers of cloud computing resources) and providing services to you, bound by confidentiality agreements.
Legal Requirements: Government authorities or law enforcement if required by law.

The data is never sold to third-parties or shared for any commercial purpose. The data is not provided to third parties in any other fashion and for any other purpose than is detailed within the scope of this privacy policy.

International Data Transfers:

Your sensitive health data is never transferred outside of the area associated with your account. For Swiss-based accounts, the sensitive data stays always in Switzerland. For accounts created in any of the jurisdictions of European Union (EU), the data is stored and processed in a data center based in one of the countries of the EU.
Some supplementary data, such as analytics cookies used on the web, or anonymised usage data used for application maintenance, might be collected and transferred outside the EU or Switzerland. In such cases, we ensure appropriate safeguards, such as Standard Contractual Clauses, are in place. By accepting analytic cookies or by using of the App, you agree that we may transfer, store and process such supplementary data outside of Switzerland and the European Union.

7. Data Security Measures
We implement the following security measures:

Encryption: Data encryption in transit and at rest using industry-standard protocols.
Access Controls: Restricted access to personal data to authorized personnel only.
Regular Audits: Periodic security assessments and vulnerability scans.

8. Data Retention Policy

Retention Period: We retain your personal data as long as your account is active or as needed to provide services.
Deletion: Upon your request or account deactivation, we will delete or anonymize your personal data unless retention is required by law.

9. User Rights
Under the GDPR and FADP, you have the following rights:

Right of Access: You may obtain confirmation of whether your data is being processed and obtain access to your personal data.
Right to Rectification: You may request modification of any inaccurate or incomplete personal data.
Right to Erasure (“Right to be Forgotten”): You may request deletion of your personal data.
Right to Restrict Processing: You may request limitation of the processing of your personal data.
Right to Data Portability: You may ask to receive your personal data in a structured, commonly used format.
Right to Object: You have the right to object to processing based on legitimate interests.
Right Not to Be Subject to Automated Decision-Making: You have the right not to be subjected to decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.
Right to complain to an authority: You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA) or in Switzerland.

To exercise these rights, either use the functionalities offered through the App (e.g. account and data deletion), or contact us at privacy@health3.app.

10. Cookies and Similar Tracking Technologies
While our App does not use cookies in the traditional web browser sense, we employ similar technologies to collect information and improve your experience. These technologies are essential for the App’s functionality, performance analytics or personalization.

Types of Tracking Technologies Used:

Local Storage: Data stored locally on your device to enhance App functionality, such as user preferences, settings, and offline content.

Purpose of Using Tracking Technologies:

App Functionality: To enable core features of the App, such as remembering your login status and preferences.

11. Children’s Privacy

Age Limitation: The App is not intended for individuals under the age of 18.
Data Deletion: If we become aware that we have collected personal data from a child under 18, we will take steps to delete that information.

12. Automated Decision-Making

No Automated Decisions: We do not engage in automated decision-making that produces legal effects concerning you or similarly significantly affects you.

13. Third-Party Links
Our website may contain links to third-party websites that are not operated by us. We are not responsible for the privacy practices of these sites, and we encourage you to review their privacy policies.

14. Changes to the Privacy Policy
We may update this Privacy Policy periodically. Changes will be communicated via:

In-App Notifications: Notices within the App.
Email Notifications: Sent to the email address associated with your account.
Updated Effective Date: Indicated at the top of this policy.

15. Contact Information
For questions or concerns regarding this Privacy Policy, please contact us:

Email: privacy@health3.app
Address: Health3 AG, Wiesenstrasse 10A, Schlieren 8952, Switzerland

16. Right to Lodge a Complaint
If you believe your data protection rights have been violated, you have the right to file a complaint with:

In the EU: Your local data protection supervisory authority.
In Switzerland: The Federal Data Protection and Information Commissioner (FDPIC).