Privacy Policy

When you use EFELYA, you are trusting us with intimate personal information. We are committed to keeping that trust, which is why our policy as a company is to take every step to ensure that individual user's data and privacy rights are protected and to provide transparency about our data practices. 

The primary purpose of our Privacy Policy is to provide a clear understanding of what data we collect, how it is used and shared, and how you can control it.

Introduction

This Privacy Policy explains how EFELYA (“Company” or “we” or “us”) collects, stores, uses, transfers and shares  Personal Data from our users (“you”) in connection with:

(all collectively, the “App”).

We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you by email (sent to the email address specified when you register), through the App, or by presenting you with a new version of this Privacy Policy. Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to accept changes to the Privacy Policy explicitly. Please review our Website and the App for the latest updates on our data privacy practices. If you do not accept the terms of the Privacy Policy, we ask that you do not use the App. Please exit the App immediately if you do not agree to the terms of this Privacy Policy.

Personal Data and information we collect from you

Personal Data you provide us directly

General Information. When you sign up to use the App, we may collect Personal Data about you such as:

Health and Well-being. When you use the App, you may choose to provide personal information about your health and well-being such as:

You also may give us the ability to import into the App Personal Data about your health and activities from third-party services such as Apple HealthKit and Google Fit. Such imported Personal Data may include sports activities, weight, calories burnt, heartbeat rate, number of steps/distance traveled, and other data about your health. In order for us to process any Personal Data under this category we will explicitly ask your consent on the registration screen.

Personal Data we may collect automatically

When you access or use the App, we may automatically collect the following information:

Device Information:

Location Information:

App usage data, including, among others:

To collect this information, we may also send cookies to your mobile device or computer or engage other tracking technologies. Cookies are small data files stored on your hard drive or in device memory. See more in our Cookie Policy.

Data from external sources. We may use third-party tools like AppsFlyer that provide us some of your attribution data that we further utilize to customize and personalize your App experience. We may also use such data for statistical purposes and analytics.

How we use your Personal Data

Purposes of processing

We may use your Personal Data for the following purposes:

Example: We may use your Personal Data to predict your cycles or ovulation

Example: Based on your Personal Data we may provide you certain suggested articles to read

Example: We may send you a reminder to log your medical data or symptoms to make predictions more accurate

Example: We may send you a discount offer for EFELYA Premium or offer to pass a course. You can opt-out anytime by contacting us at info@efelya.com

Example: We may ask for age verification if we have reasonable doubts regarding your age

Example: We may send you an email notification that contains a customer satisfaction survey

Example: We may send you an email containing your invoice, if applicable

Example: We may process the data to reply to your support request

Example: We may analyze your activities in the App to understand what you like or dislike about it in order to improve your future experience

Example: If you give your consent, we can post your review or comment on our website

Example: We may aggregate your Personal Data for analysis and AI training to provide you more accurate predictions

Example: We may aggregate your Personal Data into a dataset and analyze it, for example with leading research institutions, in order to contribute to the development of science

Example: We will contact you directly, if we need your Personal Data for anything else

Principles of processing

Data minimization and purpose limitation. We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Data that is not needed for the mentioned purposes. For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amounts and types of Personal Data that is strictly needed for the mentioned purposes.

No sale of Personal Data. We will never sell, rent, or disclose your Personal Data. We may share only some of your Personal Data to our service providers strictly limited to cases and purposes stipulated in this Privacy Policy. We will also not use the information gained through your use of the HealthKit and Google Fit framework for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers.

Your privacy rights

It does not matter what country or region you come from. We are committed to providing you vast privacy rights for your Personal Data.


Correction of Personal Data

If you believe that your Personal Data is inaccurate, you have a right to contact us and ask us to correct such Personal Data. 

 

Restriction of Processing

You also have a right to request that the processing of your Personal Data be restricted, if you contest the accuracy of the Personal Data and we need some time to verify its accuracy.

 

Information rights and access to your Personal Data (including in portable form)

The App gives you the ability to access Personal Data within the App. You have a right to request information about what Personal Data we have about you, to access all your Personal Data and receive a copy of it, including in a structured and portable form (.json). We also commit to notify you, as required under applicable laws, about Personal Data breaches related to your Personal Data.

 

Erasure of your Personal Data

You may ask us to erase your  Personal Data, if you withdraw your consent to processing, if you believe such processing is not compliant with applicable law and in some other cases. Please be aware that erasing some Personal Data may affect your App experience. 

 

Right to object to the processing of your Personal Data

In some cases you can object to the processing of your Personal Data, for example, if we process it under legitimate interest basis.

How to exercise your privacy rights

Сontact us at info@efelya.com to exercise any of your privacy rights. 

We will exercise them within 30 days after receipt. It may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems. We will let you know if we need more time and explain the reasons for the delay. 

What else?

Please keep in mind that if we receive a vague request, we may engage the individual to better understand the motivation and content of the request. We may also refuse manifestly unfounded and excessive (repetitive) requests. 

We might also require you to prove your identity in some cases. Normally, we make sure to verify that the request is coming from the same email as you indicated when registering in the App. In case of doubt we may ask you to undergo some additional verification. This is made to ensure that no rights of third parties are violated by your request.

Subject to applicable laws, you may have a right to lodge a complaint with your local data protection authority about any of our activities (related to your privacy rights, among others) that you think are not compliant with applicable law. However, if you think that we do something incorrectly, let us know first at info@efelya.com. We care about your privacy and want to make sure that we did everything to address any of your concerns.

Aggregated information

We may share aggregated, anonymized or de-identified information, which cannot reasonably be used to identify you, with our partners or research institutions. For example, we may share, including, without limitation, in articles, blog posts and scientific publications, general age demographic information and aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users. Sharing such data contributes to the advancement of scientific research on women’s health.

Special circumstances

We may also share some of your Personal Data in the following special circumstances: 

Retention of your Personal Data

When you use the App

We will retain your Personal Data as long as your account is active or needed to provide you Services, and only for as long as it serves purposes of processing identified in Section 2 of this Privacy Policy. At any time, you can erase your Personal Data in accordance with the Privacy Policy.

After you stop using the App

If you choose to delete the App or deactivate your account, or your account becomes inactive for a while, we will retain your Personal Data for a reasonable period in case you decide to re-activate the Services. The App covers different periods of users’ lifecycle; therefore retention of your data is needed in some cases to secure your smooth experience with other App functions.

You should be aware that we may retain certain Personal Data and other information after your account has been terminated or deleted in an aggregated, anonymized form. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Data as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

Personal Data you elect to share with third parties

You can direct us to share data from the App with other parties. For example, you can permit us to share data with other health apps and services like Google Fit and Apple HealthKit. Once you direct us to share your data with a third party, that third party will have their own privacy policy and we do not control how the third party uses or handles the information. You can revoke your consent to share information with such a third party at any time in your App account settings.

We take reasonable steps in order to ensure compliance of such third parties with any applicable laws that might govern the processing of your Personal Data.

Security of your Personal Data

General security measures

We take all reasonable and appropriate measures to protect all Personal Data collected from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health). Among others, we utilize the following information security measures to protect your Personal Data:

Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your mobile device. Please understand that no security system is perfect and, as such, we cannot guarantee the absolute security of the App, or that your information will not be intercepted while being transmitted to us.

Security breaches

If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential Personal Data breach, together with other actions referred to in Section 3 of the Privacy Policy (such as notifying you in certain cases), we will also undertake particular actions to remedy the breach, including, but not limited to, logging you out from all the devices, resetting a password (sending a temporary password for you to apply) and performing other reasonably necessary activities and actions.

If you want to report a security incident related to the App please contact us at info@efelya.com.

Children’s privacy

General age limitation. We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 13 years old. The App does not collect Personal Data from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the App, please contact us at info@efelya.com and we will take the required steps to delete such information and (or) delete her account. 

Age limitation for the European Union residents. Due to legal requirements you shall be at least 16 years old to use the App. We do not allow the use of the App by the European Union residents younger than 16 years old. If you are aware of anyone younger than 16 using the App, please contact us at info@efelya.com and we will take steps to delete such information and (or) delete her account.

Communication with you

We may contact you from time to time via email or through other means (like popups or push notifications) to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you. 

Opt-out options. You can always opt out of receiving emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting-out of these emails or notifications will not end the transmission of important service-related emails that are necessary to your use of the App. If applicable laws prescribe so,  we may ask some users to provide their consent for such communications.

Please note that we may contact you with our information about products, services, offers, promotions, rewards, and events offered by us and others via third-party platforms (like social media). See more in section Processing to find new Efelya users and stay in touch with you. Please note that you can always opt-out from such communication and usage of your Personal Data by contacting us at info@efelya.com.

Storage and international Personal Data transfers

General

The Company is based in France, and Personal Data we collect is governed by French and European Union jurisdisation. Please be advised that French law and laws of other countries may not offer the same protections as the law of your jurisdiction.

Data Protection Officer (DPO)

To communicate with our Data Protection Officer, please email at dpo@efelya.com or use the contact details below.