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 Efelya mobile application,
- efelya.com website ("Website"),
(all collectively, the “App”).
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:
- Full name;
- Email address;
- Date of birth;
- Password or passcode;
- Place of residence and associated location information;
Health and Well-being. When you use the App, you may choose to provide personal information about your health and well-being such as:
- Body temperature;
- Menstrual cycle dates;
- Various symptoms related to your menstrual cycle and health;
- Other information about your health (including sexual activities), well-being, and related activities, including personal life (collectively, “Personal Data”).
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:
- Hardware model;
- Information about the operating system and its version;
- Unique device identifiers (e.g. IDFA);
- Mobile network information;
- Device storage information.
- IP address;
- Time zone;
- Information about your mobile service provider.
App usage data, including, among others:
- Frequency of use;
- Areas and features of our App you visit;
- Your use patterns generally;
- Engagement with particular features.
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:
- to analyze, operate, maintain and improve the App, to add new features and services to the App, to support the existing functions of the App
Example: We may use your Personal Data to predict your cycles or ovulation
- to customize content and materials you see when you use the App
Example: Based on your Personal Data we may provide you certain suggested articles to read
- to provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders
Example: We may send you a reminder to log your medical data or symptoms to make predictions more accurate
- to customize product and service offerings and recommendations to you, including third-party products and offerings
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 firstname.lastname@example.org
- to verify your identity when it is required by law
Example: We may ask for age verification if we have reasonable doubts regarding your age
- to send you technical notices, updates, security alerts and support and administrative messages
Example: We may send you an email notification that contains a customer satisfaction survey
- for billing (invoicing), account management and other administrative purposes, if applicable
Example: We may send you an email containing your invoice, if applicable
- to respond to your comments, questions and requests and to provide customer service
Example: We may process the data to reply to your support request
- to monitor and analyze trends, usage and activities in connection with our App
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
- solely with respect to information that you mark for sharing, for Company promotional purposes (except data from Apple HealthKit and Google Fit)
Example: If you give your consent, we can post your review or comment on our website
- to link or combine with information we get from others or (and) from you to help understand your needs and provide you with better service, to use in training AI
Example: We may aggregate your Personal Data for analysis and AI training to provide you more accurate predictions
- for scientific and academic research purposes
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.
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 email@example.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.
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 firstname.lastname@example.org. We care about your privacy and want to make sure that we did everything to address any of your concerns.
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.
We may also share some of your Personal Data in the following special circumstances:
- in response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law (including to meet national security or law enforcement requirements);
- when disclosure is required to maintain the security and integrity of the App, or to protect any user’s security or the security of other persons, consistent with applicable laws. In such cases we may also delete some of your Personal Data (e.g. resetting your password to avoid unauthorized access);
- when disclosure is directed or consented to by the user who has input the Personal Data;
- in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.
Retention of your Personal Data
When you use the App
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
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:
- Pseudonymization and tokenization of certain categories of your Personal Data;
- Encryption of your Personal Data in transit and in rest;
- Systematic vulnerability scanning and penetration testing;
- Protection of data integrity;
- Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the App. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.
- Conducting periodical data protection impact assessments in order to ensure that the App fully adheres to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake a privacy audit in the event of the Company’s merger or takeover.
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.
If you want to report a security incident related to the App please contact us at email@example.com.
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 firstname.lastname@example.org 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 email@example.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 firstname.lastname@example.org.
Storage and international Personal Data transfers
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 email@example.com or use the contact details below.