PRIVACY Policy - AIO.guide

Last updated 25-03-2020

We, RMD Boost APP IVS (hereinafter “We” or “Us”), are committed to protecting privacy of users of the AIO website, AIO application(s), and/or other related services (hereinafter collectively the “AIO Services” or the “Services”). Our aim is to make you feel secure when We collect and further process your personal data as We recognize and respect the importance of your privacy

This Privacy Policy describes how we protect your personal data and how we ensure to process your personal data accordingly to the General Data Protection Regulation.

1. WHO ARE WE?

RMD Boost APP IVS is the data controller for the personal data being processed in AIO Services and thereby responsible for the processing of your personal information. You are always welcome to contact us on the information below:

RMD Boost APP IVS
c/o Drive
Artillerivej 86, 4.
2300 København S
Company registration no. (CVR) 39 73 42 14
Telephone number +45 60353028
info@AIO.guide

2. WHY DO WE PROCESS YOUR PERSONAL INFORMATION AND WHAT IS OUR LEGAL BASIS?

We process personal data about you for the following purposes:

  • a.) Purpose of the AIO Services: to provide you with insights and good advice via dialogue, challenges, and content about how to live a more balanced life.
  • b.) Improvement of AIO Services: investigations, statistics, and analyses in order to improve products, services, and technologies.
  • c.) Profiling: to provide you with personalized content through our AIO services.
  • d.) Marketing: to send you marketing content and offers tailored to your preferences and interests.

The legal basis for our processing of your personal data is:

  • a. Purpose of the AIO services: Processing of your personal information for the purposes described is necessary for the performance of the contract with you or in order to take steps at your request prior to entering into a contract. The legal basis is the Data Protection Regulation Art. 6, paragraph 1 (b).

    We only process special categories of personal data, such as information concerning your physical status if you have provided your explicit consent. The legal basis is the Data Protection Regulation Art. 9, paragraph 2, litra a).
  • b. Improvement of AIO services: Processing of your personal information is necessary for our legitimate interest to continuously improve services and technologies as well as the experience when you interact with us. The legal basis is the Data Protection Regulation Art. 6, paragraph 1 (f).
  • c. Profiling: Processing of your personal data for providing you with personalized content relies on your consent. The legal basis is the Data Protection Regulation Art. 6, paragraph 1 (a) and Art. 9, paragraph 2, litra a).
  • d. Marketing: Processing of personal data for the purpose of sending you marketing relies on your consent. The legal basis is the Data Protection Regulation Art. 6, paragraph 1 (a).

Where We rely on your consent to process your personal data you always have a right to withdraw this consent. You can withdraw your consent by contacting us via the contact information in section 1.

3. WHAT PERSONAL INFORMATION DO WE PROCESS ABOUT YOU?

We only process personal data about you for the specific purposes mentioned above under Section 2, and We only process personal data that is necessary. We process the following categories of personal data about you:

  • a.) Ordinary personal data such as:
    • Basic contact details, such as
      • Name
      • Address
      • iii. contact information as telephone number and email address interactions with the app, such as completed surveys, completed sessions etc.
  • b.) Special categories of personal data:
    • Physical status, such as stress level, pain areas, mental state, etc.

4. WHERE IS YOUR DATA COLLECTED?

Personal data is collected directly from you, when you create an account in the AIO Services and from your use of the AIO Services.

5. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

Third parties who process personal data on our behalf are prohibited from using your personal data for purposes other than those requested by us or required by law. These companies are considered ‘data processors’. If we cooperate with data processors, we enter into data processor agreement regarding the service providers processing of your personal data.

We share your regular personal information with the following data processors:

  • a. Suppliers, that We work with, such as service providers, hosting providers, technical support, IT consultants, and supply services.
  • b. Distributors of e-marketing, such as HubSpot, Mail chimp, etc. in order to supply you with marketing material if you have given you consent to this

Third parties who process personal data on their own behalf are considered ‘data controllers’. We will share your personal data with the following data controllers:

  • a. Public authorities or other parties, to whom it is required by applicable law to disclose personal data. We will e.g share personal data with public authorities, such as the Danish Data Protection Agency (Datatilsynet) if it is required by applicable law.
  • b. Others, personal information may also be disclosed in connection with a corporate restructuring, sale, or assignment of assets, merger, divestiture, or other changes of the financial status of Us.

Some third parties will not only collect and process personal data on our behalf, but for their own purposes as well. For the collection and sharing of personal data in this regard, We are shared data controllers with our third parties. However, we do not control any further processing being done, for this part our third parties are independent data controllers. We share personal data about your use of the AIO application(s) with the following third parties as shared data controllers:

  • a. Third party services, such as Google (Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043, U.S.A. – hereinafter “Google”). We use Google Analytics for Firebase for our AIO application(s). This tool allows us to use the same Google Analytics functions for an application that can also be used for websites. Firebase uses technologies that work similar to cookies, in particular advertising IDs. This way, we collect information about how you use the AIO application(s). We use such data for statistical analysis purposes, to test our offers, and to improve our offers. In addition, we use such information for personalized advertising. We only collect and share these data with Google if we have your freely given consent to do so and you can withdraw your consent at any time without any consequences in any regard.

We will not share any personal data with investors in the AIO services.

6. UNDER WHAT CIRCUMSTANCES WILL WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE THE EU/EEA?

In some cases, We will be transferring personal information to countries outside the EU/EEA, e.g. when using IT service providers in such countries.

Such transfers will only happen for the specific purposes mentioned above under Section 5, and We will always ensure that appropriate safeguards are in place for such transfer as set out below:

  • a. The country/countries has/have been deemed by the Commission of the European Union to have an adequate level of protection of personal data.
  • b. The country/countries has/have not been deemed by the Commission of the European Union to have an adequate level of protection of personal data. We will in such cases provide appropriate safeguards for the transfer through the use of "Model Contracts for the Transfer of Personal Data to Third Countries", as published by the Commission of the European Union, or any other contractual agreement, such as Privacy Shield, approved by the competent authorities. You may obtain a copy of the contract/agreement by contacting Us at info@aio.guide

7. FOR HOW LONG WILL WE RETAIN YOUR PERSONAL INFORMATION?

We will retain your personal information only for as long as it is necessary for the purposes for which the data was collected or later processed.

As a general rule, We will delete all personal data when your user account has been inactive for 12 months.

We may retain your personal information for a longer period if we are legally required to do so or if retention is necessary for the establishment, exercise or defense of legal claims.

Information processed for marketing purposes will be deleted in accordance with the above or upon your withdrawal of the marketing consent you initially gave us, whichever comes first.

8. WHAT IF THE PROVISION OF YOUR PERSONAL INFORMATION IS MANDATORY?

In some cases, the provision of at least some of your personal information is a requirement necessary to enter into a contract.

Therefore, if you refuse to share such personal data, we may not be able to provide the services you request.

9. PROFILING

Profiling is a form of automated processing of your personal data to evaluate certain personal aspects relating to you to analyze or predict aspects concerning your personal preferences, behavior or health.

When you interact with the AIO Services We receive information about you, e.g. if you perform a Workout session, we will receive information about which and how many sessions you have completed and in connection with the information you provide in the other areas of health, such as Sleep, Drink, Breathe, Mind and Eat We use the received information to get to know you better in order to provide you with insights and good advice via dialogue, challenges and content about how to live a more balanced life.

We use profiling to be able to offer you specific services that meet your preferences and for marketing purposes.

10. WHAT ARE OUR SECURITY MEASURES?

We have implement security measures to protect your personal data against manipulation, loss, destruction, and against unauthorized access. We continuously revise our security procedure based on the newest, technological developments. As an example all sensitive data are encrypted and only via an identification key (UserID) can personal data and sensitive data be connected.

11. WHAT ARE YOUR RIGHTS?

Below you can read about your rights when We process your personal data. Under data protection law, you have rights including:

  • Your right of access - You have the right to ask us for copies of your personal information.
  • Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
  • Your right to withdraw your consent - Where processing of your personal data is based on your consent, you have the rights to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent
  • Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.
  • Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.
  • Your right to data portability - You have the right to ask that we transfer the personal data you gave us to another organization, or to you, in a structured, commonly used and machine-readable format, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at through the contact information in section 1 if you wish to make a request.

12. CHANGE TO THIS PRIVACY POLICY

We may need to make changes to this Privacy Policy, e.g. if cases were We add new functions or services to the AIO Services. We will however notify you of any changes and ask that you read the Privacy Policy to ensure you are aware of the changes.

13. CONTACT INFORMATION FOR THE DANISH DATA PROTECTION AUTHORITY

You may always lodge a complaint with the data protection supervisory authority. Please find there contact information below:

Datatilsynet,
Borgergade 28, 5.,
DK-1300 Copenhagen K.
Email: dt@datatilsynet.dk.
Phone: +45 33 19 32 00