Privacy Policy

Last updated on 2019/01/28

BewellConnect’s ambition is to be a major player in the connected health sector. We place great importance on transparency, honesty and security, which are essential to building a relationship of trust. This means that protecting your personal data, especially in the health sector, is essential to us. The aim of this document is to inform you about the data protection policy and how we apply it.

Basic principles

The new General Data Protection Regulation 2016/679 came into force on 25 May 2018. In applying it, we only use your personal data with your consent and make every effort to ensure its security. BewellConnect controls the personal data that you communicate to us and is responsible for your personal data in accordance with French law no. 78-17 of 6 January 1978 relating to data protection.

 

This Privacy Policy (” Privacy policy “) of BewellConnect describes how we (BewellConnect, together with its affiliates around the world) collect and use information about each of our visitors and customers, in relation to how they access and use BewellConnect websites (including and each one of its sub-domains, the ” Website “), Mobile applications (” Mobile Apps ” and related services (jointly: the ” Services “).

 

  • “Service(s)”:
    all the services, products accessible online or via customer service or Mobile Apps, etc., whether paid for or not
  • “Mobile App(s)”:
    refers to any downloaded software, app, widget or plug-in on a mobile device (smartphone, tablet, laptop, and any device that has an operating system that allows you to download, install, operate, and update these apps).
  • “We” and “Our
    refers to any company owned or operated, directly or indirectly, by any company in which BewellConnect has an interest and that can collect or process your personal data and cookies, as well as their respective service providers located in France or abroad.
  • “You” and “Your
    refers to any user of our products and/or Services, whether they are paid for or free.

 

The purpose of this Privacy Policy is to provide you with a clear explanation of when, why, and how we collect and use your personal information, as well as an explanation of your rights in relation to this data.

We encourage you to read this Privacy Policy carefully and to fully understand our practices regarding your personal information before accessing or using any of our Services. If you read and fully understand this Privacy Policy but are opposed to our practices, you must immediately leave this website, app or service and avoid or discontinue any use of any of our Services. If you have any questions or concerns about this policy, contact us using the contact form.

Our commitment to protecting privacy

We are committed to respecting the following principles:

 

  • You have no obligation to provide us with the personal data we request from you. However, some of this data may be required to access certain Services and/or be necessary for the operation of Mobile Apps and our connected health objects. For example, if you decide not to provide us with this data, you may not have access to some of these Mobile Services or Apps;

 

  • We only collect and process your data for the purposes described in this Policy or for any specific purposes that we have notified you of and/or to which you have consented;

 

  • We adopt the principle of proportionality and minimisation of personal data collection: in other words, we only collect the personal data necessary for the processing and uses envisaged, and do not collect data superfluously;

 

  • If any personal data that we possess is no longer required for the processing of personal data that we undertake and there is no legal obligation requiring us to keep it, we will do everything in our power to remove, destroy or anonymize it.
Applying the data protection policy

This Privacy Policy applies to all online websites, apps, online games/draws and any other online initiative owned by BewellConnect that collects personal data. This Policy does not therefore apply to third party websites, including those that may be mentioned on any of our Materials available via an internet link.

Data collection: what information do we collect?

We collect two types of information about our visitors:

 

  1. Information that is of a personal nature since it contains information that identifies you, directly or indirectly using reasonable means and that may be private or sensitive (“Personal Information”).

 

When you use BewellConnect’s solutions, certain personal data essential to the operation of our products and the provision of services is collected. This concerns measurements taken using medical equipment or entered by the user:

 

  • Weight,
  • Body mass (fat, muscle),
  • Temperature,
  • Blood pressure,
  • Heart rate,
  • SpO2 (oxygenation rate),
  • Glucose,
  • ECG trace and raw data,
  • Sleep analysis graph.

 

As part of the “Locate” feature, geolocation data will be used.

 

The other personal information we collect mainly relates to contact and financial details, which is collected exclusively via our website accessible from your computer or the BewellConnect app.

 

Furthermore, when you use our Materials, we may collect and process some or all of the following data:

 

  • The data you provide when you complete forms, subscribe to online services (for example, click to chat on our website) or send us correspondence (for example, an online contact form);
  • First and last name;
  • Email address;
  • Gender;
  • Phone number;
  • Address;
  • Contact type: Professional or individual;
  • Age/date of birth;
  • Any special request that you might send us (mainly for archival purposes);
  • We may ask you to answer questionnaires that we will use for scientific and statistical purposes.

 

This personal data gives us information about you and enables us to respond to your requests. Data is also collected when you browse our websites via cookies (a text file deposited on the user’s computer when visiting our site) to improve the user experience that we offer you on our interfaces.

When you fill in a contact form, the collection of your personal data allows us to answer the questions received and to facilitate your identification. When you fill out a newsletter registration form, we collect your personal data so that we can inform you about our news, our business operations and share content and health tips with you.

As part of the click to chat feature, your IP address and country are also collected.

 

  1. Unidentified and unidentifiable information about a visitor or a user who has not identified themselves, that may be available to us or automatically collected by their use of the Services (“Impersonal Information”). This Impersonal Information does not allow us to identify the visitor or user from whom it was collected. The impersonal information that we collect is primarily of a technical nature along with usage data, such as browsing activity and clickstreams on the Services, session statistics, and scrolling, as well as information preventing any identification relating to the device, operating system, browser, screen resolution, language and keyboard settings, ISPs, landing/exit pages, timestamps, etc., used by the Visitor or User.
Purposes: for what purposes do we collect your personal data?

We collect your personal data to provide you with the best online experience and a high-quality service. In particular, we may collect, hold and use your personal data for the following purposes:

 

  1. To deliver the product or service you ordered online via our website
  2. to process and respond to your inquiries and to contact you to respond to your questions and/or requests;
  3. to develop and improve our products, services, communication methods and the functionality of our websites, apps, services;
  4. to provide you with information and to manage your registration and/or subscription to our newsletter service or any other communications service;
  5. to manage our business needs on a daily basis linked to your participation in our competitions, draws, promotional activities and requests;
  6. to authenticate the identity of individuals who contact us by telephone, electronically or otherwise;
  7. to ensure the quality of our services;
  8. to better understand and evaluate the points of interest and desires of consumers and the changes required for them, in order to improve our websites/apps, our Services and/or to develop new products and services;
  9. to provide personalised products and tailored communications, or to recommend products based on your consumer needs.

We may also need your personal data to fulfil legal obligations or as part of the contractual relationship with you.

When we collect and use your personal data for the purposes mentioned above or for any other request, we will inform you before or at the time of collection.

We request your consent to process your personal data. If you have given your consent for the processing of your personal data, you have the right to withdraw that consent at any time.

Sharing your personal data:

When we share your personal data with our affiliates, we make sure that we do so only with organisations that have significant data and data storage security systems in place that respect privacy laws under conditions equivalent to those we comply with.

 

Your personal data will not be shared, sold, rented or disclosed for purposes other than those described in the Policy. We may, however, transmit your data for purposes other than those provided for in the Policy, in cases where their disclosure is required by law and governmental authorities.

Consent

We will not collect, use or disseminate your personal information without your knowledge or consent, as defined in this Policy, unless otherwise provided by law. We may occasionally transfer your personal data to trusted third parties and/or non-BewellConnect partners who may assist us in developing new services or products, inquire about our services or products, provide services that we offer to you. In this case, we ask these companies to protect your data in accordance with this Policy. You may modify or revoke your agreement at any time, within a reasonable time, subject to the legal or contractual restrictions in this regard.

Data retention

Your personal data will only be stored for the time necessary to carry out our activities and services for the purposes of each processing action and under the terms of the Regulations. Your personal data is kept for 3 years following the last contact at the initiative of the person concerned or at the end of the contractual relationship.

 

When you contact BewellConnect, we keep a record of you in a register for as long as we need to provide our services. We may also retain a copy of any exchanges with you for the required duration to protect us during any legal proceedings. As soon as we no longer need to keep your personal data, we will delete it.

Rights of the persons concerned: what are your rights?

When we process your personal data, you are eligible for several rights that you can exercise at any time. Below is an overview of these rights and what they mean for you.

 

The right to access your personal data and the right of rectification

It is important to us that the personal data we hold about you is accurate, up-to-date, complete, relevant and not misleading. In order to ensure that this commitment is respected, you have the right to access, correct or update your personal data at any time.

 

The right to portability of your data

You have the right to receive your personal data in a structured, commonly used and machine-readable format if we have processed your personal data on the following grounds:

 

  1. You have given us your consent to process your personal data for an objective or purpose that we have communicated to you beforehand;
  2. We processed your personal data to facilitate a business transaction, such as providing you with the products and/or services you require;
  3. We processed your personal data using automated means (such as profiling).

 

 

The right to request the deletion of your personal data

You have the right to request the deletion of your personal data when:

  1. Your personal data is no longer required for the purposes for which we collected it;
  2. You withdraw the consent you previously gave us to process your personal data, provided that there is no other legal basis to continue processing your personal data;
  3. You object to us processing your personal data for direct marketing purposes;
  4. You object to us processing your personal data for the legitimate interests of BewellConnect (such as improving the overall user experience on our websites);
  5. personal data is not being processed legally;
  6. your personal data must be erased in order to comply with the legislation in force.

If you wish to delete personal data that we hold about you, please notify us and we will take reasonable steps to respond to your request in accordance with legal requirements.

If the personal data we collect is no longer necessary for any purpose and there is no legal obligation for us to keep it, we will do our utmost to delete, destroy or anonymize that data.

 

The right to limit the processing of your data

You have the right to request the limitation of the processing of your personal data if:

  1. You believe that the personal data we have about you is inaccurate
  2. Regarding any personal data not processed legally, your preference is that we limit its processing rather than delete this data
  3. We no longer need your personal data for the purposes for which we collected it, but you need the data to establish, exercise or defend legal claims
  4. You object to the processing of your personal data and are waiting to see if your considerations relating to this objection take precedence over the legitimate grounds pursued by BewellConnect

If you wish to limit the processing that we carry out on your personal data, please notify us and we will take reasonable steps to respond to your request in accordance with legal requirements.

 

The right to oppose the processing of your personal data

You have the right to object to the processing of your personal data at any time.

 

The right to file a complaint with a supervisory authority

You have the right to file a complaint directly with a supervisory authority, such as the CNIL, with regard to the way in which we process your personal data.

Transparency and data access

Upon request, we will inform you of the existence, use and distribution of personal data about you, and we will allow you to access it.

 

In accordance with the applicable law, the User has a general right to access, modify, rectify and delete, for legitimate reasons, the Personal Data relating to them and collected via our materials.

 

You can exercise these rights and prerogatives by sending us your request via the contact form on our website or by writing to BewellConnect at 112 avenue Kléber 75116 Paris. This email and/or letter must contain a way to verify your identity.

 

A response will be sent to you within a maximum of two (2) months following receipt of the request.

How do we protect your personal data?

We are mindful of the importance of the security of your personal data. We make every effort to protect your personal data from misuse, interference, damage, unauthorised access, modification or disclosure. We have implemented numerous security measures to help you protect your personal data. In particular, we use access controls, firewalls and secure servers, and we encrypt personal data.

International transfers of your data:

Personal data will not be processed outside the European Economic Area (EEA)

Cookies and other technologies

Through our use of cookies and other technologies, we may also collect personal data about you when you visit our websites or third-party websites, or our mobile or third-party apps. This may include:

  1. information about your device’s browser and the operating system you are using;
  2. the IP address of the device you are using;
  3. the web pages you visit;
  4. the links you click on while you interact with our services.

More information is given about this in our cookie policy.

Notifications on our mobile apps

Our Mobile App may include notifications that may appear on your mobile device. The online platform from which our Mobile App can be downloaded to your mobile device determines, under its sole responsibility, the settings compatible with your mobile device’s operating system enabling you to authorise or deny the use of the notification features.

 

Please refer to the terms and conditions of use of the distribution platform from which our Mobile App can be downloaded to your mobile device. Please also refer to your mobile device settings to set up your notifications. You can change the notification settings of your Mobile App at any time to authorise or deny the use of notification features.

Location services on our mobile apps

The location services on your mobile device are your responsibility.

Our Mobile Apps may contain localisation features for your mobile device or our Services. The online platform from which our Mobile App can be downloaded to your mobile device determines, under its sole responsibility, the settings compatible with your mobile device’s operating system enabling you to authorise or deny the use of the location features.

Please refer to the terms and conditions of use of the distribution platform from which our Mobile App can be downloaded to your mobile device. Please also refer to your mobile device settings to set up the location services. You can change the location settings of your Mobile App at any time to authorise or deny the use of location features.

 

Location features may enable us to give you access to our Services or Customised Services based on your location. They also enable us to send you information, content, services or personalised sales offers that match your interests and location.

Contact us

BewellConnect is at your disposal for any comments or suggestions. You can write to us by email using the contact form

Data protection Policy modification

This Privacy Policy may be subject to change.