Privacy Policy
Last updated: October 16, 2024
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells you about Your privacy rights and how the law protects You.
We use Your data to provide and improve Our Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.
1. Interpretation & Definitions
1.1. Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
1.2. Definitions
For the purposes of this Privacy Policy:
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Account means a unique account created for you to access our Service or parts of our Service.
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Activity Data are data collected given your permission from accessing Apple Health or any relevant services, and may be generated from your devices, and relate to physical actions and measurements regarding your activity.
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Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to WUP Technologies IKE, Adeflon Didaskalou 6, 15669, Papagou Greece (GEMI registry: 153440001000). For the purpose of the GDPR, the Company is the Data Controller.
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Cookies are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.
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Country refers to: Greece
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Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Data.
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Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
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Health Data is information regarding your health, either as information for your medical history or as exams you have uploaded to create your health record.
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Medical personnel is any medical related profession, like doctor or nurse, that may be using the Service to add and get value from it.
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Personal Data is any information that relates to an identified or identifiable individual.
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For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
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Service refers to the Website or the Mobile Application.
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Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
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Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
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Website refers to Nudge, accessible from https://www.nudge.care
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You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
2. Collecting & Using Your Data
Overall, we don’t transfer your sensitive data to any other entity outside the Service, without your previous and explicit consent. You provide Us with your data, at your will, optionally to get the value from the functionality we provide you with. We don’t seel your data to any entity outside the Service.
Also, we work with Medical advisors to minimize the information collected, and maximize the value you can get when you share it with medical personnel, to advise you on prevention topics.
Any processing to help you with your health prevention will take place with your consent, according to Our Terms and Conditions.
2.1. Types of Data Collected
2.1.1. Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
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First name and last name
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Phone number
This information is representative of you and it is encrypted.
Additionally, personal information needed to get value from the application is:
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Date of birth
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Sex at birth
This information is used to give you a list of recommendations (checklist) that help you with your health prevention.
The additional information you may give to the application is:
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Height
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Weight
Which is used to calculate your BMI (Body Mass Index), as an indication of your health, which may be used by Medical personnel to provide you with health services.
That information is encrypted and accessed by you with the usage of your email and your password. You must keep your password private from any other entity. You may provide access to that information to other users of the platform with medical background, only with your explicit permission, in order to receive any medical advice or service.
Your email is used to support the operational parts of the system, such as blocking and unblocking users, or completing requests for downloading your data. If you are concerned that your email may expose your identity, you should use the anonymized login methods that account providers offer, such as Apple ID. We are continuously working to improve technically, to reduce any hazards.
2.1.2. Activity Data
Activity Data are collected by syncing with the Apple Health application on your iOS device, for measurements that you have explicitly given access to the application.
This information is used to visualize your activity progress through time, so you have a better understanding of your lifestyle. You can also share any of that information with medical personnel, to help them provide you better advices or health services. The list of activity data the app collects is, if supported by your devices:
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Respiratory rate
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Blood oxygen
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Blood pressure
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Body temperature
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Weight
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Heart Rate
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Steps
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Sleep
You can revoke access to the application to this activity data by visiting the settings of your iOS device, under the category health, and choose to remove certain or full access to the Service.
2.1.3. Health Data
You can provide the Application with health data, in two different ways.
Category 1: You can provide manually through the application the following information regarding your health history:
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Diagnosed conditions
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Surgeries
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Family record
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Medication
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Allergies
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Lifestyle information (smoking, drinking)
This information is used by the system to provide you with more personalized health check recommendations. It may also be reviewed by Medical personnel if you give them access to, it to help with Your health prevention and give your recommendations or create plans.
Category 2: You can provide manually or upload files from the results of the lab exams, so you can create you health record. We are agnostic of the information you will provide through the files, and we do the best effort to match with actual data. You have the option to edit or remove information, after the analysis of this document. Your documents are also encrypted and can be retrieved only by you or from users you give them access to. This information can be mapped with actual values that will be available under your personal metrics. You can choose to share that information with Medical personnel. You can access, view, and delete any files you uploaded.
The goal of collecting Health Data is to build a health record you can later share with medical personnel, to get better medical advices or services, or for your own usage, to monitor your health progress through time and understand your behavioral patterns that affect your health.
Providing your health data is optional, and you can delete and remove that information at any time from the Service.
2.1.4. Usage Data
Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when you access the Service by or through a mobile device.
2.2. Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
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Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
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Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. Learn more about cookies: Use of Cookies by Free Privacy Policy.
We use both Session and Persistent Cookies for the purposes set out below:
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Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services. -
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website. -
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website. -
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.
2.3. Scope of Data Collection and Processing
2.3.1. Use of Your Data
The Company may use Data for the following purposes:
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To provide and maintain our Service, including to monitor the usage of our Service.
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To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
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For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
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To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
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To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
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To manage Your requests: To attend and manage Your requests to Us.
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For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
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For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
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With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.
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For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
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With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
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With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
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With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
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With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Your Activity and Health Data are used in the following situations:
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Create visualization: your data are grouped and analyzed in order to give You a detailed view and understanding of your behavior and health through time.
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Provide Your health checklist: your personal information, your lifestyle and health record is used to provide you a personalized list of recommendations for visits to medical experts and exams. All these recommendations should be subscribed at the end by a health service provider, but You are informed of what health standards and protocols suggest to stay healthy.
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Create your shareable health record: all the information You collect will become shareable under secure and detailed ways, on Your explicit request, to medical service providers of your choice. It will also be withdrawable.
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With Your consent: We may process Your Activity and Health information for any other purpose with Your consent.
2.3.2. Retention of Your Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
2.3.3. Transfer of Your Data
Your information, including Personal, Activity and Health Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
2.3.4. Disclosure of Your Data
2.3.4.1. Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Data may be transferred. We will provide notice before Your Data is transferred and becomes subject to a different Privacy Policy.
2.3.4.2. Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
2.3.4.3. Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
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Comply with a legal obligation
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Protect and defend the rights or property of the Company
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Prevent or investigate possible wrongdoing in connection with the Service
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Protect the personal safety of Users of the Service or the public
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Protect against legal liability
2.4. Security of Your Data
The security of Your Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Data, We cannot guarantee its absolute security.
3. Detailed Information on the Processing of Your Data
3.1. Analytics
We may use third-party Service providers to monitor and analyze the use of our Service.
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Google Analytics and Firebase - Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the GoogleAnalytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms webpage: https://policies.google.com/privacy
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Sentry for Error Monitoring and Performance Analysis - We use Sentry to monitor application performance and track issues, helping us identify and resolve errors effectively to enhance your user experience. Sentry collects non-personally identifiable information related to system errors, performance, and usage metrics. This data enables us to promptly address technical issues and optimize app performance.
3.2. Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
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Mailchimp - Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC. For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/
3.3. Website & Form Builder
We may use Website Management to manage Your cookie preferences and manage contact forms, as well as the forms You are answering to subscribe to Our Email Marketing services.
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Wix - Wix is a website builder tool. For more information on the privacy practices of Wix, please visit their Privacy policy: https://www.wix.com/about/privacy
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Typeform - is an online form building and online surveys. You can send Us and email to remove any data related with the forms We collected through Typeform. For more information on the privacy practices of Typeform, please visit their Privacy policy here.
4. GDPR Privacy
4.1. Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
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Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
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Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
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Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
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Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
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Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
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Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
4.2. Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
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Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
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Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
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Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
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Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
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Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
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Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
4.3. Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
5. Children's Privacy
Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.
6. Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
7. Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
8. Contact Us
If you have any questions about this Privacy Policy, You can contact us:
By email: contact@nudge.care