Privacy policy

Welcome to Euneo Health. This Privacy Policy outlines how we handle the Personal Information you provide or that we collect in connection with our services, including our mobile application (the "App"), clinician console (the "Console"), or website at www.euneohealth.com (the "Website"), collectively referred to as the "Products".

"Euneo Health," "we," "us," or "our" refers to Euneo Health ehf., the provider of the Products. “User” or "you" refers to anyone who accesses or uses our Products, including healthcare professionals and clients.

By accessing or using the Products you agree to this Privacy Policy and all applicable laws. If you do not accept this policy, please do not use the Products.

1. Information we collect

We may collect and process the following information:

Account Registration: When you create an account, we collect your email, password, name, date of birth, and gender. Healthcare professionals may also be asked to provide specific professional details, such as their role and practice setting.
Program Participation: When you start a program, you provide information including your height, weight, physical activity level, sports participation, personal goals, and other relevant health related information.
Program Activity: As you participate in a program, you provide self-reported data, including your pain level, responses to assessments, and adherence to exercises.
User Interaction Analysis: We use user behavior tracking tools, such as Mixpanel, to analyze how you interact with our Products. This data helps us enhance user experience and functionality.
Feedback: Any feedback you submit to us is collected to improve our Products and services.
Payment Processing: For subscription purchases, your payment information is processed by our third-party payment processors. We do not store your payment card details.
Device and Usage Data: We also collect data such as your device type, operating system version, system performance data, and your country of residence.
Anonymized or Aggregate Data Use: We may use anonymized or aggregated data derived from your information for research or development purposes, ensuring that such data does not personally identify any individual user.

2. Use of collected information

The information we collect from you is utilized for various purposes, including but not limited to:

Account Management: Creating and managing user accounts, specifically tailored for healthcare professionals and clients.
Service Provision: Providing access to our Products, which includes tailored programs and features based on the information you provide.
Product Enhancement: Improving the functionality and user experience of our Products, based on feedback and user interaction data.
Updates and Communications: Notifying you about changes, updates, or new features in the Products, and addressing your queries or concerns.
Feedback Analysis: Using your feedback to improve our services and respond to your needs more effectively.
Exercise and Progress Tracking: Enabling you to monitor your engagement and progress, including tracking exercises, pain levels, and assessment scores.
Healthcare Professional Access: Facilitating healthcare professionals' access to their clients' health data, contingent upon receiving informed consent from the clients.
Personalized Recommendations: Offering personalized suggestions and guidance based on your engagement with your program and progress.
Contractual Obligations: Fulfilling our commitments under any agreements you enter into with us.
Content Optimization: Ensuring that the content we provide is presented in the most effective and user-friendly manner.
Geographic Analysis: Understanding broad geographic locations to identify user groups and tailor services accordingly.
Marketing Communications: Sending marketing and promotional communications relevant to your interests and interactions with our Products.
Targeted Advertising: Delivering advertisements that are aligned with your interests and usage patterns.
Customer Testimonials: Showcasing user experiences and testimonials for promotional and feedback purposes.
Legal Compliance and Prevention of Harm: Addressing legal requests, complying with regulatory requirements, and taking actions to prevent any potential harm.
Operational Management: Ensuring the smooth running and operation of our Products, based on user data and interaction insights.
Anonymized or Aggregate Data Usage: To use anonymized or aggregated data for research, analysis, or development purposes, ensuring individual users cannot be identified.

By using our Products, you consent to the use of your information for these purposes. We are committed to ensuring that your data is used responsibly and in accordance with our Privacy Policy.

3. Payment processing

We do not directly collect or process credit or debit card data. For subscription purchases, your payment information is processed by our third-party payment processors, Apple, Google, and Stripe.

4. Protection and retention of information

Your information is securely stored using the Google Cloud SQL service until you decide to delete your Euneo Health account. Accounts that remain inactive for a period of two years will be automatically anonymized. To delete your account, you can follow the instructions available on our support page or reach out to support@euneohealth.com for assistance.

Euneo Health implements comprehensive administrative, technical, and physical safeguards to protect your Personal Information against unauthorized access, loss, theft, or misuse. Your data is encrypted on secure servers in controlled facilities. Access to personal data is limited to authorized personnel who require it for operational purposes. Despite our robust measures, please be aware that no internet transmission is entirely secure.

5. Disclosure of information

We may share your information with trusted subsidiaries, affiliates, joint venture partners, contracted companies, and service providers for operational assistance, under strict privacy agreements. We do not share personally identifiable information with unaffiliated third parties.

These service providers, listed below, are authorized to use your information only as necessary to perform specific services on our behalf:

Cloud computing services
Communication and collaboration services
Data analytics services
Data storage services
Financial services
Performance monitoring services
Product engineering and design services
Sales and marketing services
Social networks
User authentication services
Website hosting service providers

We may also disclose Personal Information as required by law or in response to legal processes. In a business transition, such as a merger or acquisition, your Personal Information may be among the transferred assets.

6. Legal basis for processing personal information

Our Role

As a Data Controller: In most instances, Euneo Health acts as a data controller. This means we decide how and why your personal information is processed for the purpose of providing our Products. This includes instances where we collect your information directly or determine the specific uses of that data.
As a Data Processor: In certain specific scenarios, particularly when processing data on behalf of another entity, like a healthcare organization, we may act as a data processor. Here, we process personal information strictly according to the instructions provided by the entity, the data controller, which might be your healthcare provider.

Basis for Processing Your Information

User Consent: We mainly process your personal information based on your explicit consent, especially for personalized services and features within our Products.
Contractual Necessity: If we have a contract with you (e.g., a subscription agreement), we process your personal information to fulfill our obligations under that contract.
Legal Obligations: We process personal information as necessary to comply with our legal obligations, such as regulatory requirements.
Legitimate Interests: In some cases, we process personal information based on legitimate interests, like improving our Products, unless your data protection interests or fundamental rights override those interests.

Your Control and Choices

Opt-Out Rights: You have the right to opt out of certain uses of your personal information, especially for marketing purposes.
GDPR Compliance: We adhere to the GDPR, which means you have rights regarding your personal information, including the right to access, correct, and in some cases, delete your data.

7. Your rights as a user of our Products

Providing Personal Information

Voluntary Submission: Providing your Personal Information is entirely voluntary. However, not providing certain information may limit your ability to fully utilize our Products.

Data Protection Rights

For EEA Residents: If you are in the European Economic Area (EEA), you have specific rights regarding your Personal Information.
General Rights for All Users: Regardless of your location, we respect your rights to control your Personal Information.

Your Specific Rights

Right to Rectification: You can request the correction of inaccurate Personal Information and completion of incomplete data.
Right to Erasure: You may request the deletion of your Personal Information. We will anonymize your data upon request, ensuring it cannot be reconstructed to identify you. This right is subject to legal and legitimate grounds that may necessitate retaining the data.
Right to Restrict Processing: Under certain conditions, you can request that we limit the processing of your Personal Information.
Right to Data Portability: You have the right to receive your Personal Information in a structured format and transfer it to another entity, applicable when processing is consent-based or contract-based.
Right to Object: You can object to the processing of your Personal Information, especially for direct marketing. You can exercise this right through opt-out options in communications.
Right to Lodge a Complaint: If you believe your data protection rights are violated, you can lodge a complaint with the relevant supervisory authority.
Right to Post-Mortem Instructions: As per applicable laws, you may guide us on handling your Personal Information posthumously.

Exercising Your Rights

Contact Us: To exercise your rights, contact us using the details provided below.
Verification Process: We will verify your identity before processing requests to ensure the security of your information.
Authorized Representatives: If a request is made by an authorized representative, we may need evidence of this authorization.
Sufficient Information Requirement: Ensure your request includes enough detail for us to understand and respond effectively.

Please Note

Conditions Apply: Some rights are subject to specific conditions or exceptions.
Identity Verification: We must verify your identity or authority before responding to requests.

9. Marketing and advertisements

Newsletter Subscription: You can subscribe to our electronic newsletters at any time. Your email address will be kept confidential and only used as outlined in this policy.
Opt-Out Option: You can unsubscribe from marketing emails at any time using the 'unsubscribe' link in our emails or by contacting us directly. Essential transactional emails will still be sent as needed.
Advertisement Practices: We may show online advertisements and share non-personal, aggregated information with our advertising partners. This information helps tailor advertisements to your interests. We do not share your identifiable personal information with these partners.

10. Links to third-party sites

Our Products may include links to external sites. We do not endorse and are not responsible for the content or privacy practices of these sites. We recommend reviewing their privacy policies before submitting any personal data.

11. Social media features

Our Products include social media features like “Share”. These features may collect your IP address and the page you’re visiting on our site, and may set a cookie to function properly. Interaction with these features is governed by the privacy policy of the providing company.

12. Privacy of children

Our Products are intended for users aged 18 and over. Minors under 18 may access the content only with parental or guardian consent. We do not knowingly collect personal information from children under 18. If we become aware of such collection, we will take steps to delete the information as soon as possible.

13. Transfer of information

We store your personal data securely within the European Union. If we need to transfer your data outside the EU, we will protect it with legal safeguards like EU-approved standard contractual clauses to ensure its security and integrity.

14. Data breach

In the event of a data breach, we will take appropriate measures, including investigation, reporting, and cooperating with law enforcement. Affected individuals will be notified if there is a reasonable risk of harm or as required by law. We advise users to monitor their accounts and report any suspicious activity.

15. Changes to our privacy policy

We reserve the right to modify this Privacy Policy at any time. Changes will be effective immediately upon posting the updated policy. We'll inform you of significant changes through the contact information you've provided or via our Products. By continuing to use the Products after updates, you agree to the revised policy. However, we won't use your personal information in a new way without your consent if it's materially different from what was stated when your information was collected.

16. Acceptance of this privacy policy

By using our Products, you acknowledge that you have read and agree to this Privacy Policy. If you do not agree with the terms, you should not access or use our Products.

This Privacy Policy is effective and was last updated on November 14, 2023. Euneo Health ehf. is located at Klapparstígur 25-27, 101 Reykjavík, Iceland. We encourage you to contact us at support@euneohealth.com if you have any further concerns.