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Privacy Policy

Introduction

We ("we", "us", "our") take the protection of the data of the users ("users" or "you") of our website and/or mobile app (the "website" or the "mobile app") very seriously and undertake to protect the information that users provide us in connection with the use of our website and/or mobile app (together: "digital assets"). Furthermore, we undertake to protect and use your data in accordance with applicable law.

This privacy policy explains our practices regarding the collection, use and disclosure of your data through the use of our digital assets (the "services") when you access the services via your devices.

Please read the privacy policy carefully and make sure you fully understand our practices regarding your data before using our services. If you have read and fully understood this policy and do not agree with our approach, you must stop using our digital assets and services. By using our services, you acknowledge the terms of this privacy policy. Continued use of the services constitutes your consent to this privacy policy and any changes to it.

In this privacy policy you will learn:

  • How we collect data
  • What data we collect
  • Why we collect this data
  • Who we share the data with
  • Where the data is stored
  • How long the data is retained
  • How we protect the data
  • How we deal with minors
  • Updates or changes to the privacy policy

What data do we collect?

Below you will find an overview of the data we may collect:

Unidentified and unidentifiable information that you provide during the registration process or that is collected through the use of our services ("non-personal data"). Non-personal data cannot be used to identify who it was collected from. The non-personal data we collect mainly consists of technical and aggregated usage information.

Individually identifiable information, i.e. all information by which you can be identified or could be identified with reasonable effort ("personal data"). The personal data we collect through our services may include information that is requested from time to time, such as names, e-mail addresses, addresses, telephone numbers, IP addresses and more. If we combine personal data with non-personal data, these will be treated as personal data by us as long as they are in combination.

How do we collect data?

Below are the main methods we use to collect data:

We collect data when you use our services. So when you visit our digital assets and use services, we may collect, record and store usage, sessions and related information.

We collect data that you provide to us yourself, for example when you contact us directly via a communication channel (e.g. an e-mail with a comment or feedback).

We may collect data from third-party sources, as described below.

We collect data that you provide to us when you log in to our services via a third-party provider such as Facebook or Google.

Why do we collect this data?

We may use your data for the following purposes:

  • to provide and operate our services;
  • to develop, customise and improve our services;
  • to respond to your feedback, requests and wishes and to offer assistance;
  • to analyse request and usage patterns;
  • for other internal, statistical and research purposes;
  • to improve our data security and fraud prevention capabilities;
  • to investigate violations and enforce our terms and policies and to comply with applicable law, regulations or official orders;
  • to send you updates, news, promotional material and other information related to our services. With advertising e-mails you can decide for yourself whether you wish to continue receiving them. If not, simply click on the unsubscribe link in these e-mails.

Who do we share this data with?

We may share your data with our service providers to operate our services (e.g. storing data via third-party hosting services, providing technical support, etc.).

We may also disclose your data under the following circumstances: (i) to investigate, detect, prevent or take action against illegal activities or other misconduct; (ii) to establish or exercise our rights of defence; (iii) to protect our rights, property or personal safety and the safety of our users or the public; (iv) in the event of a change of control at us or one of our affiliated companies (by way of merger, acquisition or purchase of (substantially) all assets, etc.); (v) to collect, retain and/or manage your data using authorised third-party providers (e.g. cloud service providers) to the extent appropriate for business purposes; (vi) to work with third-party providers to improve your user experience. To avoid misunderstandings, we would like to point out that we may transmit, share or otherwise use non-personal data to third parties at our own discretion.

Please note that our services enable social interactions (e.g. posting content, information and comments publicly and chatting with other users). We would like to point out that all content or data that you make available in these areas can be read, collected and used by other people. We advise against posting or sharing information that you do not want to make public. If you upload content to our digital assets or otherwise make it available in the course of using a service, this is at your own risk. We cannot control the actions of other users or members of the public with access to your data or content. You acknowledge and confirm that copies of your data may remain accessible on cached and archived pages or after a copy/storage of your content by third parties, even after deletion.

Cookies and similar technologies

When you visit or access our services, we authorise third parties to use web beacons, cookies, pixel tags, scripts and other technologies and analytics services ("tracking technologies"). These tracking technologies may enable third parties to automatically collect your data in order to improve the navigation experience on our digital assets, optimise their performance and ensure a customised user experience, as well as for security and fraud prevention purposes.

To find out more, please read our cookie policy.

Without your consent, we will not share your e-mail address or other personal data with advertising companies or advertising networks.

Google Ads (conversion measurement and remarketing)

With your consent we use Google Ads by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). This lets us measure whether visitors who reach this website through one of our ads go on to, for example, send an enquiry (conversion measurement), and lets us show you relevant ads on other websites (remarketing).

For this, your browser loads the Google tag (gtag.js) from Google's servers. Google sets cookies (e.g. "_gcl_au") and processes usage data such as your IP address, pages visited, time, browser and device information and the identifier of an ad click. Data may be transferred to Google LLC in the USA; Google LLC is certified under the EU-US Data Privacy Framework, which is covered by an adequacy decision of the European Commission.

The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). Without your consent the Google tag is not loaded. You can withdraw your consent at any time with effect for the future: choose "Cookie settings" at the bottom of the page and untick "Advertising" or choose "Reject". This deletes this website's Google Ads cookies ("_gcl_…"); cookies that Google sets on its own domains can be deleted in your browser settings.

More information: Google Privacy Policy and How Google uses cookies in advertising.

OpenAI Ads (measuring ads in ChatGPT)

With your consent we use the measurement pixel of OpenAI Ireland Ltd, 1st Floor, The Liffey Trust Centre, 117-126 Sheriff Street Upper, Dublin 1, D01 YC43, Ireland ("OpenAI"). This lets us measure whether visitors who reach this website through one of our ads in ChatGPT go on to, for example, try AnnaCare Home for free (conversion measurement).

For this, your browser loads a script from OpenAI's servers and sends measurement data to OpenAI. The pixel sets the cookies "__oppref" (identifier of the ad click, 30 days) and "__obref" (random identifier of your browser, 365 days). Your IP address, the page visited, the time and browser and device information are also processed. If you continue to app.anna.care via "Kostenlos testen" (try for free), we pass the ad click identifier on to it, where it is stored until the tab is closed; if you order a trial there, our server reports this order with the identifier to OpenAI, without your name, e-mail address or phone number. The data may also be processed in the USA; according to OpenAI, the transfer is based on adequacy decisions and standard contractual clauses of the European Commission.

The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). Without your consent the pixel is not loaded. You can withdraw your consent at any time with effect for the future: choose "Cookie settings" at the bottom of the page and untick "Advertising" or choose "Reject". This deletes this website's "__oppref" and "__obref" cookies.

More information: OpenAI Privacy Policy.

Web analytics with Umami

To understand how our website is used, we use the open-source software Umami. Umami runs on our own server in Germany (Hetzner Online GmbH, Falkenstein data centre); the data is not passed on to third parties.

When you open a page, your browser sends the following to this server: the page opened, the previously visited page (referrer), browser, operating system, device type, screen size and language, the page's loading times, and whether you successfully submitted a form, clicked "Kostenlos testen" (try for free) or a link to the AnnaCare Dashboard, moved the mouse over the dashboard preview, or ordered a trial on app.anna.care. For the Nacht-Check these are: the start, the progress per question (only the number of the question, never your answer), that the result was displayed, that the plan was requested, the e-mail address confirmed and a call back requested – without your answers and without your e-mail address. Umami derives country, region and city from the IP address; the IP address itself is not stored. To group page views into a visit, Umami creates a pseudonymous identifier (hash) from the IP address and browser details that changes every month. Umami sets no cookies and stores nothing on your device. We keep the data for as long as we need it for the analysis.

The AnnaCare Home app at app.anna.care also reports page views on the public path to an order (start page, plan selection, order form and order confirmation) to these statistics. From the address it only sends the path, the chosen plan and campaign parameters (utm), not the ID of an ad click. What the app measures beyond that in statistics of its own is described in its privacy policy. If your browser has “Do Not Track” enabled, app.anna.care sends nothing to Umami.

The legal basis is our legitimate interest in data-minimising audience measurement in order to improve our offering (Art. 6(1)(f) GDPR). You can object to this at any time. If you tick the box, your browser stores the entry "umami.disabled" and no longer sends data to Umami from www.anna.care; if you clear your browser data, you need to tick it again.

Heatmaps and session recordings (Umami)

With your consent we use Umami to record how you use our website: mouse movements, clicks, taps and scrolling, the window size and the structure and content of the pages displayed. From this we create heatmaps (in summary: where on a page people click and how far they scroll) and session recordings (a reconstructed replay of a single visit). This shows us what is clear on our pages and where visitors get stuck.

What you type into form fields is not recorded but replaced by placeholders. Areas showing your own details (for example your e-mail address after subscribing to the newsletter, the confirmation of an enquiry or the "Rufanlage erfassen" page) are hidden. Nothing of the Nacht-Check is recorded: no recording takes place on its own pages, and its window on our home page is hidden, including clicks and mouse movements in it. The recording belongs to the pseudonymous identifier of your visit described under "Web analytics with Umami"; your IP address is not stored and no cookies are set.

The data is processed exclusively on our server in Germany (Hetzner Online GmbH, Falkenstein data centre, as hosting provider on our behalf) and is not passed on to third parties. We delete heatmap data and session recordings automatically after 90 days.

The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). Without your consent nothing is recorded. You can withdraw your consent at any time with effect for the future: choose "Cookie settings" at the bottom of the page and untick "Heatmaps and recordings" or choose "Reject". Recording then stops immediately.

Nacht-Check (night check)

The Nacht-Check consists of seven questions. We evaluate your answers exclusively in your browser; they stay on your device and are not transmitted to us, nor to Umami.

If you would like to receive the night plan by e-mail, we store your e-mail address and who the plan is for (mother, father, yourself or others) so that the e-mails address you correctly. We process the information on when someone notices a fall only to create and send the first e-mail: it is contained in the signed confirmation link (valid for seven days) and is not stored in our CRM; the text of the confirmation e-mail and the first e-mail is deleted no later than one day after sending.

If you also tick the newsletter box, we add your e-mail address to the AnnaCare Home newsletter list only after your confirmation. The newsletter has its own unsubscribe link.

We use the double opt-in procedure: you first receive an e-mail with a confirmation link; only after you confirm do we send you the plan and, over the course of ten days, four further e-mails with tips and information about AnnaCare Home (five e-mails in total). Entries that are not confirmed are deleted after seven days. We send the e-mails through our CRM (ERPNext), which we operate ourselves.

The legal basis is your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time with effect for the future: every e-mail contains an unsubscribe link; alternatively, a message to us is enough. After that you will not receive any further e-mails.

If you request a call back, we store your phone number, the time you chose (morning or afternoon) and who you did the check for in our CRM and call you back accordingly. The legal basis is the handling of your request (Art. 6(1)(b) GDPR).

Nothing of the Nacht-Check is recorded, neither on its own pages nor in its window on our home page (see "Heatmaps and session recordings"). The confirmation and unsubscribe links carry their details in the part of the address after the "#", which is not transmitted to our server.

Server log files

Each time our website is accessed, our web server stores in log files: the shortened IP address (for IPv4 without the last byte, for IPv6 only the first 48 bits), date and time, the address requested, the HTTP status code, the amount of data transferred, the referrer and the browser identifier (user agent). From these, the software GoAccess on the same server creates statistics, for example on page views, error pages and search engine crawlers. The log files are deleted after 30 days at the latest. The legal basis is our legitimate interest in operating the website securely and without errors and in analysing its use (Art. 6(1)(f) GDPR).

Where do we store the data?

Non-personal data

Please note that our companies and our trusted partners and service providers are located all over the world. For the purposes explained in this privacy policy, we store and process all non-personal data we collect in different jurisdictions.

Personal data

Personal data may be maintained, processed and stored in the United States, Ireland, South Korea, Taiwan, Israel and, to the extent necessary for the proper provision of our services and/or required by law (as further explained below), in other jurisdictions.

How long is the data retained?

Please note that we retain the collected data for as long as necessary to provide our services, comply with our legal and contractual obligations to you, resolve disputes and enforce our agreements.

We may correct, supplement or delete inaccurate or incomplete data at any time at our own discretion.

How do we protect the data?

The hosting service for our digital assets provides us with the online platform through which we can offer you our services. Your data may be stored via our hosting provider's data storage, databases and general applications. They store your data on secure servers behind a firewall and they offer secure HTTPS access to most areas of their services.

Notwithstanding the measures and efforts taken by us and our hosting provider, we cannot and will not guarantee absolute protection and security of the data you upload, publish or otherwise share with us or others.

For this reason, we would like to ask you to set secure passwords and, where possible, not to transmit confidential information to us or others whose disclosure you believe could cause you significant or lasting harm. Since e-mail and instant messaging are not considered secure forms of communication, we also ask you not to share confidential information via either of these communication channels.

How do we deal with minors?

The services are not intended for users who have not yet reached the legal age of majority. We will not knowingly collect data from children. If you are not yet of legal age, you should not download or use the services and should not provide us with any information.

We reserve the right to request proof of age at any time so that we can verify whether minors are using our services. In the event that we become aware that a minor is using our services, we may prohibit and block such users from accessing our services, and we may delete any data we hold about that user. If you have reason to believe that a minor has provided data to us, please contact us as explained below.

We only use your personal data for the purposes set out in the privacy policy and only if we are convinced that:

  • the use of your personal data is necessary to fulfil or conclude a contract (e.g. to provide you with the services themselves or customer support or technical support);
  • the use of your personal data is necessary to comply with applicable legal or regulatory obligations, or
  • the use of your personal data is necessary to support our legitimate business interests (provided that this is always done in a manner that is proportionate and respects your privacy rights).

As an EU resident, you may:

  • request confirmation of whether or not personal data concerning you is being processed, and request access to your stored personal data as well as certain additional information;
  • request the receipt of personal data that you have provided to us in a structured, commonly used and machine-readable format;
  • request the correction of your personal data stored with us;
  • request the deletion of your personal data;
  • object to the processing of your personal data by us;
  • request the restriction of the processing of your personal data, or
  • lodge a complaint with a supervisory authority.

Please note, however, that these rights are not unrestricted and may be subject to our own legitimate interests and regulatory requirements. If you have general questions about the personal data we collect and its use, please contact us as indicated below.

In the course of providing the services, we may transfer data across borders to affiliated companies or other third parties and from your country/jurisdiction to other countries/jurisdictions worldwide. By using the services, you consent to the transfer of your data outside the EEA.

If you are resident in the EEA, your personal data will only be transferred to locations outside the EEA if we are satisfied that an adequate or comparable level of protection of personal data exists. We will take appropriate steps to ensure that we have appropriate contractual arrangements with our third parties to ensure that appropriate safeguards are in place to minimise the risk of unlawful use, alteration, deletion, loss or theft of your personal data and that these third parties act at all times in accordance with applicable laws.

Rights under California Consumer Privacy Act

If you use the services as a California resident, you may be entitled under the California Consumer Privacy Act ("CCPA") to request access to and deletion of your data.

To exercise your right to access and delete your data, please see below how to contact us.

We do not sell personal data of users for the intentions and purposes of the CCPA.

Users of the services who are California residents and under 18 years of age may request and obtain the deletion of their published content by e-mail at the address given in the "Contact" section below. All such requests must be labelled "California Removal Request". All requests must include a description of the content you wish to have deleted and sufficient information to enable us to locate the material. We do not accept notices that are not labelled or properly submitted, and we may not be able to respond if you do not provide sufficient information. Please note that your request does not guarantee that the material will be deleted completely or comprehensively. For example, material you have posted may be republished or reposted by other users or third parties.

Updates or changes to the privacy policy

We may revise this privacy policy from time to time at our own discretion, and the version published on the website is always current (see the "as of" date). We ask you to check this privacy policy regularly for changes. For material changes, we will post a notice on our website. If you continue to use the services after notification of changes on our website, this constitutes your acknowledgement and consent to the changes in the privacy policy and your agreement to be bound by the terms of those changes.

Contact

If you have general questions about the services or the data we collect about you and its use, please contact us at:

Name: senvis Medical GmbH, Joel Esapathi
Address: Hermann-Enters-Str. 1, 42287 Wuppertal
E-mail address: esapathi@senvis.de

DISCLAIMER

The information contained herein does not constitute legal advice and you should not rely on it alone. Specific requirements relating to legal terms and policies may vary from state to state and/or from legal system to legal system. As set out in our terms of use, you are responsible for ensuring that your services are lawful under the law applicable to you and that you comply with it.

To ensure that you fully comply with your legal obligations, we strongly recommend that you seek professional advice to better understand the requirements that apply specifically to you.