Privacy Policy

Effective Date: 2024-08-24

1. Introduction

Welcome to EphyrTech OU (“we”, “us”, “our”). We are committed to protecting your privacy and ensuring that your personal information is handled safely and responsibly. This Privacy Policy explains how we collect, use, share, and safeguard your data when you use our services, which include collecting and analyzing a range of health and activity metrics to provide personalized insights for both our platform users and health coaches.

2. Information We Collect

a. Personal Information Provided by You

When you create an account with us, we collect the following details:

- Account Information: First name, last name, email address, phone number, birthdate, and sex.

- Physical Metrics: Weight, height, sleep, daily activity, sleep activity, and additional body metrics.

b. Health and Activity Data

We collect a comprehensive set of health and activity metrics, including but not limited to:

• Sleep data

• Steps count

• Heart rate

• Daily activity levels

• Other related health and activity data

This data is collected both through direct user input and via connected wearable devices.

c. Automatic Data Collection

We also automatically gather the following information:

- Device and Usage Data: Device type, IP address, browser and device data.

- Location Data: General location information such as the city where you reside. This data is collected only with your consent.

3. How We Use Your Information

a. Primary Use of Data

We use the collected health and activity data to perform analyses and generate insights that help improve your health. Our platform creates personalized training programs designed to enhance your well-being.

b. Insights and Recommendations

Based on your data, we provide:

• Personalized training recommendations

• Food and product suggestions

• Activity suggestions

• Lifestyle improvement suggestions

c. Support for Health Coaches

Data is shared with health coaches through our website to facilitate:

• Personalized guidance

• Tailored health improvement plans

d. Communication

We use your information to send email and push notifications regarding:

• Upcoming meetings

• Suggestions related to sleep, nutrition, and hydration

Users can manage their communication preferences within the settings, where they can adjust both push and email notification levels.

4. Data Sharing and Third Parties

a. Third-Party Service Providers

We work with third-party service providers only when agreed with our users and their health plan providers (for example, an insurance company that has enrolled its users with us). These providers are required to adhere to strict security measures related to PII, PHI, and other data processing standards.

b. Legal Disclosures

We may disclose your information if it is necessary to comply with legal obligations, particularly in cases where non-disclosure could adversely affect a person’s life or result in injury.

c. Aggregated and Anonymized Data

We may use aggregated or anonymized data for research, analytics, or service improvement purposes. We ensure that such data is processed in a manner that it cannot be traced back to any individual.

5. Data Retention and Security Measures

a. Data Retention

We retain your personal data for a period of three (3) years. Our data deletion policy ensures that data is securely disposed of after this period or upon request, subject to applicable legal requirements.

b. Security Practices

We protect your data using industry-standard technical safeguards including:

• Encryption

• Secure storage

• Regular system analysis

Additionally, our employees and partners receive ongoing training to maintain high standards of data privacy.

6. Your Rights and Consent

a. Access and Correction

Users can access their personal data and request corrections through the app settings. We provide a clear process within the platform for such requests.

b. Data Portability and Deletion Requests

You can request data portability or deletion by submitting a ticket through the settings section of the app. There are no limitations or conditions on these requests beyond what is legally mandated.

c. Consent Management

• Providing Consent: Users register through the platform interface, thereby providing consent for data processing.

• Withdrawing Consent: To withdraw consent or delete your account, please file a ticket through the app settings.

Additional tools and settings are available within the app to manage your data preferences.

7. International Data Transfers and Compliance

a. Jurisdiction

We operate in Europe, the USA, Ukraine, Russia, and Asia. Currently, we do not transfer data internationally beyond these regions.

b. Regulatory Compliance

We comply with applicable privacy regulations, including GDPR and HIPAA. Our practices are aligned with these legal requirements, and we have taken the necessary steps to ensure your data is processed securely and lawfully.

8. Special Considerations for Health Data

a. Sensitive Health Data

In addition to standard health metrics, we also process sensitive data such as lab results. We employ additional safeguards and adhere to security best practices for handling this sensitive information.

b. Explicit Consent

We require explicit consent from users before collecting and processing health data. This consent is obtained and managed via our user interface during the data uploading process.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When changes occur, we will update the effective date at the top of the policy and notify you as appropriate. Your continued use of our services after any changes constitutes your acceptance of the revised policy.

10. Contact Information

For any questions, concerns, or requests regarding your privacy and data practices, please contact us at:

Email: admins@ephyrtech.com

Physical Address: Masina 22, Tallin, Estonia

Note: We only provide email support for privacy concerns.