WINGS Health AG (hereinafter also referred to as “WINGS”) is aware that the security of your private information from the use of our mobile application is an important concern. We take the protection of your personal data very seriously. Personal data means any information which may lead to your identification (hereinafter “Personal Data”). This Privacy Statement explains which data we collect and how we use and protect the data collected. This Privacy Statement applies to any Personal Data that we process.
The constant development of the internet and mobile technologies requires occasional adjustments to this Privacy Statement. We retain the right to make changes when necessary.
1. Information about WINGS Health
WINGS Health is an online platform from WINGS. Owner of the mobile application WINGS Health is:
WINGS Health AG
Dreikönigstrasse 34
8002 Zurich
Switzerland
2. Terms
‘Personal Data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
3. Data Controller and Contact Details
The Controller of your Personal Data is: WINGS Health AG.
Please contact WINGS Health AG with any problems, questions or suggestions that you may have.
Contact Information:
WINGS Health AG
Dreikönigstrasse 34
8002 Zurich
Switzerland
E-Mail: privacy@wings-health.com
4. Collection of Data
You need to create a personal profile in order to use our mobile application. Mandatory information that needs to be provided is:
- Your name, birthday, country of residence and ZIP code
- The language that you want to receive content in
- Your medical conditions
- Your interests
You can optionally choose to opt in to
- Collection of anonymous, technical performance data to help improve the app (statistical data about functions used, time spent in the app, crash logs, etc.)
- Collection of anonymous statistical information based on your personal profile
- Personalized offers from third parties
Regarding the Personal Data actively provided by you, we rely on technical and organizational means to assure that applicable data security regulations are followed.
5. Processing of Personal Data / Transfer of Personal Data
The processing of your Personal Data is generally carried out by the Controller in European data centers. An updated list of parties contracted by WINGS may be requested from the Data Controller at any time. We will retain control of and responsibility for the use of any Personal Data processed by us.
Some of this data may be stored or processed at computers located in other jurisdictions, such as the United States, whose data protection laws may differ from the jurisdiction in which you live. In such cases, we will ensure that appropriate protections are in place to require the data processor in that country to maintain protections on your Personal Data that are equivalent to those that apply in the country in which you live.
This applies mainly to the application’s authentication system, which makes use of Google’s services to verify authentication credentials. During authentication, your phone number, IP and browser type may be visible to Google. However, none of your profile data is shared with Google. Authentication and profile data resist on physically and logically isolated systems without any means of communication.
In case you have questions relating to your Personal Data and potential transfers of your Personal Data and the protections taken connected to such transfers please do not hesitate to send an e-mail to the Controller of your data: privacy@wings-health.com
Your Personal Data will not be passed on by us or by our agents/data processors for use by third parties in any form whatsoever, unless you have explicitly consented or we are legally obliged/entitled to do so.
6. Purposes of Use
The Personal Data that you actively provide us with will only be used for the purpose for which you provide such data i.e. to enable you to use the features of our mobile app.
All purposes which are not immediately linked to enabling you to use the app require explicit consent from you and include only the optional points listed in “Collection of Data”.
7. Security
Evoleen uses technical and organizational security precautions to protect your Personal Data from manipulation, loss, destruction or access by unauthorized persons. Our security procedures are continuously revised based on new technological developments.
8. Right of Access to, Rectification, Erasure or Restriction of Processing, Right to Object to Processing, Right to Data Portability
You have the right to request from the Controller (1) access to and (2) rectification or (3) erasure of your Personal Data or (4) restriction of processing of your Personal Data as well as you can (5) object to the processing of your Personal Data. In addition, you have (6) a right to data portability. Just send an e-mail to the Controller of your Personal Data: privacy@wings-health.com or contact the Controller at the address as set forth above under the section 3. ‘Data Controller and Contact Details’.
9. Right to Withdraw Consent at Any Time
You have the right at any time to withdraw your consent to the processing of your Personal Data for the future. For clarifications sake such withdrawal will, however, not affect the lawfulness of processing based on consent before its withdrawal. Again, just send an e-mail to the Controller of your Personal Data: privacy@wings-health.com or contact the Controller at the address as set forth above under the section 3. ‘Data Controller and Contact Details’.
10. Data Retention
We only retain Personal Data for as long as is necessary for us to render the service you have requested or to which you have given your consent, or to fulfill the purposes as set out in this document except where otherwise provided by law (e.g. in connection with a pending litigation). You have at any time the right to request the Data Controller to suspend or remove your Personal Data. Again, just send an e-mail to the Controller of your Personal Data: privacy@wings-health.com or contact the Controller at the address as set forth above under the section 3. ‘Data Controller and Contact Details’.
11. Right to Lodge a Complaint with a Supervisory Authority
If you are based in the EU you have in addition the right to lodge a complaint with a supervisory authority in case you do not agree with the processing of your Personal Data.
12. Changes to this Privacy Statement
WINGS reserves the right to make changes to this Privacy Statement at any time. It is strongly recommended to check this document often and consider the date of the last modification listed at the bottom of this document. If you disagree with the use of your Personal Data set out in this Privacy Statement you should quit using our mobile application and can send a request to the Data Controller to suspend or remove your Personal Data. Just send an e-mail to the Controller of your Personal Data, privacy@wings-health.com or contact the Controller at the address as set forth above under the section 3. ‘Data Controller and Contact Details’.
BY PROVIDING PERSONAL DATA TO US AND BY USING OUR MOBILE APPLICATION, YOU CONSENT TO THE COLLECTION AND USE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY STATEMENT.
