- Our Policy applies to all users who access the Service (“Users”).
1. INFORMATION WE COLLECT
We collect the following types of information.
Information you provide us directly:
- Any information you provide at the time of registering for a VIA Together App account. This includes your name, e-mail address, address, date of birth, gender, diagnostic, status: currently in treatment / finalized treatment, year of diagnosis/year of finishing treatment, interests, description and profile picture. Note that while numerous fields are provided at the time of registering, not all are required to activate your VIA Together App account.
- Profile information that you provide for your user profile. This information allows us to help you or others be “found” on the VIA Together App, and may include your name, address, e-mail address, date of birth, gender, diagnostic, status: currently in treatment / finalized treatment, year of diagnosis/year of finishing treatment, interests, description and profile picture or any other information you may voluntarily choose to place into your profile or share with other Users.
- Any other Content that you choose to associate with your account on the Service.
- Communications between you and the VIA Together App. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related e-mails.
We do not collect personally identifiable information from you unless you provide it to us voluntarily and knowingly. Personal information may also be needed for certain optional activities:
- If you choose to customize the Application or Service to your needs, we retain the preferences you select so that you will not have to reenter the information each time you access the Application or the Service. These preferences may include requests for email, information on specific cancer types and language preferences. You can access your profile by entering your e-mail address and password each time you use the Application or Service.
- If you choose to participate in a direct or group chat or discussion that we make available to our users in connection with the Service, please remember that any information that you disclose in these areas might become public information. You should exercise caution when deciding whether or not to disclose your personal information.
- We may use third-party analytics tools (Google Analytics) to help us measure traffic and usage trends for the Service. These tools collect information and data about your usage of the Service. We collect and use this analytics information with analytics information from other Users. We may choose to use this information to both improve the Service, make it available to other persons or entities who may benefit from the Service, or other persons or entities with whom we may choose to enter into a license agreement for the use of the Service or the Application. However, we will never share individualized medical information with third parties. We may share de-identified or aggregate information as stated herein for the purposes stated herein. By using the Service, you agree that we may use this information for these purpose(s).
Cookies and similar technologies:
Log file information:
- Log file information is automatically reported by your mobile device each time you make a request to access (i.e., visit) the Application. It can also be provided when content from the Service is downloaded to your device.
- When you use the Service, the Application may automatically record certain log file information, including your request to download the Service, your device information and other such information. The information allows for more accurate reporting and improvement of the Service.
Creating an account using social media.
- When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by the Service.
- A device identifier may deliver information to us about how you use the Service and may help us provide reports or personalized content. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
- Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted. The Service may collect or retain this information.
2. Legal Basis for Processing
- For the performance of a contract in order to perform our contractual obligations to you, including but not limited to account registration.
- To meet legal obligations in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation.
- For Legitimate Interests in order to operate our business and provide the Services, other than in performing our contractual obligations to you, for our “legitimate interests” for the purposes of applicable law – except where overridden by the interests or fundamental rights and freedoms that require protection of Personal Data.For example, the following areas include processing covered by Legitimate Interests, subject to applicable law:
-Communication. To communicate with you regarding the Services, including to provide you important notices regarding changes to our Terms and Conditions and also to address your requests, inquiries, and complaints. We may send strictly necessary communications, including emails, even if you have opted out of receiving other emails or communications from us. These types of communications do not require consent. We also process your Personal Data for our legitimate interests when you communicate with us, including when you sign up for promotional materials and we have not asked you for your consent in that regard.
-Respond to Your Requests. To respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests.
-Promotional Messages. We process your non-sensitive Personal Data to provide you with promotional messages and personalized marketing, including: when you communicate with us or sign up for promotional materials; when you participate in special activities, offers, or programs; when you engage with our online communities or advertising; to provide you geographically relevant Services, offers, or advertising; when we aggregate and centralize data;
-Surveys. To send you surveys in connection with our Services, unless commercial in nature. In those cases, a survey request may be sent to you if you have given us your consent to receive marketing from us.
-Compliance with Law and Public Safety . To assist in the investigation of suspected illegal or wrongful activity, including in-store tracking and sharing information with other entities for fraud, loss, and crime prevention purposes. To protect and defend our rights and property, or the rights or safety of third parties.
-Improvement and Development. To develop, provide, enhance, and improve our Services and your experience, including to enable you to use the full range of our Services (e.g., processing of non-sensitive Personal Data related to your use; when we collect, use, or otherwise leverage cookies, device IDs, Location Data, data from the environment, and other tracking technologies; when you connect with us through social media; when we collect data from third parties or publicly-available sources; when we aggregate and centralize data; and when we share Personal Data with our service providers and vendors). For internal purposes related to certain research, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.
-Merger or Acquisition. To support a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.
Consent as a Basis for Processing
In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when
- (I) providing us with your Personal Data through our Services or a form (including enrolling in Promotions); or
- (ii) registering or creating an account with us. Due to different countries’ laws governing consent for the collection and use of Personal Data, the requirements for consent will differ across regions. We may request your consent for a number of activities including:
We may ask for your consent to contact you by email or push notifications in the application about events or services that we think may be of interest to you and for other marketing purposes.
2. Sharing with Third Party Services.
We may also ask for your consent to share your Personal Data with certain Third Party business partners in order to offer certain goods, services, or programs. To withdraw consent, please go to the preferences of the specific third party service or app.
3. Third Party Marketing.
We may ask for your consent to provide Personal Data to allow third parties to contact you regarding their products, services, Promotions, or offers. Typically this is in conjunction with a sweepstakes or challenge (your consent for third party marketing is generally not a pre-requisite to participation. To withdraw consent, please go to the preferences of the specific third party
4. Collecting Mobile Device IDs, Advertising IDs, and Data from Sensors.
When you use our mobile app we may ask for your consent to collect these (this consent may be captured at the operating system level). If you choose not to provide this information, certain Services features may be unavailable or not function properly.
5. Processing Sensitive Personal Data.
We may request your consent to process sensitive Personal Data such as health relating data:
– Status: currently in treatment / finalised treatment
– Year of diagnosis/ year of finishing treatment
6. Collecting and Sharing Location Data.
We may request your consent to collect your precise Location Data. Our Services may require this data to provide the Services. If you choose not to provide this information, certain Services features may be unavailable or not function properly. Location Data may be used to display your live location.
In addition, we may request your consent to share your precise Location Data with Third Parties for on and off platform personalization and curated marketing and advertising purposes.
We may request your consent to use your Personal Data for Research purposes. We may also request your consent to contact you to determine your interest to participate in certain Research initiatives and to share identifying results. For market research, we may ask questions on behalf of business partners and share your response with business partners.
9. Automated Processing.
We may use some automated processing to provide our Services and to make recommendations in the context of specific services. This processing is strictly necessary for providing certain Services (and, in some cases, is the service itself) and is not covered by consent. Other automated processing is not significant either due to the nature of the data or the decisions being made or recommended, and so consent is not required. However, for automated processing that is significant and related to sensitive Personal Data, prior to sharing or using such data, we will first seek your consent.
10. To Enable Social Sharing and Connect with Us on Social Media.
Some of our services consist of social sharing and communication with others. If you sign up for these services, we may ask for your consent to use your information to enable sharing as described in the service.
We may also ask for your consent when you connect with us through Social Media.
We may ask you for permission to use your Personal Data for, events, and other Promotions. We may use the Personal Data we collect during Promotions, to administer the Promotion, verify identity and age, and to communicate with you about the Promotion.
You may withdraw your consent by sending an e-mail to the address firstname.lastname@example.org or in any other form that will be specified at the time you give your consent.
2. HOW WE USE YOUR INFORMATION
- help you efficiently access your information and user account after you sign in;
- remember information so you will not have to re-enter it during your visit or the next time you visit the Service;
- provide personalized content and information to you and others;
- provide, improve, test, and monitor the effectiveness of our Service;
- develop and test new products and features;
- monitor metrics such as total number of visitors, traffic, and demographic patterns, including but not limited to the reason(s) particular Users choose to access the service, the information they seek to obtain by using the Service, and the nature of any health conditions or concerns for which they may be accessing the Service. Any medical information that might be personally identified to a user will not be shared with third parties as stated herein;
- diagnose or fix technology problems; and
- automatically update the VIA Together App application on your device.
- Communications and newsletter activities, to contact you with messages, emails, and newsletters. These include push notifications and in-app messages, informational content about health delivered to you via email, as well as occasional promotional materials that may be of interest to you.
3. YOUR RIGHTS IN RELATION TO PERSONAL DATA PROCESSING
Subject to certain legal conditions, you have the following rights in relation to the processing of your personal data:
- The right to request a copy of your personal data which we hold. Upon your request, this information will be provided to you electronically;
- The right to the rectification of any inaccurate or incomplete personal data;
- The right to object to or restrict our use of your personal data;
- The right to withdraw your consent for the processing of personal data based on the consent;
- The right to the erasure of your personal data, when you withdrew your consent, the processing is no longer necessary, or such processing is unlawful;
- The right to data portability which allows you to receive a copy of the processed data which we received from you or to share them with another entity nominated by you;
- The right to withdraw your consent for the consent-based processing. Withdrawal of consent shall not affect the lawfulness of processing based on consent before consent withdrawal. If you withdraw your consent, we will no longer process your personal data and shall take the necessary measures to erase your personal data. We may however process your personal data if there is another legal basis for such processing.
- The right to lodge a complaint if you believe we are processing your personal data under violation of applicable data protection regulations. with the Romanian supervisory authority: The National Supervisory Authority for Personal Data Processing, headquartered in 28-30 Gheorghe Magheru Blvd., Bucharest, Romania
If you wish to exercise the rights detailed above, please contact us using contact details found in section 9 of this document.
3. SHARING OF YOUR INFORMATION
Your health-related information is privileged and confidential and will not be shared or released to any organization or business entity outside The Little People Association Romania without your consent, except as noted in this Policy.
Parties with whom we may share your information:
- We may share demographic information, or other de-identified information in the aggregate to other persons or entities who, in our discretion, may benefit from using the Service, or who may be interested in using or licensing the Service. No identifying information will be shared with such persons or entities, only aggregate information designed to demonstrate what types of persons are using the Service and for what purposes.
- We may share information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Service to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
- We may remove parts of data that can identify you and share anonymized data with other parties as stated in this policy. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.
Parties with whom you may choose to share your User Content:
- If you choose, you can use various features within the Service or Application to locate other people with VIA Together App accounts through various searches and connections. If you choose to make connections, information within your user profile may be shared with them. Any other User Content or other personal information you may elect to share with them is within your discretion.
What happens in the event of a change of control:
Responding to legal requests and preventing harm:
- We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
4. HOW WE STORE YOUR INFORMATION
Storage and Processing:
- We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, the VIA Together App cannot ensure the security of any information you transmit to the VIA Together App or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. You are solely responsible for keeping your information safe and protecting any information you may desire to keep private.
- Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your account any information you may choose to share within the Service, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.
5. YOUR CHOICES ABOUT YOUR INFORMATION
Your account information and profile/privacy settings:
- Update your account at any time by logging in and changing your profile settings.
- You may choose to unsubscribe from the Service or from email communications from us. As noted above, you may not opt out of Service-related communications (e.g., account verification, changes/updates to features of the Service, technical and security notices). If you desire to unsubscribe, please contact us or take any other steps that may be requested through the Service or the Application.
How long we keep your User Content:
6. CHILDREN’S PRIVACY
7. OTHER SERVICES AND USERS
8. HOW TO CONTACT US ABOUT A DECEASED USER
In the event of the death of a VIA Together App User, please contact us. We will usually conduct our communication via email; should we require any other information, we will contact you at the email address you have provided in your request.
9. HOW TO CONTACT US
The Little People Association Romania
Cluj-Napoca, România, Calea Mănăștur nr. 42B. 400372
To protect your privacy and security, we will take reasonable steps to verify your identity before providing information or making corrections.
Should you have any concerns regarding the privacy of your medical information, we encourage you to cease using the Service and to terminate your account. If you believe that your privacy rights have been violated, we encourage you to contact us to discuss the matter.