Privacy Policy

In connection with your use of the www.facerehab.com platform, we ask that you read these Privacy policy (hereinafter referred to as „Policy“).

When processing personal data, we are governed by Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the “GDPR”) and Act No.18/2018 Coll. on the protection of personal data and on amending and supplementing certain acts, as amended (hereinafter referred to as the “Personal Data Protection Act”).

Protecting the personal information you entrust to us is important to us and we do everything we can to make you feel safe with us. The purpose of this Policy is to explain how the personal information you provide to us when using our websites www.facerehab.com, app.facerehab.eu (hereinafter referred to as „web side“), as well as through the mobile application “FaceRehab”, FaceRehab: Therapies World (hereinafter referred to as apps) is used.

Web side and apps are owned and operated by INOVUJ, s.r.o., registered office Berlínska 11, 040 13 Košice – Sídlisko Ťahanovce, ID No.: 52 321 444, which makes this platform available solely for the purpose of facilitating communication between experts and consumers who choose to use the online service.

BY USING THE WEB SIDE AND APPS, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD AND AGREED TO THIS PRIVACY POLICY. If you do not agree or are unable to make this promise, you may not use the Platforms. In that case, you must (a) delete your account or contact us to request deletion of your information; (b) cancel any subscriptions using the features provided by Apple (if you are using iOS) or Google (if you are using Android); and (c) remove the app from your devices.

1. Who we are and how to contact us?

Operator:

Business name:                       INOVUJ, s.r.o.    

Legal form:                               Limited liability company

Registered office:                    Berlínska 11, 040 13 Košice – mestská časť Sídlisko Ťahanovce

ID:                                              52 321 444                   

VAT:                                           2121001344

VAT ID:                                      SK2121001344

Registered in:                           Commercial Register of the Municipal Court of Košice, Section: Sro,

Entry Number: 46157/V

(hereinafter referred to as “INOVUJ s.r.o.” or “we”)

If you need to contact us, you can do so via email:  info@facerehab.eu. We will get back to you as soon as possible.

2. Terms we use in this privacy statement.

1. These Policy are a binding legal agreement between you and INOVUJ, s.r.o. (“INOVUJ, s.r.o.”, “we”, “us” or “our”).

• „Consultation“ refers to an online appointment – a service that takes place between a customer and an expert via a platform. The platform is an online place that connects clients with experts. Experts are not employees of the Operator.  The Operator does not engage in Client-Expert consultations and is not responsible for the content of Client-Expert consultations. 

• „Client“ „you“ and „your“ refer to the person ordering the consultation service on the Platform.  All references to “you” or “your”, as applicable, mean the person accessing, using and/or participating in the Platform in any way.

•  „Expert“ refers to a person who provides facial health as well as healthy lifestyle consultations for a Client on the Platform. Client and Expert are together “users”. The rights and obligations of an Expert are governed by a separate Business Collaboration Agreement, these Terms govern your use of the Platform.

• „Platform“ – The platform www.facerehab.com serves as a consultation service and the experts only provide recommendations which the client is not obliged to follow (hereinafter referred to as the „Platform“). The advice is based on information obtained by describing the client’s health condition. The Platform is in no way a healthcare provider. Securing the privacy of clients’ data is our priority. All processes are GDPR compliant. Information through consultations is not intended for critical situations or cases where medical emergencies need to be sought. In case of need for medical assistance, treatment or diagnosis, the Client is obliged to contact his/her doctor or healthcare provider.

2. We may unilaterally change or amend the wording of the Privacy policy at any time. The new version of the Privacy policy is effective on the 15th day after it is published on the Platform. We will inform you of such change via an informational email, the Platform or when you log into your client account.

3. What type of personal data do we collect?

The information collection and use

We collect several different types of information for various purposes, including, but not limited to, to provide and improve our app, to personalize our app for you and to communicate with you.

Types of data collected:

• personal data – while using the app, we may ask you to provide us with certain personally identifiable information that can be used to contact you, identify you and increase accuracy of the information we provide to you (“personal data”). personally identifiable information may include, but is not limited to:
  • general information: email address, name and surname, ZIP code;
  • information relating to your face that you provide to us through your account, including but not limited to:
    • whether you have been diagnosed with Bell’s Palsy or Temporomadibular Joint Disorder and how long you have suffered from it;
    • information about your symptoms
  • to enable you to use all the features of the application, we process data obtained from your device (with iOS system and TrueDepth camera) through TrueDepth API (ARKit Framework) technologies, which provide us with information about the position and orientation of the human face.

• usage data – we may also collect information on how the app is accessed and used (“usage data”). This usage data may include information such as your phone’s hardware model, mobile network information, unique device identifiers, ip address, time zone, the pages of our app that you visit, the time and date of your visit, the time spent on those pages, engagement with particular features and other diagnostic data.

• tracking & cookies data – we use cookies and similar tracking technologies to track the activity, performance and analytics and important functionality on our app and to hold certain information.
  • cookies: from time to time, we may use “cookies” to keep track of your visit and use of the app. a cookie is a small piece of data that your browser stores on your computer’s hard drive and is used to collect information, such as identifying those areas of the app that you have used in the past in order to enhance your next visit to the app. you can choose whether to accept cookies by changing the settings on your cellular device. each browser is a little different, so look at your help menu to learn the correct way to modify your cookies.

• personal data that we obtain from other sources.
  • We do not collect only data that you provide to us directly. We may also collect information about you from other sources. When processing a payment through Stripe, a payment system that supports online card payments, payment details are shared so we can process your service booking and ensure everything goes as it should. We encourage you to click on the following links to read more about how Stripe uses this data collected: https://stripe.com/en-sk/privacy

4. For what purposes do we process your personal data?

Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date. we will only retain personal information for as long as necessary for the fulfilment of those purposes.

We use the collected data for various purposes, including, but not limited to:

• to provide and maintain the app;
• to notify you about changes to our app;
• to allow you to participate in interactive features of our app when you choose to do so;
• to provide customer care and support;
• to provide analysis or valuable information so that we can improve the app;
• to monitor the usage of the app;
• to detect, prevent and address technical issues;
• to improve and develop new features of the app, including artificial intelligence and machine learning.

5. How do we store your personal data?

We store the information and personal data you share with us on “cloud” servers owned and operated by third party providers. Our current provider is Google LLC. Our app is designed to encrypt all stored data using encryption algorithms. For information about amazon web service’s privacy protection and data security practices, please visit https://cloud.google.com/terms/cloud-privacy-notice

6. How does INOVUJ share your data with third parties?

Advertising purposes – we allow our advertising and affiliate partners access to information by placing cookies or our app.

Corporate reorganization – in the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction and such information would be part of the assets sold. We would share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.

To prevent harm – we will share information if we believe it is necessary to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights or personal safety of any person.

Legal purposes – we will share information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; or to comply with the requirements of any applicable law.

With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time by writing us at info@facerehab.eu.

Aggregate Information – We may share aggregate, anonymized or de-identified information that cannot reasonably be used to identify you with our partners or research institutions. For example, we may share, among other things, in articles, blog posts and scientific publications, general demographic information about age and summary statistics about certain activities or symptoms from the data we collect to help identify patterns across users. Sharing such data helps advance scientific research in the field of facial health and further develops the artificial intelligence needed to improve the application.

Transfer of data

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the European Union and choose to provide information to us, please note that we transfer the data, including personal data, to the  European Union and process it there. By using the app, you consent to such collection, storage and processing in the European Union, though the European Union and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your personal data. 

Security of data – the security of your data is important to us but remember that no method of transmission over the internet or electronic storage can be guaranteed as entirely secure. While we strive to use reasonable means to protect your personal data, we cannot guarantee its absolute security. It is imperative to recognize that there always exists a certain level of risk wherein an unauthorized third party might circumvent our security systems.

Service providers – we may employ third party companies and individuals to facilitate, administer, operate, host, configure, design, maintain and provide internal support for our app (“service providers”), to or to assist us in analyzing how our app is used.

These third parties have access to your personal data only to perform these tasks on our behalf and are contractually obligated not to disclose or use it for any other purpose.

Links to other apps – our app may contain links to other apps that are not operated by us. If you click on a third-party link, you will be directed to that third party’s app. We strongly advise you to review the privacy policy of every app you visit to understand how that third party collects and uses your information. You should be aware that any information you disclose to these third parties once you access these third party apps or websites is not subject to this privacy policy.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party apps, websites or services. Our app does not endorse and is not responsible for the privacy practices of these third parties.

Young users – we are committed to protecting the privacy of children. our app is not intended or designed to attract anyone under the age of 16 (“children”).

We do not knowingly collect personally identifiable information from anyone under the age of 16, if you are a parent or guardian and you are aware that your children has provided us with personal data, please contact us at info@facerehab.eu. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

Opt-out – you may choose to prevent us from disclosing or using your personal data under certain circumstances („opt out“).  You may opt out of any disclosure or use of your personal data for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by e-mailing us at info@facerehab.eu. or by following the procedures set forth in an electronic communication from us, if applicable.  Furthermore, even where your personal data is to be disclosed and used in accordance with the stated purposes in this privacy notice, you may elect to opt out of such disclosure to and use by a third party that is not acting as our agent.  There are some uses from which you cannot opt out, such as to provide products, features or services that you have requested from us.

Please note that making such requests does not ensure complete or comprehensive removal of the content. For example, we may retain your de-identified information indefinitely. Simply contact us to exercise any of your privacy rights. We may engage you to better understand the motivation the content and motivation of any request. 

Changes to this privacy policy – we reserve the right to change or replace this privacy policy at any time and from time to time. We will state the date this privacy policy was last updated. We encourage you to review our privacy policy on a regular basis. If you do not accept the terms of this privacy policy, we ask that you do not register with us and that you exit the app immediately.

Governing law – these terms and conditions are governed by and construed in accordance with the laws of Slovak republic, and you irrevocably submit to the exclusive jurisdiction of the courts in that state.

7. How long do we keep the data?

We process your personal data in accordance with legal requirements, which means that we do not keep personal data for longer than is necessary for the purpose of the processing.

If we process your personal data on a legal basis – your consent, we process the personal data for the period for which you have given us consent to process your personal data or for as long as necessary for the relevant processing purpose.

8. What are your rights when processing personal data?

There are a number of rights you can exercise in relation to the personal data we process about you.

a) Right of access to personal data

You have the right to access and obtain a copy of your personal data. If we process your personal data, we will provide you with information about what data we process about you, for what purpose, to whom we have provided your personal data, whether it has been transferred to a third country and how long we will keep the data. If you request a copy by electronic means, we will provide you with the information in a commonly used electronic format unless you request otherwise.

b) Right to rectification of personal data

If your personal data is incorrect, you have the right to have it corrected. If it is incomplete, you have the right to have it completed. You can correct or complete your personal data in your Profile settings, or you can ask us to correct it.

c) Right to restrict the processing of personal data

You have the right to restrict processing in the cases specified by the Personal Data Protection Act, for example until they are corrected (or verified as correct) or if the processing of your personal data is unlawful and you request a restriction of use instead of erasure, or if we no longer need the personal data for the purpose of processing it but you need it to assert a legal claim.

d) Right to erasure of personal data (to be forgotten)

You have the right to erasure of data in the cases determined by the Data Protection Act, unless this right is restricted by law. The right to erasure applies, for example, if your personal data is no longer necessary for the purposes for which it was collected or if you withdraw your consent to the processing of your personal data and there is no other legal basis for processing it.

e) Right to data portability

If we process data on the basis of your consent or a contract and the processing of your personal data is carried out by automated means, you have the right to data portability (the right to obtain the data in a structured, commonly used, machine-readable format and the right to transfer it to another controller).

f) Right to withdraw your consent

If we process your personal data on the basis of your consent, you have the right to withdraw your consent to the processing of your personal data at any time.

g) Right to bring a data protection action

If you feel that your rights have been affected, you may file a petition with the Office for Personal Data Protection of the Slovak Republic for a data protection proceeding pursuant to § 100 et seq. of the Personal Data Protection Act.

h) Right to object to the processing of personal data

Pursuant to Section 27(3) of the Data Protection Act, we expressly draw your attention to the right to object to the processing of personal data concerning you (i) on grounds relating to your particular situation carried out pursuant to Section 13(1)(e) (processing of personal data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller), or (ii) on grounds relating to your particular situation carried out pursuant to Section 13(1)(e) (processing of personal data is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller), or (iii). (f) (processing of personal data is necessary for the purpose of the legitimate interests of the controller or of a third party) of the OU Protection Act, including profiling based on these provisions, and (ii) for the purpose of direct marketing, including profiling to the extent that it is related to direct marketing.

With respect to the purpose of the processing of personal data, we will inform you in more detail of your rights in relation to such processing.

With regard to the purpose of the processing of personal data, we will inform you in more detail about your rights in relation to such processing.

Acceptance of these terms

By creating a profile or signing up to use the app, you explicitly consent that:

i. We may store and process your personal data you provide through the usage of the app and through the account creation solely for the purposes indicated in this privacy policy. Such purposes may include sending you information and reminders through the app or to the email address.

ii. We will not transmit any of your personal data to third parties unless otherwise is provided by this privacy policy.

Contact us

If you have any questions about this privacy policy, the practices of this app, or wish to exercise your rights related to your personal data, please contact us at email: info@facerehab.eu

The address at which the consumer can make a claim, complaint or other complaint:

INOVUJ, Ltd.      

Berlínska 11, 040 13 Košice – Sídlisko Ťahanovce

Supervisory authority: Slovak Trade Inspection Authority (SOI)

SOI Inspectorate for the Bratislava Region

Prievozská 32, 820 07 Bratislava

P.O. Box: 5

Supervision Department

tel. 02/58 27 21 72, 02/58 27 21 04,

fax no. 02/58 27 21 70

http://www.soi.sk,

http://www.soi.sk/sk/Podavanie-podnetov-staznosti-navrhov-a-ziadosti.soi

Effective date: 01.11.2023