Iryo Moshi - Privacy policy

As used in this Privacy Policy, “Iryo”, “We”, “Us” or “Our”, refers to Iryo, medicinske rešitve, d.o.o., Ljubljanska cesta 24D, 4000 Kranj, Slovenia.

This Privacy Policy is part of and incorporated by reference into the Terms of Service (the “Terms”) governing the use of all “Iryo” branded software applications (the “Application/s”, or “ App/s”), which may operate on any type of computing device (including without limitation, a mobile device), and applies to your use of the Applications and/or iryo.io, and/or URL which may replace it or which may be added to the list of websites published by us and linking to this Privacy Policy (the “Website/s”).

By agreeing to the Terms and/or using the Websites or the Applications, you particularly agree to the collection, use and disclosure of your information (including personal information) in accordance with this Privacy Policy. We may collect and/or you may be asked to provide us with your information (including personal information) any time you are in contact with us or use the Applications or the Websites.

We take the privacy of our users and data security very seriously and believe in the right of our users to know which data is collected and for what purpose. We therefore strive to make our actions transparent and allow our users to control the collected data and remove it if they so wish, and we take all reasonable precautions to prevent unauthorised access to this data.

We value your privacy and will never sell your information to anyone without your knowledge and consent.

When accessing to our website and/or using any of our Apps you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Irrespective of which country you are based in, you authorise Iryo to use your information in, and as a result to transfer it to and store it in Slovenia and any other country where Iryo, or any third party service providers acting on its behalf, operates. Privacy and data protection laws in some of these countries may vary from the laws in the country where you are based, but we will always take appropriate steps to safeguard the privacy of your personal information.

Only when the transfer is based on one of the following safeguards, we will transfer your personal information:

If a country outside of EEA ensures an adequate level of protection in accordance with EEA data protection legislation.
If we have entered into standard contractual clauses with our contractual partner that are adopted by Commission of European Union in accordance with EEA data protection legislation and are deemed to offer sufficient safeguards with respect to the protection of the privacy rights.

Please read this Privacy Policy in order to learn more about the data we collect, what do we use it for and how we protect your privacy.

Collected information

We may collect any or all of the information that you give us together with data about your use of the website and applications, but we will primarily use the collected data to provide you with a satisfactory service and enhance your Iryo experience. We use information for (i) delivering and improving our services and products, providing updates, technical troubleshooting, understanding and analysing trends in connection with usage of the apps, and administering the apps; (ii) analytics and research in a way that we use your information for understanding and analysing trends in connection with usage of the apps, gathering demographic information about user base, data about where download of our app was performed, and we might use created reports and analysis for the purpose of business intelligence; (iii) security in a way to use your data for enhancing the safety and security of our products and services; (iv) providing customer support to you and to respond to your inquiries; and (v) our legal obligation when we are required to do so by law.

We use different SDKs from our business partners and they share collected information with us. For detailed information, see Analytics section below.

Collection of device and technical information

We might collect the data necessary for you to use our app and for us to maintain and analyse the functioning of the app and to personalise the content of the app.

We automatically obtain certain information about your computing device. We also obtain information about your account; technical device information (e.g. device model and name, operating system name and version, unique device identifier (IMEI), advertising ID, MAC address). Although some of this information may uniquely identify your device, this information does not identify you personally. Some legislation may treat information that uniquely identifies your device as personal information.

Collection of classical personal information

We may also collect personally identifiable information about you (such as your name and surname, email address, birth year, and password), as well as non-personally identifiable information (such as age range and gender) that you provide us by contacting us directly. We might also collect the messages You sent to Us.

We will only use the contact information you provide to us (for example, your name and email address) for the purpose for which you provided it to us. We will not share this data with third parties.

If you wish to delete your contact information that we received upon your specific email inquiry, please send an e-mail to support@iryo.io and your e-mail will be deleted from our database.

What is collected data used for

Our use of information collected from you

We use the information collected from you for delivering our services, internal analysis and research to improve the services. You hereby allow us to collect, process and store the data as stated in this Privacy Policy. We use the information we collect about you/your computing device to deliver services to you and to operate our business. Such use by us and by our Partners may include:

Delivering our services: developing, delivering and improving our products, services, and content, tailoring our products and services, providing software updates and product support, understanding and analysing trends in connection with usage of the Applications and the Websites, administering the Applications and the Websites, and customer communications, develop and improve the App and user experience, manage our relationship with you, provide social features as part of the App, customise your App experience, respond to your comments and questions, provide you our offers in the App as well as in other websites and services, and by email, send you related information, such as updates, security alerts, and support messages, enable you to communicate with other users of the App, create accounts and allow you to use the App, to operate, maintain and provide all the features and services found on the App now and in the future, send you App-related communications, to provide support and to help you solve any technical difficulties.
Analytics and research: Understanding and analysing trends in connection with the usage of the Applications and the Website, auditing, learning about user behaviour within the Applications and the Websites (how often you use the Application/Website, the events that occur within the Application/Website, aggregated usage, performance data etc.), gathering demographic information about our user base, data about where the Application was downloaded from. For information that can be treated as personal information in some legislation, we use only device identifiers. We use the data we receive from Third Party Social Network for internal analytics.
Push Notifications: We use push notifications to remind you about your activities within the App. You will receive push notifications only if you are subscribed to push notifications in the App. You can always unsubscribe from push notifications, please use the instructions provided below.

For iOS: You will be asked to accept or refuse push notifications after an Application is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, some mobile phones will allow you to disable push notifications later on by using the settings on your mobile phone. To manage push notifications on your mobile phone please follow these instructions: Open your Settings menu and tap “Notifications”; Find the App; Tap on the icon of App; Manage the “Notifications” option by sliding it OFF or ON.

For Android: After an App is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the “info screen” on the homepage of the App and choosing the “Settings” option. Here, push notifications can be disabled by unchecking the “Notification” option within the App.

When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database.

Storing of information

We store your information for as long as needed to provide you with our services and for as long as we are legally obliged to do so. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need them for providing our services and in any event no later than five (5) years after your interaction with our products has ceased.

We store personal information as long as it is needed for the provision of our services. Traffic information is erased or made anonymous when it is no longer needed for the purpose of the transmission or, in the case of payable services, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Location information is stored to the extent and for the duration necessary for the provision of a value-added service. Other information is stored for as long as we consider it to be necessary for the provision of our services. This section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary in order for us to provide the service you requested.

Deletion of information

When information is no longer needed, we shall delete it using reasonable measures to protect the information from unauthorised access or use.

Protection of personal information

We have implemented: reasonable security measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorised access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

Sharing your personal information

The medical facility using Our software

The App you downloaded and installed on your device is not useful without your medical facility using it. You only connect with your medical facility and provide your personal information to them, in no case to any other medical facilities without Your consent. Medical facility might provide you with question forms about your medical information. Before connecting with such medical facility within Our App, you will have to agree with their Privacy Policies and Terms of use. We concluded with Data processing agreements with every medical facility using our App and we operate as data processor and we process your information in accordance with our agreements with them.

Partners working for us

We have partners who perform services on our behalf, such as data storage, technical or customer support and data analytics. Processors are contractually required or bound by law to protect your data and are only permitted to process such data in accordance with our agreements with them.

We use the following services in relation to your personal information:

Microsoft Azure: https://azure.microsoft.com/en-us/
Amazon Web Services: https://aws.amazon.com
Google Cloud: https://cloud.google.com
Magic Bell: https://www.magicbell.com
Sentry: http://www.sentry.io

Other companies and public authorities

Based on your consent or if so required by law we may supply or disclose your data, including personal information to third parties.

We cannot provide all services necessary for the successful operation of our products by ourselves. We must therefore share collected information with third parties (collectively referred to as “Partners”). The only personal information we collect from users for the purposes of offering our services are persistent identifiers (such as device ID, IDFA, IDFV, advertising ID, IP address). Such persistent identifiers are used and shared with third parties only to place contextual advertisement (including frequency capping, fraud prevention and tracking for the attribution and billing purposes), to authenticate users of or personalise the content on Apps, to maintain or analyse the functioning of the Apps, personalise the content of the App (such as sending push notifications), to perform network communications to protect the security or integrity of the user or the App, to ensure legal or regulatory compliance.

Integrity of personal information

We strive to enable you to keep your information accurate, complete and up to date. You can access, check and ensure the integrity of your information as described below.

Information collection relating to children

We consider ourselves to be oriented towards general public and even though our products and services are not directed to, and we do not knowingly collect personal information from, children under the age of digital consent according to EEA data protection legislation, with the sole exception persistent identifiers as described herein. If we learn that we have collected personal information of a child under the age of digital consent according to EEA data protection legislation, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at support@iryo.io.

Opt-out

You are always free to opt out from the future collection of your personal information by Iryo in accordance with this Privacy Policy by uninstalling all the Applications from each of your computing devices and discontinuing use of the Websites.

Third Parties terms of service

We may provide links and/or connections to third-party websites or services from our website and our mobile applications. We are not responsible for the practices employed by websites or services linked to or from Iryo website or applications, including the information or content contained therein.

Please remember that when you use a link to go from the Iryo website iryo.io or applications to another website or service, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those linked on our website or in our applications, are subject to that third party’s own rules and policies. We are not responsible for the privacy practices or content of these third-party sites.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (i) we have your consent to do so, (ii) where we need the personal information to perform a contract with you (e.g. to deliver a service you have requested), or (iii) where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

Support

If you have further questions or any concerns regarding privacy with Iryo, the best way to get the answers is to contact us by email at support@iryo.io If you submit a support request, we may receive your email address and other information you provide related to your support request (“Support Information”). We use Support Information only to provide support to you. We don’t rent, sell or share your email address unless we have your express consent and in the following circumstances:

We may share your Support Information with our support providers, but only for the purpose of providing support to you.
We may share your email address and Support Information to enforce compliance with our mobile application license agreements and user agreements, to respond to legal requirements, when legally required to do so, and at the request of governmental authorities.
We may share your email address and Support Information with a successor entity or in connection with a corporate merger, consolidation, sale of assets or other corporate reorganization provided that use of your email address is otherwise in compliance with this Privacy Policy.

Your data protection rights

You have the following data protection rights:

To access, correct, update or request deletion of your personal information. You may do so by contacting us at support@iryo.io
To object to the processing of your personal information ask us to restrict processing of your personal information or request portability of your personal information. You may do so by contacting us at support@iryo.io
If we are processing your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted pursuant to lawful processing grounds other than consent. You may do so by contacting us using the details at support@iryo.io.
You have the right to file a complaint with a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

You can control and limit the type of personal information we collect and process about you in a number of ways. You can reset your mobile advertising identifier or limit ad tracking altogether using the settings on your phone. You can also limit or disable the use of cookies (or similar technologies).

We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Any changes will be placed here and the amended version will supersede this version of our Privacy Policy. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected. We will take reasonable steps to draw your attention to any changes in our Privacy Policy. However, to be on the safe side, we suggest that you read this document each time you use the website to ensure that it still meets with your approval.

If we make changes in the way we use your email address, we will notify you in advance of posting by email. Such modifications will become effective on the date set forth in the email.

English language

By accepting this Privacy Policy you acknowledge that you are proficient in the English language, or have consulted with an advisor who is sufficiently proficient in English, so as to allow you to understand the terms of this Privacy Policy.

Privacy questions

For general information please feel free to contact us via contacts provided on www.iryo.io and for privacy question via support@iryo.io.