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VIV™ Privacy Policy1. VIV's COMMITMENT TO PRIVACYAt VIV, protecting your data is a task we take seriously. Our products are designed to help you track important aspects of your health, like your daily habits, health, and sleep quality.This Privacy Policy (“Policy”) is designed to provide you with the information you need to take control of your data, which is a fundamental aspect of empowering your health journey.2. ABOUT THIS PRIVACY POLICYThis Policy applies to the processing of personal data by VIV Health Inc. and its subsidiaries (collectively, "VIV") when you visit our web properties (“Sites”); use the VIV Ring with the VIV App, VIV on the Web, or use other VIV services (“Services”). The sections below explain the categories of personal data we collect and process and the reasons we do so. You will also find information on our legal basis for processing your data and our data sources.A. DEVICE & APPLICATION USERS1)PROCESSING PURPOSESWhen you use VIV Services, we collect and process your data for the following purposes:To Provide VIV ServicesWe process personal data when you use our Services to provide personalized insights about your readiness, sleep, activity, and other inferences about your health status.To Provide Customer ServiceWe process personal data to provide customer service and manage our customer communication. For example, if you contact our virtual assistant with questions regarding your account, we may use the provided information to answer your questions and solve any issues you may have.To Protect Your PrivacyWe may process personal data regarding the use of your services to protect your privacy. This may involve using privacy-enhancing technologies and other privacy-protective techniques. When information is aggregated or anonymized, it is no longer personal data.To Improve Our ServicesWe process personal data regarding your use of our Services to understand how you use them and how we can improve them. For example, we may process personal data to improve your user experience in the VIV App or to develop cutting-edge features to provide you with new insights about your health. When feasible, we do this using data that has been processed to protect your privacy, such as by pseudonymization.To Perform AnalysisWe may process personal data about human performance and well-being to benefit our users and improve the cutting-edge insights we provide with our Services. Some features of our Services may use third-party automated technology to provide a more personalized experience and give you comprehensive insights about your data. For example, our Services include intelligent features that may use the responses you provide to better personalize the Services. When feasible, we do this using data that has been processed to protect your privacy.To Market ServicesWe process marketing-related personal data to provide online advertising and other marketing communications for VIV and our partners. For example, as explained more fully in our Cookie Policy, we use cookies and similar technologies on our website to create audiences for online advertisement. You can opt out of direct marketing communications from VIV.To Enable Third-party Integrations and ServicesWe process your data to VIV to enable third-party integrations, services, features, and offerings. For example, with your permission, our Services may integrate with third-party services like Google Health Connect, Apple HealthKit, or our partners. VIV takes measures to help ensure third-party services protect your data, which means that VIV only processes your data concerning third-party integrations when you integrate them with our Services or provide the necessary consent. We process the data we receive from these third parties according to applicable terms, such as the Google Health Connect, Apple HealthKit Permissions policy, Google Limited Use requirements, and relevant third-party developer license agreements, as we become aware of those policies and agreements.To Comply with Legal ObligationsIn certain cases, we must process certain data when required by applicable laws and regulations. Such statutory obligations relate, for example, to accounting and tax requirements, legal claims, or other legal purposes. VIV will oppose any request to provide legal authorities access to user data for surveillance or prosecution purposes. We will notify users if we receive any such request whenever legally permissible.2. LEGAL BASIS FOR PROCESSINGData protection law in Europe and the U.K. requires a "lawful basis" for collecting and retaining personal information from residents of the European Economic Area. Our lawful bases for processing your data depend on the particular processing purposes, including:3.ConsentWe process your sensitive personal data only with your consent. In some cases, you can provide your consent to us for processing your data through your actions, such as by adding sensitive personal data into your notes or by adding health-related tags in the VIV App.4.Legitimate InterestWe process your personal data based on our legitimate interests when we use it to market our Services and Sites, provide customer service, and improve our Services. When choosing to use your personal data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy in compliance with applicable law.5.Legal ObligationVIV must process certain information to comply with statutory obligations, which may vary in each country. Such obligations can relate to consumer protection or tax laws.6.PROCESSED DATA AND DATA SOURCEIn most cases, VIV collects personal data directly from you, such as when you register for an account, tag your data in the VIV mobile or web app, or use your VIV Ring. We may also process the data produced from the information you provide to us. VIV may also rely on trusted third-party processors, such as our cloud service providers, to process data on our behalf.VIV processes the following personal data categories when you use our Services:Contact information such as email address or physical address.User information such as gender, height and weight, User ID, and other information you may provide about yourself or your account.Device information such as IP address and location data.User-provided activity and contextual information include the activities, notes, comments, user feedback, and tags you provide within the app.Measured data such as heart rate, heart rate variability, stress, activities, movement, temperature, and respiration data.Calculated user, sleep, health, and activity data such as sleep phases (deep, light, REM, awake), activity levels throughout the day, readiness level.Please note that some of the personal data we process, including any data concerning your health, is considered special or sensitive personal data. Under applicable law, such data is processed only if you consent to process it. Suppose you access or use any of VIV's location-based services, such as enabling GPS-based activity tracking through our Services. In that case, VIV may process your device's approximate or precise location while the service is active. This data may be obtained via your device's service provider network ID, GPS, and Wi-Fi data. VIV does not process such location data without first obtaining your consent. You may disable such location processing using your device's location permission settings. If you choose to disable access to location data, please note that certain Services, features, or functionalities may no longer be accessible.Please also note that if you give opt-in consent through our Services, you may share limited personal information like your current and past sleep and readiness scores with other VIV users. The information you choose to share may be shared with other VIV users in the circle(s) you join and with any additional VIV users who are added to those circles. You can change the data you share with other VIV users, including opting out of sharing any data. Depending on your use of our Services, you may also choose to communicate with and react to other users' information and scores. Always maintain a respectful and supportive environment when communicating with other users.7. Contact details:"Your privacy is very important to us. If you have any questions or concerns, please feel free to reach out to us using the contact information below."Contact Details: viv@vivring.aiVIV Health Inc.