Last Updated: June 18, 2024
This Privacy Notice describes how Kynisca UK and Kynisca Innovation Hub (collectively, “we”, “us,” “our”) collects, uses, and discloses information about individuals who use our website, software, mobile application, services, tools and features, or otherwise interact with us (collectively, the “Services”). For the purposes of this Privacy Notice, “you” and “your” means you as the user of the Services, whether you are a registered user or visitor of our application, customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Notice. Please note that the Services are designed for users in the United States, United Kingdom, Canada, New Zealand, Australia, South Africa and the European Union only and are not intended for users located outside these regions.
Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Services.
We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.
Data Processing Transparency
We require explicit, informed consent for the collection and processing of personal data. Users can manage their consent preferences through their account settings at any time. Our End User License Agreement(EULA) includes detailed information on how consent is obtained and how users can withdraw their consent.
We process personal data only for the purposes explicitly stated at the time of collection. This includes providing and improving our services, communicating with users, and complying with legal obligations. We rely on the legal basis of our user consent, contract performance, and legitimate interest for processing personal data. When you use or access the Services, we collect certain categories of information about you from a variety of sources.
Information You Provide to Us
Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:
Personalization and User Insights
Logs for Wellness, Sleep Data, Exercise Data: These categories track activity levels, sleep patterns, and work out details. By analyzing this information, the app can provide users with:
Menstrual Cycle Data: This data can be used to:
De-identified Health Research
Physiology, Injuries, Soreness, Physical Activity, Wellness Data: This comprehensive data set, once de-identified, can be incredibly valuable for researchers in various fields like:
We also automatically collect certain information about your interaction with the Services (“Usage Data”). Usage Data includes:
We use Usage Data to tailor features and content to you, market to you, provide you with offers or promotions, run analytics, and better understand user interaction with the Services. For more information on how we use Tracking Technologies and your choices, see the section below, SDKs and Other Tracking Technologies.
Information Collected From Other Sources
We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. We are committed to processing this data in accordance with GDPR.
Any information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third Party Websites and Links.
In addition to the specific uses described above, we may use any of the above information to provide you with the Services and to maintain our business relationship, including by enhancing the safety and security of our Services (e.g., troubleshooting, data analysis, testing, system maintenance, and reporting), providing customer support, sending service and other non-marketing communications, monitoring and analyzing trends, conducting internal research and development, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting the Services, our rights, and the rights of our employees, users or other individuals.
Finally, we may deidentify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you (“deidentified information”) (or we may collect information that has already been deidentified/anonymized), and we may use such deidentified information for any purpose, including scientific research and studies. To the extent we possess or process any deidentified information, we will maintain and use such information in deidentified/anonymized form and not attempt to re-identify the information, except solely for the purpose of determining whether our deidentification/anonymization process satisfies legal requirements. Once deidentified information has been shared with a research partner, it cannot be deleted or recalled. However, any data that has been deleted will not be included in subsequent data sets.
Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may decline, block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including certain features and general functionality, to work incorrectly. If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.
To opt out of tracking by Google Analytics, click here.
Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of your information when you visit various websites. Like many websites, our website is not designed to respond to such signals, and we do not use or disclose your information in any way that would legally require us to recognize opt-out preference
signals. To learn more about “do not track” signals, you can visit http://www.allaboutdnt.com/. To learn more about Global Privacy Control, you can visit https://globalprivacycontrol.org/.
For Tracking Technologies on your mobile applications, check your mobile device for settings that control ads based on your interactions with the applications on your device. For example, on your iOS device, disable the “Allow Apps to Request to Track” setting, and on your Android device, enable the “Opt out of Ads Personalization” setting.
We may disclose your information to third parties for legitimate purposes subject to this Privacy Notice, including the following categories of third parties:
To help advance female athletic potential through research, education, and innovation, we may share relevant aggregated and de-identified information, including health and wellness information, with carefully selected research partners to be used in their scientific research and studies.
International Data Request and Cloud Act
In the event of a request from U.S. law enforcement under the Cloud Act for data pertaining to non-U.S. residents, we will assess whether the request conflicts with the laws of the country where the data is stored and whether there is a relevant Executive Agreement in place. If we reasonably believe that the data request conflicts with applicable laws or pertains to a non-U.S. resident, we will seek to challenge, modify, or quash the request to ensure compliance with GDPR and protect the privacy of our users.
We may provide links to third-party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.
Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.
We employ industry-standard encryption protocols for the transmission and storage of all Personal Identifiable Information (PII) and Protected Health Information (PHI). Access to PII and PHI are restricted to authorized personnels only, and all access is logged and audited regularly to ensure compliance with HIPAA regulations and GDPR. Our application implements least privilege access controls to minimize unnecessary access to sensitive data. Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.
GDPR Compliance
We are committed to complying with the General Data Protection Regulation (GDPR). We process personal data based on the following legal bases:
We conduct Data Protection Impact Assessments (DPIAs) for processing activities that are likely to result in a high risk to the rights and freedoms of data subjects.
We ensure that any international transfers of personal data are conducted in compliance with GDPR, using appropriate safeguards such as Standard Contractual Clauses (SCCs) or Binding Corporate Rules (BCRs).
We adhere to the principles of Privacy by Design and Default, integrating data protection into our processing activities from the outset.
Data Breach Notification
In the event of a data breach involving PII or PHI, we will notify relevant supervisory authority within 72 hours and affected individuals within 60 days of the breach discovery, in accordance with HIPAA and GDPR requirements. Notifications will be sent via email or through in-app alerts, depending on the contact information available.
We adhere to the principle of data minimization, collecting only the data necessary for specified purposes. Personal data is retained only as long as necessary for these purposes or as required by law, after which it is securely deleted. For users who do not access their account for a period of 12 months, we may anonymize and aggregate data after a reasonable period. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products.
Active Users: For active users who continue to use the app, we retain all data for as long as your account is active. This allows you to access historical trends, analyze progress, and maintain a complete health and wellness record.
Inactive Users: Users who do not access their account on the app for a period of 12 months, will be categorized as an inactive user. For inactive users, we may anonymize, aggregate, and store your de- identified data after a reasonable period (i.e., 12 months) while your identifiable data will be removed from our system. This anonymized data helps us improve the app, perform scientific research, and understand user behavior without identifying individuals.
Account Deletion: You have the right to delete your account at any time. Upon deletion, we will remove your personal data from our systems, except for anonymized and aggregated data used for analysis or anonymized and aggregated data that previously shared with partners.
Depending on where you live, you may have some or all the rights listed below in relation to information that we have collected about you. Note that a number of these rights only apply in certain circumstances, and all these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your personal data.
Should you have any questions about our privacy practices or this Privacy Notice, please email us Privacy@KyniscaInnovationHub.com.