1.1 JSC “Aichomas” cares about the privacy and personal data protection of its clients and seeks to ensure fair and transparent processing of personal data of clients and comprehensive notification of customers about the processing of their personal data.
Your personal data controller
2.1 JSC “Aichomas”, a company registered and operating in the Republic of Lithuania, legal entity code 304895097, registered office address Girulių g. 10-201, Vilnius, the Republic of Lithuania, is your personal data controller.
2.2 As a controller of your personal data, we shall independently set the purposes and means of the processing of personal data. We ensure data protection by implementing provisions of the General Data Protection Regulation (EU) 2016/679 and other personal data protection legislation.
2.3 Should you have any personal data-related questions, contact us by e-mail firstname.lastname@example.org.
Processing of your personal data
Use of the Mobile application (when Client uses the Mobile application via the smartphone to track their reliant relative)
3.1 The Mobile application is a software program for a smartphone, that, in conjunction with the Smartwatch, provides the approximate geographical position of reliant relatives to be known to the Client by means of geolocation systems and the map monitoring.
3.2 The Mobile application also has health data tracking ability – it uses sensors of the smartwatch to track essential health data (sleep time, heart rate etc.) of the reliant relative and displays it on the display of the Mobile application.
3.3 To use our services, the Client needs to install the Mobile application on the smartphone. When the Client uses our Mobile application to track their reliant relative’s location and health status, we will process personal data of the Client for the purpose of providing our services on the legal basis of a contract with the Client (the Client has to agree with Terms and Conditions of the Mobile application before using the Mobile application).
3.4 In order to offer our Client proper tracking services, we may process the following data of the Client:
3.4.1 Your own personal data you have provided to us (e.g. name, surname, age, e-mail address, phone number etc.);
3.4.2 Technical data related to your smartphone, as well as its activity during your use of the Mobile application (e.g. smartphone model, operating systems, Mobile application interaction with other smartphone functions, communication service provider, information whether your smartphone is one or off, has internet access, data relating to devices linked to your smartphone etc.);
3.4.3 Data required to provide proper tracking services (e.g. real-time tracking of the GPS of your smartphone, analysis of that data etc.);
3.4.4 Your financial data required to make payments for the use of Mobile application (bank (money payment institution) account information etc.);
3.4.5 Other data provided when creating an account and / or using our Mobile application and / or other data relating to our services.
3.5 Please note that the processing of all the aforementioned data is necessary for the complete performance of our tracking service and proper operation of the Mobile application. If we do not receive the aforementioned data (or part of it), we will not be able to properly provide our services and track your reliant relatives.
3.6 When providing our services, we will process personal data of our Clients for up to 5 years from the date of the termination of the services (when the Client deletes the Mobile application from their smartphone), unless a longer period of retention of individual data is required by law.
Use of the Mobile application through the smart wearable device by the reliant relative
3.7 To use this Mobile application properly, the smartphone (with Mobile application installed on it) of the Client has to be linked to the smart wearable device worn by the reliant relative of the Client.
3.8 The Mobile application collects and aggregates data (location and health data) of the reliant relative with the smartwatch and provides essential tracking service for the Client via the Mobile application. It shows the exact location of the reliant relative and informs the Client if their reliant relative leaves a designated home area. The Mobile application also provides the Client with smart advice based on the essential health data of the reliant relative acquired through the sensors of the smartwatch.
3.9 For the Mobile application to be able to track the reliant relative (their location and health status) of the Client, the reliant relative has to accept the collection and processing of their data by the Mobile application through the smart wearable device. Thus the personal data of the reliant relative of the Client is processed for the purpose of providing proper services and necessary safety for the reliant relative on the legal basis of the consent acquired from the reliant relative, when reliant relative explicitly allows the linked smartphone to install the Mobile application on the smart wearable device of the reliant relative.
3.10 In order to properly track the location and health status of the reliant relative, we may process the following data of the reliant relative (subject to the consent of the reliant relative):
3.10.1 Location data of the reliant relative. When properly installed on the smart wearable device of the reliant relative, the Mobile application allows the approximate geographical position of reliant relatives to be known to the Client by means of geolocation systems and the map monitoring, alternatively using for the purpose the main infrastructures assigned to these services, such as geolocation-GPS, GPS based stations, Wi-Fi and etc.;
3.10.2 Health data of the reliant relative. The Mobile application uses sensors of the smart wearable device to track essential health data (sleep time, heart rate etc.) of the reliant relative and displays it on the display of the Mobile application on the smartphone of the Client. Based on the aforementioned health data of the reliant relative, the Mobile application also provides the client with generalized and basic smart advice based on the essential health data of the reliant relative;
3.10.3 Technical data on the smart wearable device of the reliant relative (model of the smart wearable device, operating system and etc.);
3.10.4 Data on the reliant relative, provided through the Mobile application (name, surname, home address, photo (optional));
3.10.5 Other data provided by the reliant relative subject to his own consent.
3.11 Please note, that the aforementioned location data and health data of the reliant relative, are being processed by us on the ground of separate, explicit, clear, and unambiguous consent from the reliant relative, which is given during the installation of the Mobile application on the smart wearable device. The data on the reliant relative shall not be used for any purpose other than the proper provision of tracking services for the Client and ensuring the safety of the reliant relative.
3.12 At any given time, the reliant relative has the right to revoke his / her consent for the aforementioned processing of his personal data by uninstalling the Mobile application from his smart wearable device.
3.13 Data of the reliant relative, which we process for the aforementioned purpose of tracking, shall be stored for a term of 1 year from the date of the consent of reliant relative unless reliant relative revokes the consent before the expiry of the said term as mentioned in the paragraph 3.13 of this Policy. After the expiry of the said term or in the event reliant relative revokes consent, we will cease the processing of these personal data for the purpose of tracking.
3.14 To ensure timely and appropriate processing of your requests, contact you regarding any information you provide, protect our interests and interests of our Clients and fulfill various legal requirements, we process your personal data when you contact us (by email, through our website, social media accounts or by any other method). We keep all communications with our Clients to ensure that in case of disputes we have all available communication logs.
3.15 The basis for the processing of your personal data upon your request is consent which is expressed through your active actions – submitting a request.
3.16 We store your personal data for the aforementioned purposes for up to 3 years, depending on the nature of received personal data and other circumstances. We apply longer periods of personal data storage when:
3.16.1 there is a reasonable suspicion of an unlawful act which is subject to investigation;
3.16.2 your data is necessary for the proper resolution of the dispute, complaint or claim;
3.16.3 we have received complaints related to you, or if we have noticed any violations committed by you;
3.16.4 it is necessary for back-up copies or related purposes of the functioning of our internal systems;
3.16.5 it is mandatorily required by applicable law;
3.17 In any case, we kindly recommend that you protect your personal data when submitting the requests and therefore do not disclose certain personal data if such disclosure is not necessary for the development of your request.
Direct marketing and Push notifications
3.18 In cases where you subscribe to Aichomas email newsletters, Aichomas shall process your personal data for direct marketing purposes, i.e. for the purpose of sending the aforementioned newsletters. Aichomas newsletters provide information on the progress of Aichomas projects, updates and news of the Mobile application, and other relevant information regarding services provided by Aichomas.
3.19 When sending these newsletters, Aichomas processes data based on your consent, i.e. when you subscribe to these newsletters on Aichomas website. In this case, Aichomas shall process your personal data such as your e-mail address.
3.20 When you use our Mobile application and with your consent, Aichomas can send push notifications to your mobile device. These push notifications are sent to inform our Clients of various events (such as locations of the reliant relative, the moment when the relative leaves a designated safe zone, the health status of the reliant relative), and also other information related to our activities. Some of the push notifications may be addressed to all the Clients and some notifications may be addressed personally for you.
3.21 Notifications may also be sent to our Clients through smart wearable devices. The notification informs such Clients of various events (such as health status, location) also updates of the Mobile application, and other information related to our activity. Some of the notifications may be addressed to all the Clients and some notifications may be addressed personally for you.
3.22 Your personal data processed for direct marketing purposes shall be stored for 3 years from the date of your consent, unless you withdraw your consent before the expiry of this period. Upon the expiry of this period or upon your withdrawal of our consent, Aichomas shall stop processing your personal data.
3.23 You shall have the right to unsubscribe from newsletters or refuse push notifications sent to you at any time. You can unsubscribe from newsletters by clicking on the dedicated link at the bottom of the newsletters sent to you or by notifying Aichomas in writing (for example, by email). To refuse push notifications you have to change settings for Mobile application in your mobile device and / or smart wearable device.
Visiting our website (www.aichom.com)
3.24 When you browse our website, we do not hold any personal data about you, but we use various tools to help us maintain the website and provide the best possible experience for you.
3.25 Each time you access or visit the website, the following technical personal data may be automatically collected: IP address, access date and time, webpage name and URL, device operating system data, information about the Internet provider, geo-location data, language settings, and other relevant data.
3.27 Aichomas uses the following cookies
3.28 When you use a browser to access our content, you can configure your browser to accept all cookies, to reject all cookies, or to notify you when a cookie has been downloaded.
3.29 Each browser is different, so if you don’t know how to change your cookie preferences, check out its Help menu. The operating system of your device may have additional cookie controls. If you do not want the information to be collected using cookies, use a simple procedure offered in most browsers that allows you to opt-out of cookies. To learn more about managing cookies, visit http://www.allaboutcookies.org/manage-cookies/.
3.30 However, please note that in some cases, deleting cookies may slow down your browsing speed, limit some website features or block access to the website altogether.
Security of your data
4.1 We take the protection of your personal data very seriously – we encrypt the information you provide to us during the transmission of the information, our offices have perimeter control from unauthorized entry, we have internal IT security procedures and use best security practices to minimize risks from outside attacks, also other organizational and technological security measures.
4.2 While we implement different security measures on our website and Mobile application, you should be aware that complete and absolute security is not always possible. Whenever you give out personal information online there is a risk that a third party may intercept and use that information. While we strive to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. By using the Aichomas services, you expressly acknowledge and agree that we cannot guarantee the security of any personal data provided to or received by us through the services (by using Mobile application and our website) and that any personal information, general information, or other data or information received from you through the Mobile application or the website is provided at your own risk.
Recipient of your personal data
5.1 We may hire certain service providers, i.e. data processors, to process your personal data. These may be companies providing data storage, server and / or communication services, tracking services, companies developing and maintaining software, companies providing marketing services and analysis of activities online, online traffic and website analysis, statistics services, and other service providers. Your personal data may be transferred to these data processors only when and solely to the extent necessary for the provision of the respective services of these data processors.
5.2 Finally, we may transfer certain personal data of our Clients to third parties, such as courts, persons providing legal or audit services, in compliance with legal requirements, lawful instructions from competent authorities, and other individuals in the performance of legislative requirements, legitimate instructions by competent authorities or in presence of another legitimate basis.
5.3 Usually, we do not transfer the personal data of our Clients outside the European Economic Area (EEA). However, in some cases, the performance of our activities may require a transfer of the Client’s personal data to a data recipient outside the EEA (e.g. if our service provider is located outside of the EEA) to a certain extent. In this case, we shall aim to ensure that the security measures required for such data transfer are implemented (e.g. that a US-based data recipient has been certified in accordance with the EU and US privacy requirements; that the data recipient has been certified in accordance with the European Commission as properly
Your rights as a data subject
6.1 General Data Protection Regulation (EU) 2016/679 gives you more rights to control which data about you can be accessed by companies like us. Here is a list of rights specified in regulation:
6.1.1 The right of access to your personal data. You have the right to receive confirmation that we process your personal data as well as the right to access your personal data processed and information about the purposes of the processing, the categories of data being processed, the categories of data recipients, the period of data processing and the sources of data;
6.1.2 The right of rectification. If you think that data processed by us is inaccurate or incorrect, you have the right to request that such data be modified, clarified, or corrected;
6.1.3 The right of erasure (right to be forgotten). When there are circumstances specified in certain legal acts, you have the right to request us to erase your personal data;
6.1.4 The right of restriction of the processing. When there are circumstances specified in legal acts, you also have the right to request us to restrict the processing of your personal data;
6.1.5 The right of data portability. You have the right to transfer your data processed by us with your consent and by automated means to another data controller.
6.1.6 The right to disagree with the processing of your persona data if it is processed on a legitimate interest basis, unless there are legitimate reasons for such processing or for the Purpose of claiming, enforcing or defending legal requirements;
6.1.7 The right to revoke your consent to process your personal data. If we have no other legal basis for the processing of personal data, we will cease processing of personal data immediately after the cancellation / revocation of the consent provided by you;
6.2 These rights of data subjects shall be implemented if all requirements set by applicable legal acts are met. In order to exercise your rights, contact us by e-mail at email@example.com. Having received your written request, we may ask you to confirm your identity and / or to revise the scope of the implementation of your specific right as a data subject.
6.3 Finally, if you feel that your personal data protection rights have been violated, you shall have the right to contact the State Data Protection Inspectorate (vdai.lrv.lt) in all cases and to lodge a complaint. However, we recommend that you contact Aichomas prior to a formal referral to the supervisory authority to find a mutually appropriate and effective solution to the problem.