Health Circle Privacy Policy
as of March 6, 2022

 

The protection of your data and your privacy are very important to us. We understand that your health information is sensitive. That is why the legislature also speaks of “special personal data” when it comes to certain health data. These are particularly worthy of protection.

We at health circle collect as little data as necessary! These data are only intended to ensure that you are using the app and that the treatment is successful.

Which questions does the privacy policy answer for you?

  1. Why does Health Circle collect, process and use your data?

  2. How does Health Circle handle your data?

  3. What data do we collect?

  4. When do we process your data?

  5. How long will the data be stored by us?

  6. Who does Health Circle share your data with?

  7. Where do we store your data and how do we protect it?

  8. How can you delete your data stored by Health Circle?

  9. How do you get your data?

  10. What third party tools do we use?

  11. What other rights do you have as a user?

  12. What happens if this data protection declaration is changed?

 

1. Why does the health circle collect, process, and use your data?

We would like to support you in supplementing conventional forms of treatment to approach your therapeutic training optimally at home and to help you complete your program as much as possible. This also means that we use our product with anonymized data for the success of the treatment.

The processing of your data by health circle serves these purposes only.

 

2. How does The Health Circle handle your data?

The Health Circle Company, a Tennessee corporation (THC) located at 236 E. 5th Street, Suite 206, Chattanooga, Tennessee 37403, is behind the The Health Circle app. The Health Circle collects and processes your personal data in connection with the Health Circle (“App”) and the website www.the-health-circle.com (“Website”). We are “responsible” within the meaning of the General Data Protection Regulation (“GDPR”).

We only process your data insofar as this is necessary to provide the Health Circle services you have requested, you have consented to the processing or we are otherwise authorized to do so on the basis of data protection laws. We will obtain your consent separately for the processing of your health data. You can consent to the processing of this data, e.g. by activating the consent slider. Your consent will be recorded by us.

Inquiries of all kinds can be directed to info@the-health-circle.com at any time. You can find more information about the company at the-health-circle.com

 

3. What data do we collect?

Personal data are specially protected by law. Such data is understood to be information that relates to an identified or identifiable person.

Apart from your IP address, we do not collect any data that allow direct assignment to your person. Nevertheless, strictly confidential handling of all your data is very important to us. Therefore, we treat all data according to the rules that also apply to personal data.

If you do not want to provide us with the required data, we cannot provide the services described in our user agreement (GTC) for you.

Technical specifications

Technical data collected by us inform us about which hardware and software you are using to access our app:

In the app

Platform (e.g. iOS or Android)

Version of the Health Circle app

Make and model of your device

Version of the operating system on your device

The so-called "Identifier for Advertising in Apple" for iOS devices

The so-called "Advertising ID" for Android devices

In the web browser

 

Usage data

Usage data collected by us are data that inform us about how and how often you use our offers:

In the Health Circle app

Times and frequency of app usage

Areas of the app that have been used

Duration of use

App settings used (language settings, notifications)

Feedback data (including email service)

 

4. When do we process your data?

We collect and store your health data, technical data and usage data while you are using the app.

 

5. How long will the data be stored by us?

Your data will only be saved as long as you are logged into the app. When you log out, your video will be deleted immediately, as will your personal data

 

6. Who does Health Circle pass on your data to?

In order to ensure optimal treatment success, we pass on your data to your personal physiotherapist, who gave you access.

 

7. Where do we store your data and how do we protect it?

Your video data will only be saved on your smartphone. All other data is stored on the firebase.google.com platform. These are the following elements: Name, training plan, name of the therapist, email of the therapist, telephone number of the therapist

8. How can you delete your data stored by Health Circle?

You can delete your data via the menu ribbon! In addition, your data is automatically deleted when you log out.

9. How do you get your data?

Do you want to see all of your saved data? Write to us at info@the-health-circle.com

 

10. What third party tools do we use?

Google Analytics

The Health Circle app uses Google Analytics, an analysis service provided by Google LLC (1600 Amphitheater Parkway Mountain View, CA 94043, USA; "Google"). Use includes the "Universal Analytics" operating mode. This makes it possible to assign data, sessions and interactions across multiple devices to a pseudonymous user ID and thus to analyze the activities of a user across devices.

Google Analytics uses so-called "cookies", text files that are stored on your device and that enable your use of the Health Circle app to be analyzed. The information generated by the cookie about your usage is usually transferred to a Google server in the Germany and stored there. If IP anonymization is activated on the website, your IP address will be shortened beforehand by Google in member states of the European Union and contracting states of the Agreement on the European Economic Area. The full IP address will only be sent to a Google server in the Germany and shortened there in exceptional cases. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. Google uses this data on behalf of Health Circle to evaluate your use of the Health Circle app and the Internet for Health Circle. Health Circle uses the evaluations with the aim of improving the Health Circle user experience. Our legitimate interest in data processing also lies in this purpose.

The legal basis for the use of Google Analytics is Section 15 Paragraph 3 TMG or Article 6 Paragraph 1 lit. f GDPR (“Legitimate Interests”). We assume a legitimate interest, as we can significantly improve the app and website for all users based on the findings from the data from Google Analytics.

You can object to data processing at any time by proceeding as described in section 10 of this data protection declaration and deleting your data. The legality of the data processing operations that have already taken place remains unaffected by the objection.

The data sent by us and linked to cookies, user IDs (e.g. user ID) or advertising IDs will be deleted after 14 months. The deletion of data whose retention period has expired takes place automatically once a month.

Google has a Privacy Shield certification. Google thus voluntarily fulfills the data protection requirements of the EU. You can find more about this here: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI

You can find more information on terms of use and data protection at Google at https://www.google.com/analytics/terms/de.html or at https://policies.google.com/?hl=de.

You can prevent the storage of cookies by setting your browser software; however, we would like to point out that in this case you may no longer be able to use all the functions of the Health Circle to their full extent. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the app (including your IP address) and from processing this data by downloading and installing the appropriate browser add-on : https://tools.google.com/dlpage/gaoptout/

In order to prevent the collection by Universal Analytics across different devices, you have to carry out the opt-out on all systems used.

 

Firebase

Data storage and processing takes place on servers in Germany. The provisions of the German Data Protection Act apply.

In our apps we use technology from Google Firebase (Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, “Google”) with various functionalities. Firebase Analytics enables the analysis of the use of our offer. In this way, completely anonymous information about the use of our app is recorded and transmitted to Google and stored there. Google uses the device's advertising ID for this. Google will use the information mentioned to evaluate the use of our app and to provide us with other services related to the use of apps. You can restrict the use of the advertising ID in the device settings (iOS: Data protection / Advertising / No ad tracking; Android: Account / Google / Ads). Google Analytics for Firebase (Google Inc.). We also use Firebase Remote Config, which enables us to perform A / B tests and adjust the behavior and appearance of the app without having to download a new version. Personal data is not stored. Google Inc. is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). Subcontractors that Google can use can be found at the following link: https://firebase.google.com/terms/subprocessors.The legal basis for the use, evaluation of the data and use of Firebase is a legitimate interest (i.e. interest in the analysis, Optimization and the economic operation of our apps) within the meaning of Art. 6 (1) (f) GDPR). You can object to the use of Firebase at any time by using the slider for anonymous statistics in the Health Circle app under "Settings" to adjust

Firebase Crashlytics

The customer agreeing to these terms ("Customer"), and Google LLC (formerly known as Google Inc.), Google Ireland Limited, Google Asia Pacific Pte. Ltd., or any other entity that directly or indirectly controls, is controlled by, or is under common control with Google LLC (as applicable, "Google"), have entered into the Firebase Crashlytics and Firebase App Distribution Terms of Service under which Google has agreed to provide the "Firebase Crashlytics" or "Firebase App Distribution" products or services to Customer (as amended from time to time, the "Agreement").

These Crashlytics and App Distribution Data Processing and Security Terms, including their appendices, (the "Terms") are incorporated into the Agreement. These Terms will be effective and replace any previously applicable data processing and security terms as from the Terms Effective Date (as defined below).

 

11. What other rights do you have as a user?

 

As a Health Circle user you have the following options and rights.

Correction, deletion or restriction of processing

You have the right to request the correction, deletion or restriction of the processing of your personal data. In this case it is necessary to delete your data. You do this by clicking on the “Settings” page - Privacy - Delete all videos in the Health Circle app. This will irrevocably delete all of your videos. To delete all of your remaining data, write to us at info@the-health-circle.com Your data will no longer be available to you from that moment or shortly thereafter.

Objection to the processing

You have the right to object to the processing of your data by Health Circle or to revoke your consent for reasons that arise from your particular situation. If you want to do this, please write to info@the-health-circle.com

Portability of your data

You have the right to receive your personal data stored by Health Circle in a structured, common and machine-readable format and to transmit this data to a third party without hindrance from us; If necessary, you also have the right to request that we transfer the personal data directly to a third party, insofar as this is technically feasible.

Refusal and withdrawal of consent

You have the right to refuse your consent or - without affecting the legality of the data processing carried out before the withdrawal - to withdraw your consent to the processing of your personal data at any time. As a result, Health Circle can no longer perform the services described in our terms and conditions. If you want to do this, please write to info@the-health-circle.com

Right to complain

You have the right to communicate with the data protection supervisory authority and, if necessary, to complain to them.

 

12. What happens if the data protection declaration is changed?

 

If there is a change, you will be informed by info@the-health-circle.com