1. Who is the data controller?

Persei Vivarium, S.L., with VAT B87263885 and registered office at Gran Vía 62, 5º, 28013, Madrid (hereinafter "PERSEI") is the data controller of your personal data.

The purpose of this Privacy Policy is to inform the user (hereinafter, the "User") interested in the content (hereinafter, the "Content") and services (hereinafter, the "Services") offered by PERSEI in its App “Caaring”.

The User may contact PERSEI in connection with the present Privacy Policy at dpo@perseivivarium.com.

2. Recommendations

Please read carefully and follow the recommendations below:

• Keep your device equipped with properly updated antivirus software against malicious software and spyware applications that may jeopardize your Internet browsing and the information stored on your device.
• Please read and review this Privacy Policy and all legal texts made available by Persei in the App.

3. Information on the data that PERSEI collects through the App

For the proper functioning of the App, PERSEI may have access to the following data provided, if any, by the User:

• Name and surname.
• E-mail address.
• IP address of the User.
• Health data, including:
• Health data derived from the collection of data manually entered by the User through the application’s forms.
• Health data collected from the Google Health and Apple Health applications, with the User’s prior consent.

4. What are the purposes for processing your personal data and why is PERSEI legitimized to process it?

PERSEI processes the personal data of Users to enable the relationship requested by the User or to send information requested by Users.

We take the protection of your privacy and your personal data very seriously. For this reason, your personal data is kept securely and treated with the utmost care in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR").

This Privacy Policy regulates the access and use of the service that the App makes available to the User interested in the services and content hosted on the App.

When health data is collected directly by Persei, we have a meticulous document that reflects this process. This document ensures that data acquisition is carried out with explicit user consent through informed consent. It details the purpose, legitimacy, and essential points that the User must understand regarding the collection of their personal data. It is important to highlight that Persei is unwaveringly committed to using this data exclusively for the established purposes and has no intention of making transfers to third parties. In this way, we ensure strict compliance with Article 9.2 (a) of the GDPR.

Additionally, the User should be aware that we collect health-related information from the Google Health and Apple Health applications, with prior consent from the User:

• Height
• Sleep
• Heart rate
• Menstruation
• Physical activity
• Body temperature
• Weight
• Blood oxygen

With regard to this point, the User may withdraw his/her consent at any time by sending a message to dpo@perseivivarium.com without this affecting the lawfulness of the processing based on the consent prior to its withdrawal.

5. Accuracy of the data provided by Users

The User guarantees the veracity of the personal data provided and undertakes to inform PERSEI of any changes thereto. The User shall be responsible, in any case, for the veracity of the data provided, and PERSEI reserves the right to exclude from the services any User who has provided false data, without prejudice to any other actions that may be applicable by law.

It is recommended that Users protect their data with the utmost diligence by using appropriate security tools. PERSEI shall not be liable for any theft, illegal modification or loss of data.

Any modification or update of the data must be communicated to PERSEI through the means of communication provided for in this Privacy Policy.

6. Data retention

The protection of the privacy and personal data of Users is very important to PERSEI. Therefore, PERSEI makes every effort to prevent the User's data from being used inappropriately. Only authorized personnel have access to the User's data.

The User's personal data will be retained for as long as the User's personal data is useful for the purposes for which they were collected, provided that the User has not revoked his or her consent by requesting the cancellation or erasure of the personal data. Personal data that is no longer required to fulfill the identified purposes will be destroyed, erased or de-identified.

Subsequently, if necessary, PERSEI shall keep the information blocked for the legally established periods and make it only accessible when legally required by a public authority.

PERSEI undertakes to comply with its obligation of secrecy and confidentiality of personal data in accordance with the provisions of the applicable legislation.

7. Users' rights

The User may exercise their rights of access, rectification, deletion, objection, restriction of processing, portability, and the right not to be subject to a decision based solely on automated processing, withdrawal of consent by submitting a request through the address dpo@perseivivarium.com or by ordinary mail to the following address: Calle Gran Vía 62, 5º, 28013, Madrid. The request must specify which of these rights is being requested.

PERSEI informs the User of the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Without prejudice to any other administrative or judicial remedy, the User shall have the right to lodge a complaint with a supervisory authority, in the event that he/she considers that the processing of his/her personal data is not lawful, as well as in the event that he/she is not satisfied with the exercise of his/her rights. The User may also file a complaint with the Spanish Data Protection Agency (https://www.aepd.es).

The supervisory authority to which the complaint has been lodged shall inform the complainant about the course and outcome of the complaint.

PERSEI will provide information on action taken on a request without undue delay and within one (1) month of receipt of the request. In the event that the request cannot be completed, the period may be extended where necessary, taking into account the complexity and number of requests. PERSEI shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay.

8. Data security

The protection of the privacy and personal data of Users is very important to PERSEI. Therefore, PERSEI has taken all measures within its power to prevent your data from being used improperly, allowing access to it only to authorized personnel.

PERSEI maintains adequate security measures for the protection of personal data in accordance with applicable legislation and has established all the technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access, and theft of the data provided by the User through the App, without prejudice to informing you that security measures on the Internet are not impregnable.

PERSEI undertakes to comply with the duty of secrecy and confidentiality with respect to personal data in accordance with applicable legislation.

PERSEI will not be liable for any damage or loss that may arise due to the User's failure to comply with this obligation

9. Transfers and/or assignments to third parties

There is no provision for the communication of Users' personal data to other data controllers or the international transfer of data, except as indicated below in the case of data processors to whom we have recourse.

When it is necessary for a data processor to provide us with a service essential to the operation of the platform, such as sending the User commercial communications or news, PERSEI has adopted appropriate contractual measures to protect your personal data. In the event that this data processor is located outside the European Economic Area, PERSEI will also take measures to ensure that the processing complies with the appropriate guarantees, including that it is located in a third country that has been declared as having an adequate level, under the list that, where appropriate, is published respectively by the European Commission or the Spanish Data Protection Agency (AEPD), or under any other measure approved by the GDPR.

Our team of people and collaborators working in or for PERSEI are obliged to maintain confidentiality about the personal data to which they have access.

10. Data processors

In certain circumstances, PERSEI may function solely as a data processor with prior consent from the User, despite being the entity responsible for collecting your personal data. In such cases, PERSEI adheres to the highest standards of data protection, ensuring that all necessary safeguards are implemented in strict accordance with the GDPR. PERSEI is committed to maintaining the confidentiality and integrity of your personal data and would collaborate closely with the data controller to ensure that your rights and privacy are fully respected throughout the process.

11. Updates and changes in our Privacy Policy

PERSEI has the right to revise its Privacy Policy from time to time. For this reason, we encourage the User to regularly check this Privacy Policy for the most recent version of this Privacy Policy.

However, any changes to this Privacy Policy will be communicated to the User.

12. Links

The App may contain links to third-party Apps, such as social media Apps, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these Apps. Accordingly, we recommend that you review the privacy policy posted on any external App before disclosing any personal information. Please contact those Apps directly if you have any questions about their privacy policies.

This Privacy Policy will be applied exclusively to information which we compile on this App.

The conditions offered by these Apps may not be the same as those offered by PERSEI.

13. General inquiries

If you have any questions about this Privacy Policy or the processing of your data, please contact PERSEI by e-mail at dpo@perseivivarium.com.

14. Acceptance and Consent

The User declares to have been informed of the conditions on personal data protection, accepting and consenting to the processing of this data by PERSEI, in the manner and for the purposes indicated in this Privacy Policy.