Heartics / Privacy Policy
Introduced: November 2024
1. INTRODUCTION
LOGIC FUSION LLC, a company registered and acting under the laws of the United States, having its registered office at 4713 Southern Breeze Dr, Naples, FL, US 34114 (“Logic Fusion”, “Company”, ”we, “us”, or “our”), takes your privacy seriously. This Privacy Policy (the “Policy”) explains our data protection commitment and practices and describes the types of information we may process when you install and use the Heartics: Pulse & HRV Analyzer software application for mobile devices (”the App”, “our App”).

When we refer to personal data (or personal information), we mean any information of any kind relating to a natural person who can be identified, directly or indirectly, in particular by reference to such data or to an identification number (“Personal Data”).

Our Privacy Policy applies to all users and others who access the App (”Users”) and/or persons whose Personal Data we may process as a result of our business activities. We also refer to such persons by “you” in the text. The reference to the services available in the App is the “Services”.

For the purposes of General Data Protection Regulation (EU) 2016/679 and applicable national legislation implementing the GDPR and, if applicable, the UK Data Protection Act 2018 and the UK GDPR (hereinafter collectively the “GDPR”), we are the data controller, unless otherwise stated. We compiled this Privacy Policy and adjusted our processes towards Personal Data in compliance with GDPR as the highest standard for the protection of our users` personal data rights.

PLEASE READ THE FOLLOWING PRIVACY POLICY FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY BE PROCESSED CAREFULLY.

2. SCOPE
This Privacy Policy applies to Personal Data obtained through our App, or when you otherwise interact with us.

The App may contain links to other websites not under our control. We are not responsible for other websites' information practices or content. You should always review the policies of third-party products and services to make sure you are comfortable with how they collect and use your information.

3. INFORMATION WE PROCESS
We prioritize your privacy by using tools that limit the collection of identifiable information. When data qualifies as Personal Data under GDPR, we always follow the rules set in this Privacy Policy.


3.1. Information that you submit

You may provide personal information when using our App, which is required to fulfill our contract with you. Without this, we can't offer full functionality or services. Depending on the App's features, the following information may be processed:

General Information. You may fill it in when you choose to track physical parameters for your convenience, and/or share by connecting the other app to our App:
  • Gender;
  • Date of birth or age;
  • Race;
  • Weight;
  • Height.

Contact Information. You may share it when you log in or create a profile in our App or contact us via email:
  • Name;
  • E-mail address, and any other content included in the email;
  • Password or passcode;
  • Other information you decide to share when you log in via third-party services; it may also include technical identifiers necessary for the authentication service to run.

Health and well-being. The App may estimate various metrics such as:
  • Heart rate;
  • Heart rate variability;
  • Physical stress level.

These indicators are based on RR intervals and other metrics collected by the App during measurements or when importing data from Apple Health, if connected.

The App uses your camera as a light sensor for heart rate measurements. Images captured during measurement are processed locally on your device and deleted immediately. We do not access, store, or use any data from your camera roll.

You may also allow us to connect to third-party services, such as Apple Health, to enable us to import Personal Data about your health and activities into the App, as provided by its features. When you choose to have this data imported, you are subject to Apple Health privacy policies and practices. We may collect, once you allow us, the following data from Apple Health:
  • Weight
  • Heart Rate Variability
  • Heart Rate
  • Date of Birth
  • Sleep changes
  • Height
  • Sleep
  • Gender
  • Activity and workouts

The health and well-being information you submit is stored locally on your device.

You can delete your Personal Data by uninstalling the App. However, some information may be retained as described in Section 8 of this Privacy Policy.

Information you submit during the onboarding process in the App. Our App may offer features to personalize your experience before you gain full access. During the quiz, you may need to provide some Personal Data to help us customize the App. At this stage, we won't collect sensitive information like your health, gender, or age — this data is processed locally on your device. Instead, we'll rely on technical identifiers and log information necessary for the App to function and provide the requested service. Once the onboarding process is complete, we will ask for your consent to process the full range of Personal Data as outlined in this Policy.

Other data you may submit to us. We may also collect any data you submit while using interactive features of our Services, participating in surveys, contests, promotions, sweepstakes, activities, events, applying for a job, requesting customer support, or communicating with us through social media or other channels.

Other persons` Personal Data. If you provide someone else’s information, including Personal Data, you must have their permission to act on their behalf and consent to the collection and use of their data as described in this Privacy Policy.


3.2. Information collected automatically

Information from the App. When you use the App, information about your device and user behavior may be collected and processed automatically. This information is generally non-personal, meaning it cannot directly identify you. However, when combined, it may allow us to recognize you as a distinct user, and we treat this information as Personal Data, protecting it according to legal requirements. We process Personal Data based on our contract with you or our legitimate interest in enhancing the App and providing the best user experience. If we don’t access this data, we may not be able to offer all of the App's features. For marketing purposes, we rely on either legitimate interest or your consent to process your Personal Data.

Device Details. When you access our App using a mobile device, some details about your device are reported based on your privacy settings as determined by iOS functionality. This includes device identifiers and other metadata. Device identifiers are small data files or similar structures stored on or linked to your mobile device, allowing us to uniquely identify it without revealing personal information. These identifiers enable us to perform generalized reporting and analytics. The following information may be collected and processed:
  • Information about the device itself: type of your device, type of operating system, and its version, model, and manufacturer.
  • Information about the internet connection: mobile carrier, IP address, timestamp, and duration of sessions.
  • Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, and time zone.
  • Device identifiers and technical identifiers (e.g. IDFA).
  • Information about the App: name, API key (identifier for application), version, and App properties can be reported for automated processing and analysis.
  • Cookies and similar technologies. When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information downloaded to your device when you access the App. The text file is sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access specific areas or features within our App and which links they clicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that interest you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.
  • Log file information. Log file information is automatically reported each time you request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including the time and date when you start and stop using the App and how you interact with the App.
  • In-app events. When you use our App, analytics tools automatically record in-app information (tutorial steps, leveling up, payments, in-app purchases, custom events, progression events, etc.).

Please note that some services may engage in personal data profiling and collect information about your personality and/or device using technologies outside our control. For example, if your user ID is linked to your Facebook account, Facebook may associate your device information with data already in its databases (such as age or gender). We do not oversee or guarantee how third parties process your Personal Data collected through their means (not through our App). Any inquiries about the disclosure of your personal information should be directed to those third parties.

Payment Information. Our e-commerce providers responsible for billing, processing, and charging for in-app purchases handle your Personal Data, and keep it safe and secure. We cannot access or use your credit or debit card information.


3.3. Information received from third parties

We may also obtain information from third parties, such as:
  • Authorized resellers, distributors, and partners: We may receive information from them if there is a lawful basis for doing so, such as analytics from the Apple App Store.
  • Other third parties: This includes email campaigns, marketing partners, and publicly available sources. We may use this information to enhance what we already know about you, along with other purposes outlined in this Privacy Policy.
4. THE LEGAL BASES AND PURPOSES OF PROCESSING YOUR PERSONAL DATA
We will not collect or use your Personal Data without first notifying you. We handle your Personal Data based on one or more of the following legal bases, depending on the features of our Services you use:
  1. Contract. We use your Personal Data to fulfill our contractual obligations and provide the Services to you.
  2. Consent. For example, after installing the App on the welcome screen, we may ask you to permit us to process your Personal Data.
  3. Legitimate interest. We may process your Personal Data to support our interests in providing Services to you, pursuing our legitimate commercial interests, ensuring the security and integrity of the Services, and promoting wider societal benefits, as permitted by law.
  4. Legal obligations. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.

Our mission is to enhance our App and continually provide new user experiences. To achieve this, we may use your Personal Data for the following purposes, based on the applicable legal basis:

Purpose of processing
To make our Services available
Legal basis for processing
Contract
Example
We use your Personal Data (measurements data, technical and device identifiers, payment information, in-app events, other device information, IP address, App settings information, etc.) to provide you with all requested Services

Purpose of processing
To communicate with you and send you system and transactional messages
Legal basis for processing
Contract, legitimate interest
Example
We use your contact and device information to send you system notifications, reminders, policy updates, and billing information, if applicable. We may send push notifications, which you can disable at any time through your device settings or the App's consent toggle screens, if available. Additionally, we use your contact information to respond to your inquiries, provide user support, and address your comments, questions, and requests related to your use or intended use of our App

Purpose of processing
To enhance, test, and monitor the effectiveness of our App
Legal basis for processing
Consent, legitimate interest
Example
We use automatically processed information to better understand user behavior and trends, detect potential outages and technical issues, and operate, protect, improve, and optimize our App. Additionally, we utilize some of this data for content performance and feature testing (A/B testing)

Purpose of processing
To provide you with a personalized experience within our Services
Legal basis for processing
Consent, contract
Example
We use your Personal Data from various sources to identify your preferences and interests within our Services, recommend personalized content, and deliver the best possible user experience

Purpose of processing
To send promotional communications
Legal basis for processing
Consent, legitimate interest
Example
We use the contact information you provide to inform you about services, features, surveys, newsletters, offers, promotions, contests, and events. We may also send updates about our App and share news or information about our selected partners that may interest you, including via email, push notifications, or other means, as permitted by law. If we cannot rely on legitimate interest under applicable law, we will send you marketing communications only after obtaining your explicit consent

Purpose of processing
To promote and market our App
Legal basis for processing
Consent
Example
We use automatically processed information (including Personal Data) and data obtained from our marketing service providers or partners to develop our marketing strategy and promote our Services. The information we use and share for this purpose typically does not include personally identifiable information and never includes health data

Purpose of processing
To enable interest-based (behavioral) advertising or other targeted content
Legal basis for processing
Consent
Example
We or our service providers may use automatically processed information for marketing purposes, such as displaying ads tailored to your preferences. Our service providers may deliver personalized content and information, including online ads or other marketing forms. We never share your health data for these purposes. Please refer to the “How to Opt-Out from Tracking in the App” section below for ways to stop this type of advertising

Purpose of processing
For internal business purposes
Legal basis for processing
Consent, legitimate interest
Example
We use the information you submit, automatically collected data, and information obtained from third parties for data analysis, audits, research, studies, and identifying usage trends for internal business purposes. If the results of these activities include your Personal Data, we will anonymize or aggregate it before disclosure

Purpose of processing
To keep basic data to identify you and prevent further unwanted processing
Legal basis for processing
Legitimate interest
Example
If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfill your request

Purpose of processing
To verify your age
Legal basis for processing
Legal obligations
Example
We may ask for date of birth or your identification documents to confirm that your age complies with our age restrictions to use our Services

Purpose of processing
To comply with legal obligations and legal processes and respond to requests from public and government authorities, including public and government authorities outside your country of residence
Legal basis for processing
Legal obligation
Example
We may share your Personal Data to comply with our legal obligations when we are lawfully requested to do so

Purpose of processing
To enforce the Terms of Use, protect our operations, protect our rights, privacy, the safety of property, and/or that of you or others, and allow us to pursue available remedies or limit the damages that we may sustain
Legal basis for processing
Legitimate interest
Example
We may process your Personal Data according to our legitimate interest when we need to provide security and safety of data, protect our rights, and fulfill our obligations before other people and entities

If we need to process your information for a specific purpose not clearly outlined in this Policy, or that does not relate to providing you with requested Services and App features or a justified legitimate interest, we will seek your consent and update the list of purposes accordingly.

Where required by law, we will only send you marketing communications if you consent when providing your Personal Data or if we obtain your consent separately. You can opt out of receiving such emails by following the instructions in each promotional email, or by contacting us at privacy@logicfusion.net if that doesn’t work. We will continue to contact you via email regarding your use of our Services and to respond to your requests only.


5. SHARING OF YOUR INFORMATION
General principles and prohibitions. We will only share your information with our service providers as described in this Privacy Policy. Without your permission, we do not share Personal Data with third parties for their marketing purposes, including direct marketing. We do not share identifiable health data with third parties for marketing or any purposes unrelated to providing you access to our Services. We will not rent or sell your Personal Data to any third parties.

Personnel. We share your Personal Data only with our employees, contractors, agents, and auditors who need access to it as part of their professional responsibilities. These individuals are bound by written confidentiality agreements and other obligations to protect your Personal Data in accordance with this Privacy Policy.

Protection measures. When integrating external services, we select service providers that demonstrate they implement all necessary technical and organizational measures to protect users' Personal Data. However, we cannot guarantee the security of any information transmitted to these processors due to technical issues beyond our reasonable control. As long as we comply with applicable personal data protection legislation, we are not responsible for any accidental loss or unauthorized access to your Personal Data caused by third parties.


5.1. Disclosures made by you

Certain features of our Services allow you to make your measurements public, making them accessible to anyone. We encourage you to carefully consider the sensitivity of any data you choose to share.


5.2. Service providers and subcontractors

Processing to make the App run

We occasionally engage external businesses to process your Personal Data on our behalf. These entities are considered "processors." They assist us in managing the Services, facilitating communication with you, and performing other related tasks. To achieve these objectives, they may process certain Personal Data under our instructions and in compliance with applicable data protection laws. As required by law, we will enter into data processing agreements with our processors and retain responsibility for their actions.

Processors engaged to provide us with the necessary infrastructure for the delivery and improvement of our services:

Processor`s name and location
Amazon Web Services EMEA SARL; EU, USA
Services
Cloud storage and integration services
Privacy statement and Data Processing Addendum
Privacy Statement
Data Processing Addendum
Personal data collected/shared
All Personal Data that you submit to us and all data contained in the App, namely, User ID, name, email, profile picture, date of profile creation, in-app events, IP address, subscription status, individual identifiers, billing information, subscription ID, measurements data, measurements data source
Purpose of sharing
Storage of all Personal Data when you use the App

Processor`s name and location
Firebase (Google LLC); EU, USA
Services
Hosting, storage, and technical management services
Privacy statement and Data Processing Addendum
Privacy Policy
Cloud Data Processing Addendum
Firebase Data Processing and Security Terms
Personal data collected/shared
All Personal Data
Purpose of sharing
Storage of all Personal Data when you use the App, cloud computing to perform the App`s functionality

Processor`s name and location
App Store Connect, App Store, Test Flight (Apple Inc.), USA
Services
Technical, payment processing, and analytics services
Privacy statement and Data Processing Addendum
App Store & Privacy
App Analytics & Privacy
Personal data collected/shared
Payment information, personal identifiers
Purpose of sharing
To collect and process payments for subscription to the App, and for analytic purposes. Note that we do not access your banking information or payment requisites when you purchase subscriptions in the App.

Processor`s name and location
OneSignal, Inc., USA, EU
Services
Push notifications and analytics service
Privacy statement and Data Processing Addendum
Privacy Policy
Data Processing Addendum - to be provided on data subject`s demand, if applicable
Personal data collected/shared
Device identifiers, external user IDs, and in-app events
Purpose of sharing
To enable reminders and push-notification as part of our App`s functionality and Services

Processor`s name and location
SendGrid (SendGrid, Inc.), USA
Services
Email notifications
Privacy statement and Data Processing Addendum
Privacy Policy
Data Processing Addendum
Personal data collected/shared
Email address
Purpose of sharing
To communicate with you regarding your purchase of our Services, send you our newsletters, surveys, and other related notifications

Processor`s name and location
AppsFlyer (AppsFlyer, Inc), USA
Services
App analytics services
Privacy statement and Data Processing Addendum
Services Privacy Policy
Data Processing Addendum
Personal data collected/shared
  • Technical Information, such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier
  • Technical Identifiers that generally only identify a computer, device, browser or App. For example, device or advertising identifiers such as IDFA (identifier for advertisers); Google Advertiser ID; and App IDs.
  • Network Generated Data such as IP address and User agent.
Purpose of sharing
To perform analytics activities aimed at monitoring and improving our Services


We also engage service provider OpenAI (ChatGPT) to provide health insights and recommendations in the App. We do not intentionally disclose your Personal Data to such service providers, however, some technical identifiers may be shared only as it is necessary for the API to properly function.


Processing for marketing and marketing analytics purposes

With your consent, we may share some of your non-health Personal Data with our marketing and promotional service providers. We do this to market our App and Services, to help new users find out about us, and to develop our business by increasing awareness about the Services.

These are processors we engage for the above purpose:

Processor`s name and location
AppsFlyer (AppsFlyer, Inc), USA
Services
Marketing and marketing analytics services
Privacy statement and Data Processing Addendum
Services Privacy Policy
Data Processing Addendum
Personal data collected/shared
  • Technical identifiers: IP address (which may also provide general location information), User agent, IDFA (Identifier for advertisers), Customer-issued user ID and other similar unique technical identifiers;
  • Engagement Information such as: clicks on our ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, the URL from the referring website, downloads and installations of the App.
  • Your subscription status;
  • The fact of application launch.
Purpose of sharing
To analyze and obtain reports of how to optimize our marketing campaigns; for analytical purposes. In order to discover you or users who are similar to you on other platforms, including social networking websites, AppsFlyer may provide your Personal Data to some of its integrated partners (such as Pinterest, Google Ads, Apple Search Ads, FB marketing network, and others). These partners review your Personal Data to display pertinent information about Logic Fusion to those who might be interested in it or prompt you to use the App again if you haven't in a while.
You can withdraw your consent or opt-out from the sharing of your Personal Data with AppsFlyer for marketing and promotional purposes anytime by adjusting your device settings.

Processor`s name and location
RevenueCat
(RevenueCat, Inc.), USA
Services
Technical and transactional analytics services
Privacy statement and Data Processing Addendum
Privacy Policy
Data Processing Addendum
Personal data collected/shared
Technical identifiers (User ID, Device ID), Usage Data, and purchase history.
Purpose of sharing
To perform analytics towards your purchases in our App

Processor`s name and location
Facebook (Meta), USA
Services
Analytics / ad management services
Privacy statement and Data Processing Addendum
Privacy Policy
Data Processing Addendum
Personal data collected/shared
Technical identifiers and raw data, namely, event status, event revenue, and currency, event source, campaign ID, site ID, region, country, state, city, IP address, Customer User ID, Advertising ID, IDFA, IDFV; data about your device, namely, device category, platform, OS version, App version, and ID.
Purpose of sharing
To promote our Services and obtain marketing analytics data

Processor`s name and location
Mintegral North America Inc., USA
Services
Marketing services
Privacy statement and Data Processing Addendum
Privacy Policy and Data Protection Addendum
Personal data collected/shared
Technical identifiers and raw data, namely, event status, event revenue and currency, event source, campaign ID, site ID, region, country, city, IP address, AppsFlyer ID (if applicable), Advertising ID, IDFA, IDFV; data about your device, namely, device category, platform, OS version, App version, and ID.
Purpose of sharing
To promote our services and place ads on the Internet

Processor`s name and location
TikTok Pte. Ltd, Singapore
Services
Analytics / ad management services
Privacy statement and Data Processing Addendum
Privacy Policy
Data processing addendum
Personal data collected/shared
Personal information accessed or collected in connection with an event on TikTok inventory and properties, including a user’s non-intentional interaction with our ads, including hovering over, muting, pausing, or closing our ads; and any derivations or combinations of such personal information
Purpose of sharing
To promote our services and place ads on Tik Tok platform

Processor`s name and location
Unity Technologies S.F., (USA)
Services
Analytics / ad management services
Privacy statement and Data Processing Addendum
Privacy Policy
Data Processing Addendum
Personal data collected/shared
  • End Users data including voice (if applicable), advertising identifiers or device IDs (e.g. IDFA GAID), User IDs, IP address, gameplay, in-app purchase, and device data, including device identifiers,
  • Information related to the ad content or attribution data sent by Logic Fusion or Logic Fusion`s agent
Purpose of sharing
To promote our services and place ads on Unity platform

Processor`s name and location
Apple Search Ads platform (Apple Inc.), USA
Services
Analytics / ad management services
Privacy statement and Data Processing Addendum
Privacy Policy
General Apple Privacy Policy
Personal data collected/shared
To ensure delivering the most relevant ads, Apple Search Ads may use the following:
  • Account Information. This includes the information a customer includes in their Apple ID account (is not shared with Logic Fusion).
  • App Store Data. This includes information provided by developers to define and categorize their apps. It also includes insights derived from non-personal historical search terms, App Store downloads, App Store browsing activity, and in-app purchases made through the App Store.
  • App Transaction Data. This includes historical information about users’ transactions on the App Store, including apps they’ve downloaded and in-app purchases they’ve made.
  • Contextual Information. This includes a user`s device type, iOS version, time of day, device location, search query, and information about the page they’re viewing, or app they're downloading.
Purpose of sharing
To promote our Services and place ads on Apple Search Ads platform

Processor`s name and location
ironSource Mobile Ltd.
Services
Analytics / ad management services
Privacy statement and Data Processing Addendum
Privacy Policy
Data Protection Addendum
Personal data collected/shared
Device ID, IP address, Online unique identifiers, User ID, if provided by us
Purpose of sharing
To promote our Services and place ads on ironSource platform

Processor`s name and location
Snapchat Ads (Snap Inc.)
Services
Advertising services
Privacy statement and Data Processing Addendum
Snapchat Privacy Policy
Data Processing Agreement
Personal data collected/shared
Mobile ad ID (IDFA/AAID); IP address; cookie id; browser user agent; actions and events taken on apps, including pages viewed, purchases, searches, check-out events, wish lists, installs, and user registration methods.
Purpose of sharing
We use this service from time to time to promote our services and place ads

Processor`s name and location
X (Twitter) (Twitter, Inc., Twitter International Unlimited Company)
Services
Advertising and ad management/analytics services
Privacy statement and Data Processing Addendum
Privacy Policy
Data Processing Addendum
Personal data collected/shared
Conversions data - app installs, website visits, and product purchases
Purpose of sharing
We use this service from time to time to promote our services and place ads. Please learn how to disable targeted behavioral advertising for X here, or you can just limit Ads tracking on your iOS device.

Processor`s name and location
AppLovin Corporation (USA)
Services
Advertising and ad management/analytics services
Privacy statement and Data Processing Addendum
Privacy Policy
Data Processing Agreement
Personal data collected/shared
  • Mobile device advertising identifiers (e.g., IDFA/Google Ad ID, IP address);
  • Device data such as make, model, operating system, device properties and settings, coarse location data;
  • Click attribution data and transactional data;
Purpose of sharing
We work with AppLovin to deliver ads. For more information about AppLovin’s collection and use of your information, visit: https://www.applovin.com/privacy/

These lists may be amended or modified from time to time according to our business needs, on our sole discretion and without giving notice to you, but provided that such extension in sharing of your Personal Data do not require your consent as legal basis for processing. If so, we will ask you for consent while informing you of modifications for further processing.


How to opt-out from tracking in the App

If you don't want third-party service providers to personalize ads on the basis of your interests, please choose option "Limit Ad Tracking" on your iOS device in Settings/ Privacy/ Advertising, please find additional information here: https://support.apple.com/en-us/HT202074.

You can also disable Tracking for Heartics: Pulse & HRV Analyzer App in the Settings of your phone.

Remember that when you opt out of certain interest-based advertising, you may still receive contextual ads based on other non-personal information, such as ads related to the content of other digital products you are using.

Our App does not track your precise location data.



5.3. Third-party websites and social media widgets

Our Services may include social media features, such as Twitter (X), Facebook, and Instagram buttons. These features may collect your IP address and which page you visit on our site and may set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy statements of the company providing them.


5.4. Business transfers, legal requirements, and protection of our rights

We may disclose your personal information for objective reasons, due to public interest, or in unforeseen circumstances, including:
  • As permitted by law, in response to subpoenas, court orders, or legal processes, including to meet national security or law enforcement requirements.
  • When we believe, in good faith, that disclosure is necessary to protect our rights, your safety, or the safety of others, to investigate fraud, or to enforce our agreements, policies, and terms of service.
  • If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we will notify you through a prominent notice in our App regarding any changes in ownership or the use of your personal information, as well as any choices you may have concerning your information.

Depending on the circumstances, we may rely on legitimate interest or legal obligation as a legal basis for the above processing activities.


5.5. Aggregated or anonymized data

We may share aggregated or anonymized information that does not directly identify you with third parties, including our partners and research entities, for statistical, analytic, and scientific purposes. The anonymization and further use of this information are conducted under our legitimate interest and aim to contribute scientific value to our efforts in raising awareness about heart health and general well-being worldwide.
6. YOUR PRIVACY RIGHTS
We are committed to providing you with extensive privacy rights concerning your Personal Data, regardless of your nation or region. This commitment includes all individuals in the EEA, the UK, and Switzerland.
Please refer to Section 4 of this Policy to discover legal bases and specific purposes for processing your Personal Data.

Your rights under the GDPR:
  • the right of access. If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of the Personal Data along with certain other details.
  • the right to rectification. If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we share your Personal Data with others, we will tell them about the correction where possible.
  • the right to erasure. You may ask us to erase your Personal Data in some circumstances, such as when we no longer need it, or you withdraw your consent. If we share your Personal Data with others, we will alert them to the need for erasure where possible.
  • the right to restriction of processing. You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restrictions on processing. If we share your Personal Data with others, we will tell them about the restriction where possible.
  • the right to data portability. You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that we processed with automated means. We will give you your Personal Data in a structured, commonly used, machine-readable format. You may reuse it elsewhere.
  • the right to object. You may ask us at any time to stop processing your Personal Data, and we will do so:
  1. if we are relying on a legitimate interest to process your Personal Data – unless we demonstrate compelling legitimate grounds for the processing, or your Personal Data is needed to establish, exercise, or defend legal claims; or
  2. in certain circumstances, if we are processing your Personal Data for direct marketing purposes.
  • the right to withdraw consent. If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
  • the right to make a complaint with the data protection authority. If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

Your rights under California Consumer Privacy Act of 2018 (CCPA):
  • The CCPA provides California residents with the right to know what categories of personal information we have collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information in Section 5 of this Policy.
  • “Sales” of Personal Information under the CCPA. Without limiting our ability to disclose information as described in the section of our Privacy Policy entitled “Business transfers”, for purposes of the California Consumer Privacy Act we do not and will not sell your Personal Data, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
  • Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
  • Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.
  • Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.

Your rights under Virginia Consumer Data Privacy Act (VCDPA):
  • Opt out of the Processing of your Personal Data for Targeted Advertising. Please note that we do not process Personal Data for purposes of (1) the sale of personal data, as defined by the VCDPA, or (2) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
  • Confirm whether your Personal Data is being Processed. You may confirm whether your Personal Data is being processed by emailing us.
  • Appeal a Case with regard to your Request. In the case where we declined to take action on your data rights request or have rejected your request, you may contact us to initiate an appeal of this decision. Once we receive your appeal, we will notify you in writing within 60 days of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
  • If your appeal is denied, you may contact the Office of the Virginia Attorney General by these means:
  • Office of the Attorney General | Virginia.gov
  • www.virginia.gov/agencies/office-of-the-attorney-general/#vagov
  • 202 North Ninth Street
  • Richmond, VA 23219

Notice for Nevada residents:

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

How to exercise your rights:

You may contact us at privacy@logicfusion.net to exercise your rights. Please be as specific as possible in the subject line and body of your request; otherwise, we may not be able to respond appropriately. Logic Fusion LLC is responsible for addressing your requests under the GDPR and local data protection laws. Please note that we can only ensure these rights concerning the information we physically access and store or if we have the technical capability to facilitate your rights.
7. INTERNATIONAL TRANSFERS OF PERSONAL DATA
We work in the cross-border area and provide our App to our users around the world.

We and third-party organizations that provide data processing technologies for the Services or our third-party advertising partners may transfer the processed information across borders and from your country or jurisdiction to other countries or jurisdictions worldwide.

If you are located in the European Union or other regions with laws governing data processing that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as in your jurisdiction. This means that your personal information can be transferred to a third country, a territory, or one or more specified sectors within that third country or to an international organization where data protection and confidentiality regulations may not provide the same level of personal data protection as your country does.

We try to ensure that the recipient of any Personal Data provides proper protection of the Personal Data received, in accordance with the current legislation on protecting such information. By agreeing with this Policy, you agree that we may transfer your Personal Data to any third country, a territory, or one or more specified sectors within that third country or to the international organization.

For the purposes of data processing, we recourse to the third-party services or the hosting organizations. We take your privacy seriously and, therefore, encrypt your Personal Data - if possible - before sending it to our service providers. Please note that we cooperate only with those service providers that have passed our security and reliability check. If applicable, we are party to data transfer agreements/data processing addendums or equivalent legal instruments with each of our service providers, and we will (i) keep each document up to date with current law and (ii) only engage in personally identifiable information transfers from safeguards area to outside safeguards area in accordance with such an agreement or an alternative means of transfer in compliance with data protection legislation. Where we transfer your Personal Data as described above, we will take steps to ensure that your Personal Data receive adequate security protection where it is processed, and your rights continue to be protected pursuant to the applicable data protection law, including through the use of Standard Contractual Clauses approved by the European Commission.
8. RETENTION
We generally retain your personal information for as long as necessary to achieve the purposes of processing and to comply with our legal obligations. If you uninstall the App from your mobile device, we will retain some technical identifiers for up to one year in case you decide to reinstall it.

Even if you request erasure or delete the App, some data may still be stored for a limited time (but no longer than necessary) if it is required to comply with legal obligations (such as taxation, accounting, or auditing), to maintain safety and data backup settings, to prevent fraud or other malicious acts, or to keep track of your privacy choices, such as unsubscribing from our marketing communications.
9. SECURITY
The security of your personal information is very important to us. The services we use to maintain the App adhere to generally accepted industry standards to protect the personal information submitted to us during transmission and after receipt. Please note that our App is only available for download through the Apple App Store. If you download our App from other sources, we cannot guarantee its availability, security, or proper functioning. Accessing our Services through unauthorized means will be considered improper, and we will take appropriate action to prevent such unauthorized use.

We take reasonable and appropriate measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.

We implement appropriate technical and organizational measures designed to uphold data protection principles, such as data minimization, and to integrate necessary safeguards into our processing activities. We aim to ensure that your Personal Data is encrypted using robust encryption algorithms, including hashing where applicable.

Please notice that by choosing and keeping your password carefully, not disclosing your password, and avoiding unauthorized access to your mobile device, you can help keep your information secure.

If you suspect or become aware of any security incident within the Services, please let us know at support@logicfusion.net.
10. CHILDREN'S PRIVACY
General limitation. The Services are not intended for children and we do not knowingly collect or solicit any personal information from children under 12. If we learn that we have collected personal information from a child under age 12 without verification of parental consent, we will erase that information as quickly as possible. If you believe that we might have any information from or about a child under 12, please contact us at support@logicfusion.net.

Limitations for users from the European Economic Area and the United Kingdom. The use of the Services by residents of EEA or the UK younger than 16 years old is prohibited. If you know that a person under 16 is using the Services, please contact us at support@logicfusion.net and we will take measures to delete such information and/or delete the child’s account.
11. CHANGES TO THE PRIVACY POLICY
This Privacy Policy is updated regularly.

Whenever we make changes, we will post those updates to this Privacy Policy and other relevant locations. We may also provide additional notifications about modifications or updates as deemed appropriate under the circumstances.
12. HOW TO CONTACT US
If you have any questions about this Privacy Policy, please feel free to contact us via email at privacy@logicfusion.net.