(Last updated November 19th 2020)
At Victor(y) Care, we believe that technology provides a unprecedented opportunity to empower people to take control of their health.
We fully acknowledge the great responsibility that comes with safeguarding sensitive data, such as information about your wellbeing, activities and medicines. We are committed to achieving the highest standards of privacy and security, as well as to being transparent about how we process data.
Victor(y) Care is made in Hamar, Norway, and the way we handle data meets Norwegian legal requirements and of course GDPR.
Victor(y) Care is made by Victor(y) Care AS, Steinrøysa 24, 2315, Hamar, Norway. Victor(y) Care has an appointed data protection officer, who can be contacted at firstname.lastname@example.org.
1. How we process your personal data at Victor(y) Care
Data processing is at the core of everything we do at Victor(y) Care, and whenever you use our services—e.g. when you use the Victor(y) Care app or when you go on our website—some personal and non-personal data is collected, stored, and analyzed using internal and third-party tools.
Here are the three purposes for which we process data and the type of data that is processed to fullfill each purpose:
1.1 To provide our services and understand your needs
When you use the Victor(y) Care app or when you go on our website Victor(y) Care collects, stores, and uses some personal and non-personal data and transmits it to some third-party services.
We primarily do this to provide you with our services, which may include the sending of occasional informational and promotional messages as well as reminders to your smart device via in-app messages and push notifications. We are thoughtful about what we communicate and how often. You always remain in full control of your communication preferences with Victor(y) Care. You can change the settings in the app or your device at any time.
We also do this in order to understand your needs and your use of our products, to analyze bugs and fix issues, and to bring you more useful features. In a nutshell, we process this data to provide you the best and most reliable experience of our services.
We do not process personal data that directly identifies you as a person (such as your first name, surname, email) or health-related data.
Here are the types of data we collect:
· Device data
This data informs us about the device you use to access our services, such as the model, name and identifiers, device settings, the application identifier, and crash information. On our website, we collect information about your browser and browser settings, the operating system you use, and the system settings of your device.
· Event and usage data
When you use the app or when you go our website, our servers process data in order to understand your usage of our services—for example, which pages you visit or which tab in the app you open. We collect this information and use it as aggregate data to better understand which features are the most relevant or useful to our users as whole, and to communicate with you about relevant and timely information and promotional content.
· IP address
We collect IP addresses provided by your browser or mobile device to deliver the service to your device. We also use the IP address to determine your approximate location for statistical and analytics purposes.
All the data we collect at Victor(y) Care is necessary for Victor(y) Care AS to deliver the services you use. The amount we collect has been minimized wherever possible to respect your privacy.
1.2 To deliver personalized insights as your trusted health companion
You can withdraw your consent at any time by simply deleting your account in the app. In this case, all your data will be deleted from the devise.
Here is the type of data we collect and store when you create an account:
· Personal data used for account creation
We need some of your personal data, such as your name, surname, and email address, in order to create your Victor(y) Care account.
· Health and sensitive data
We store health data, such as your wellbeing, activities and medicines you track in the app (e.g. awake, sleep, pain, discomfort). Victor(y) Care uses this data for the purpose of providing our services to you.
1.3 Track your health and communicate your wellbeing
The vision of our founders Kamilla Spangsberg Kristensen, Mads Thrane and Nishil Jain is for Victor(y) Care to help people with a long term illness to communicate their wellbeing in an objective way.
2. Your consent for processing health and sensitive data
If you create an account with Victor(y) Care, your personal data—including sensitive data and data related to your health—is stored on your device and is also stored and processed on Victor(y) Care servers. This is done so we can offer you the option of backing up your data and to enable additional features.
By creating an account with Victor(y) Care you explicitly consent that:
i. Victor(y) Care AS may store and process personal data you provide through the usage of the Victor(y) Care app and through the account creation process solely for the purpose of providing Victor(y) Care AS services to you and to improve Victor(y) Care’s service features. Such Victor(y) Care AS services may include sending you information and reminders through the Victor(y) Care app, e.g. via push notification or to the email address you provided to Victor(y) Care.
ii. Such personal data you provide to Victor(y) Care AS through the account creation process for the purpose of providing Victor(y) Care AS service includes personal data you enter into the Victor(y) Care app, such as your account data (e.g. your name and email address), and your health data which may include your wellbeing, activity and medicine information and depending on the data you provide, it may also contain information about your general health (e.g. weight, body temperature, seizure etc).
iii. Victor(y) Care AS will not transmit any of your personal data to third parties, except if it is required to provide the Victor(y) Care service to you (e.g. technical service providers), unless Victor(y) Care has asked for your explicit consent.
iv. Victor(y) Care may use your data to create anonymized sets of data for academic and research purposes. Victor(y) Care’s collaborators are individually selected through an internal vetting process. This anonymized research data cannot be linked to you as an individual or identify you in any way.
You may withdraw your consent to this use of your data at any time by deleting your Victor(y) Care account.
3. Your rights
We believe that privacy—including data privacy—is a basic human right. At Victor(y) Care we strive to ensure that your rights are respected.
Here are some key facts about your privacy that we would like you to know:
- Our products and services have been designed to minimize the use of your personal data. We only collect and process your data for the purposes that have been previously outlined.
- The security of our servers is routinely verified by experts to protect your data from unauthorized access. You can contact us at email@example.com if you have any questions about the security of our services.
- We do not retain your data in an identifiable format for longer than necessary to deliver our services.
- Victor(y) Care AS does not engage in any automated decision-making or profiling activities.
As a user of Victor(y) Care AS’s services and website, you may exercise your user rights to:
- Request information on your personal data processed by Victor(y) Care AS. Upon your request, this information will be provided to you electronically.
- Gain access to your information by requesting a backup of your data (as explained in the next section) in a format that is readable by other companies or organizations (data portability).
- Correct your personal information and health data in the app settings and in the tracking categories available in the Victor(y) Care app.
- Withdraw your consent from data processing at any time by deleting your account (as explained in the support section of the app) and/or deleting the Victor(y) Care app from your smart device, and/or unsubscribing from our newsletter by clicking the link at bottom of the email or by contacting firstname.lastname@example.org .
- Request the complete deletion of your data, including all past data sent to third-party services used for tracking and analysis, by reaching out to email@example.com. Your data will be deleted within 30 days.
- File a complaint with the relevant supervising authority if you believe Victor(y) Care is processing your personal data under violation of applicable data protection regulations.
4. Data Security
We apply security measures to protect against the misuse, loss, and/or alteration of personal information under our control. We follow industry best practices when transferring and storing your data. Though we cannot ensure or guarantee that misuse, loss or alteration of information will never occur, we use all reasonable efforts to prevent it.
4.1 How Victor(y) Care stores your personal data
If you have an account with Victor(y) Care, your personal profile data is stored separately from your wellbeing, activities and medicine data and your service settings. This allows us to ensure the highest possible level of privacy for your wellbeing information. Your password is stored using one-way encryption (“hashing” plus “salting”) and it cannot be read by us.
Important: Victor(y) Care AS uses servers located in the European Union to process and store your personal data.
Your data is transmitted between your device and Victor(y) Care AS’s servers using the HTTPS protocol for encryption. HTTPS is the same technology used to create secure connections for your web browser and is indicated by a padlock icon in the URL bar of your browser.
4.2 Victor(y) Care’s recommendations for protecting your data
We believe the biggest threat to the security and privacy of your data is if someone—probably someone you know—gains access to any of your devices. The data you enter into Victor(y) Care is private and it should stay that way. We have outlined some ways to keep your devices secure below.
Protect your Victor(y) Care account:
i. Activate a unique PIN code for the Victor(y) Care app. If you share your device with others, activating a unique PIN code will ensure you are the only person who can access your Victor(y) Care data on the device.
Protect your device:
i. Activate PIN or FaceID (iPhone X or later) authentication for your device. This automatically encrypts your Victor(y) Care data and prevents any person from using your device without your permission.
ii. Set up a feature that will allow you to erase all the data from your device if it’s been lost or stolen. For iOS, activating this feature is a two-step process: first, you need to Activate “Find My iPhone” via iCloud (see instructions on Apple Support pages) and then enable “Erase your device” (see instructions on Apple Support pages).
Back up Victor(y) Care on iOS without an account
Use Apple’s backup solution via iTunes or iCloud. See Apple’s support pages for instructions.
5. Data transfer outside the EU and to third-party applications
Any personal data collected from you may only be transferred to countries outside the European Union / the European Economic Area (EEA) observing applicable privacy regulations and ensuring that your privacy rights remain protected.
5.2 Apple Health (iOS)
Victor(y) Care will not exchange any personal data with Apple’s Health app without your prior approval. Approval is given by you in the relevant settings of the Health app or within the Victor(y) Care app via app settings and can be revoked by you at any time. If you have given your approval, Victor(y) Care may interact with the Health app on your iOS device and read and/or write information between the Victor(y) Care app and Health. This may include a transfer of your personal data to Apple servers located outside the European Union.
You can choose if and to what extent your personal data is exchanged between Victor(y) Care and Health by granting or revoking appropriate permissions in Health app settings. Please refer to the Privacy Information of Apple Health for further information.
5.3 Facebook Connect
6. Cookies and tracking
The Victor(y) Care app and our website also use third-party analysis and tracking services to track the performance of our services, understand how you use our services, and offer you an improved and safer experience.
Information on your usage of our website or of the Victor(y) Care app may be collected and processed by Victor(y) Care AS, or a third party engaged by Victor(y) Care using a unique identification number assigned to you. Information about your usage will be deleted as soon as this information is no longer required for the purpose collected, and will always be anonymized before sharing with third parties besides those mentioned under Section 6.2 to 6.8.
6.1 Your consent for Victor(y) Care tracking and analysis
You may withdraw your consent at any time, by either disabling cookies on your device or following the instructions on how to withdraw your consent individually for each third party provider Victor(y) Care uses for its third party tracking and analysis services.
For the purpose of tracking the performance of our services and to improve Victor(y) Care AS services Victor(y) Care uses the following third party services:
6.2 Google Analytics
Google analyzes this information to offer reports for Victor(y) Care on website usage and online usage of associated services. Google may also transfer this information to third parties either when this is required by law or when third parties are contracted by Google to process this data. Google will not allow your IP address to be linked to any other personal data. You can prevent cookies from being stored on your computer by changing your browser settings; however, if you choose to do this, your experience when visiting our website or using some of our features may be altered.
By using Victor(y) Care’s website, you consent to have non-personal data used and processed by Google as described above. You can withdraw consent for this use of your data at any time, but this withdrawal only applies to future activities.
6.3 Facebook Audiences
Victor(y) Care uses Facebook’s advertising and analytics products known as Facebook audiences in order to serve ads for Victor(y) Care on Facebook and Facebook-owned applications such as Instagram and on other third-party websites and in order to better understand our users and optimize the performance of our marketing campaigns. For this, Facebook uses a combination of advertising identifiers, device identifiers and meta-data in such a way that it is not possible to identify you personally.
Victor(y) Care does not in any way share data you are tracking in the app (e.g. when you get your period, what symptoms you experience) or any other personal information with Facebook.
By using our service, you explicitly consent to the use and processing of your data as described above.
7. Communications, Surveys and newsletter activities
Victor(y) Care AS uses your personal information, such as your email address, to contact you with messages, emails, and newsletters. These include push notifications, in-app messages and emails to deliver health content and occasional promotional materials that may be of interest to you.
Such services are only provided to you if you have signed up for the newsletter or given your consent for these notifications. You consent to push notifications when you activate Victor(y) Care’s push notifications in your device settings. You also consent to Victor(y) Care AS contacting you via email if you have contacted Victor(y) Care AS for questions or support requests in connection with our services or the Victor(y) Care app. You can withdraw your consent at any time. You can unsubscribe from our newsletter by clicking the unsubscribe link at the bottom of the message, and you can disable notifications sent by Victor(y) Care app in your device settings.
In order to provide these services, Victor(y) Care AS may forward information such as your email address to third-party providers in order to carry out such newsletter services, surveys or notifications.
These providers are The Rocket Science Group LLC (“MailChimp”), seated in Atlanta, USA, which may process your email address, name and usage data to send you informational and occasional commercial content via email; For customer support and communication with you, Victor(y) Care AS uses services provided by Zendesk, Inc. seated in San Francisco, USA.
8. Young users
Victor(y) Care does not knowingly collect or use personal data from children under the age of 13. By registering to a Victor(y) Care account you are required to confirm that you are at least 13 years old.
If Victor(y) Care AS gains actual knowledge that the information has been collected from children under the age of thirteen in the United States in contradiction with the Children’s Online Privacy Protection Act of 1998 and the regulation thereunder, Victor(y) Care AS will not disclose this data and reserves the right to immediately delete the account and wipe all related information, including health and sensitive data of the user, from our servers.
If you are located in the EU, you can only use our services if you are over the relevant age at which you can provide explicit consent to the processing of your data under the laws of your country or if you have the consent of your parent or legal guardian. If you are a parent and learn that your child is using Victor(y) Care App without your permission or if you have any specific question about data privacy at Victor(y) Care AS, do not hesitate to get in touch with us at firstname.lastname@example.org.