Privacy Policy

of Longevity Diet Tracker Application

LONGEVITY CENTER ONLINE SERVICES

INTRODUCTION

This Privacy Policy (“Policy”) sets out the obligations of:

LONGEVITY CENTER SP. Z O.O.

Belwederska 9

00-761 Warsaw, Poland

(“the Company”)

Contact details:

9 a.m-5 p.m.

[email protected]

+48 22 400 22 77 or +48 884 084 040

regarding data protection and the rights of its customers, user base and business associates (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company. The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

This Policy aims to ensure compliance with the GDPR and is governed by GDPR. The GDPR sets out the following principles with which any party handling personal data must comply.

LEADING INFORMATION

Processing of health data

As part of the use of our website, your health data may be collected and processed if you self-report such data by filling in our questionnaires, forms or you save or download such data in our Apps.

In principle, we only process health data provided to you on the basis of your express consent in accordance with Article 9 (2) (a)GDPR. Deviating from this, your health data may be processed in individual cases if one of the other, in Art. 9 (2) GDPR especially if:

● the processing is necessary to protect your vital interests or another natural person and you or the data subject are physically or legally unable to give their consent, or

● the processing relates to personal data that you have obviously made public, or

● the processing is necessary for the establishment, exercise or defence of legal claims or in the case of acts of the courts in the context of their judicial activity, or

● the processing is necessary for the purpose of health care, for the assessment of the employee's ability to work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health and social sector or on the basis of a contract of the data subject with a health professional and this data is provided by medical staff or by other persons, which are subject to a corresponding obligation of confidentiality, or are processed under their responsibility, or

● the processing is necessary for reasons of public interest in the field of public health, such as protection against serious cross-border threats to health or to ensure high standards of quality and safety in healthcare and in medicinal products and medical devices; or

● processing on the basis of Union law or the law of a Member State which is proportionate to the objective pursued, respects the essence of the right to data protection and provides for adequate and specific measures to safeguard the fundamental rights and interests of the data subject, for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) GDPR is required.

Data deletion and storage period

Your personal data will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in EU regulations, laws or other regulations to which we are subject.

Your personal data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage for the conclusion or fulfilment of a contract.

Security through the use of TLS/SSL

If you transmit your personal data to us via our website,we use currentsecure technologies, in particular the so-called "Transport Layer Security" (TLS) transmission (previously also known as "Secure Socket Layer" transmission (SSL)). All information and data transmitted using these secure methods is encrypted before it is sent to us. This applies in particular to all personal data of our customers,such as credit card number, bank sort code, bank account number, name and address. In order to protect you and us from misuse, the IP address of your computer is transmitted to us. We would like to point out that encryption using these technical methods only works if the corresponding technical default settings have also been initiated on your part.

Storage of cookies

In order to make your visit to our website attractive and to enable the use of certain functions, we use so-called cookies. Cookies are small text files that are automatically stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing the browser (so-called session cookies). Other cookies remain on your device and enable us to recognize your browser on your next visit (persistent cookies). The duration of the storage can be found in the overview in the cookie settings of the web browser.

In addition, we distinguish between technically necessary cookies, those that serve analysis and statistical purposes and those that serve marketing purposes. The latter concern cookies that are stored to follow visitors to websites with the intention of showing ads that are relevant and appealing to the visitor and therefore valuable to publishers and third parties advertisers.

When you visit one of our websites for the first time, a GDPR-compliant notice (also called cookie notice, cookie banner, cookie consent banner or consent banner) appears and you can choose which cookies are stored. You can also set your browser so that it is informed about the setting of cookies and decide individually on their acceptance or exclude the acceptance of cookies for certain cases or in general. Each browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how to change your cookie settings.

We expressly point out that the functionality of our website may be limited if cookies are not accepted.

If personal data is also processed by implemented cookies, which are technically necessary for the operation of our website, the processing takes place in accordance with Art. 6 para. 1 lit. f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit.

If personal data is also processed by implemented cookies, which serve statistical purposes, the processing is carried out in accordance with Art. 6 para. 1 lit. aGDPRon the basis of your consent, which you give us by making your selection decision in our consent banner. The same applies to your selection decision on preference and marketing cookies. Your consent can be revoked at any time. To do so, please send us an e-mail to [email protected]

Provision of the websites and creation of log files

Each time our website is accessed, our system automatically collects data and information from the computer system of the calling computer.

The following data is collected:

● IP address

● Browser type and browser version

● Operating system

● Date and time of the visit to the website

● Duration of the visit to the website

● Website visited

● Website/source/reference from which the visit to the website takes place

This data is not stored together with your other personal data.

The temporary storage of the IP address by the system is necessary to enable delivery of the website to your computer. For this purpose, your IP address must remain stored for the duration of the session. The storage in log files takes place to ensure the functionality of the website. In addition, the data serves us to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

This is also our legitimate interest in data processing within the meaning of Art. 6 para. 1 lit. f GDPR, which serves as the legal basis for the processing of your personal data.

The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. If the data is stored in log files, this is the case after seven days at the latest. Further storage is possible. In this case, your IP address is deleted or alienated, so that an assignment of the calling client is no longer possible.

The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection.

Use of Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google. "Google" is a group of companies and consists of Google Ireland Ltd. (provider of the service), Gordon House, Barrow Street, Dublin 4, Ireland, as well as Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, as well as other affiliates of Google LLC.

Google Analytics uses cookies that enable an analysis of the use of the website. The information generated by the cookies about your use of our website (including IP address, which is anonymized using the anonymizeIp() method so that it can no longer be assigned to a connection) is transmitted to a Google server in the USA and stored there. Google will use this information to evaluate your use of our website, to compile reports on website activity for website operators and to provide other services related to website activity and internet usage. Google may also transfer this information to third parties if this is required by law or if third parties process this data on behalf of Google. Google may associate your IP address with other Google data.

You can prevent the installation of cookies by setting your browser software accordingly. You can prevent tracking by Google Analytics by using the deactivation tools that Google offers for some Internet browsers. You can also prevent Google from collecting the data generated by Google Analytics and relating to your use of the website (including IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link:

https://tools.google.com/dlpage/gaoptout?hl=de

However, we would like to point out that if you take appropriate preventive measures, you may not be able to use all the functions of our website to their full extent.

The processing of your personal data takes place on the basis of your consent in accordance with Art. 6 para. 1 lit. a GDPR, which you give us by making your selection decision in the consent banner. By selecting the corresponding consent via our consent banner, you also agree to the transfer of the data collected about you to Google in the manner and for the purpose described above (Art. 49 (1) (a) GDPR). In particular, we would like to inform you that by giving your consent, data will be transferred to the USA and may therefore be exposed to access by the authorities there and in particular by the secret services.

Your consent can be revoked at any time. To do so, please send us an e-mail to [email protected].

Contact

If you contact us by email, the personal data you have transmitted to us with your e-mail will be stored. In addition, we have a contact form on our website with which you can contact us.

To provide the contact form, we use the WordPress plugin Contact Form, an open source software and is only used to forward entered form data to the e-mail address of our company. An additional storage, e.B. in the WordPress database, does not take place. Communication between browser and server takes place exclusively through HTTPS (SSL/TLS) encryption.

As part of the contact form, the following data entered by you in the input mask will be transmitted to us and stored: name, e-mail address, telephone number, subject and message. In addition, we collect your IP address and the time of dispatch. The data will be used exclusively to answer your request. Unless this is explicitly stated in this data protection declaration, the data will not be passed on to third parties.

The fields "Name" and "E-mail address" marked with an asterisk in the input mask are mandatory fields in which you enter the corresponding information. The indication of your name and e-mail address is required in order to send you our answer by email. The provision of further data (telephone number, subject) is not necessary to achieve the purpose pursued with the data processing and is therefore voluntary. However, the provision of this data facilitates personal communication (telephone number) and the assignment to the right contact person in our company (subject).

Since your message to us may contain health data, which may only be processed by us if you have previously given us your express consent, sending your message to us is only possible if you use the button next to the text "I am aware that my message may also contain health data within the meaning of Art. 9 para. 1 GDPR and expressly declare myself with the collection and storage of my communicated health data. agree." operate.

Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing of your name and email address. We have a legitimate interest in providing a modern method of communication and in identifying our communication partners. The processing of further personal data is based on Art. 6 para. 1 lit.a (if applicable. i.V.m. Art. 9 para. 1 GDPR ). Insofar as you wish to work towards the conclusion of a contract, Art. 6 para. 1 lit..b GDPR represents an additional legal basis for data processing, with the exception of health data.

Subject to statutory retention periods, your personal data will be deleted as soon as we have finally processed your request and if no contract is concluded with us. If you do not receive a response from us within a period of ten days,your personal data will also be deleted.

Your consent can be revoked at any time. To do so, please send us an e-mail to hello @longevity-center.eu . However, we would like to point out that your request cannot be processed further in the event of a revocation.

Data recipients

Your personal data may be passed on by us, e.B. to external service providers (e.B. IT service providers, companies that destroy or archive data, cloud providers). We only transfer your personal data to third parties if there is a right of transfer under data protection law.

The transfer of data to third parties is based either on the fulfilment of legal obligations, on legitimate interests, on the need to fulfil a contract or on the basis of any consent given. If the external service provider acts as a processor, the data transfer takes place within the framework of an order processing contract (DPA). If data transfer to processors in countries outside the European Economic Area (EEA) should be required, this will be based on the EU standard contractual clauses or to countries with regard to which an adequacy decision of the EU has been made.

DATA PROCESSING GENERAL PRINCIPLES

1. All personal data must be:

● Processed lawfully, fairly, and in a transparent manner in relation to the data subject.

● Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.

● Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

● Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.

● Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.

● Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.

DATA SUBJECTS RIGHTS

The GDPR sets out the following rights applicable to data subjects:

● The right to be informed;

● The right of access;

● The right to rectification;

● The right to erasure (also known as the ‘right to be forgotten’)

● The right to restrict processing;

● The right to data portability;

● The right to object ; and

● Rights with respect to automated decision-making and profiling

LAWFUL , FAIR AND TRANSPARENT DATA PROCESSING.

1. The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject.

2. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:

● The data subject has given consent to the processing of their personal data for one or more specific purposes;

● The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;

● The processing is necessary for compliance with a legal obligation to which the data controller is subject;

● The processing is necessary to protect the vital interests of the data subject or of another natural person;

● The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or

● The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

3. If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s genetics, epigenetics, biometrics (if used for ID purposes), historic and current and lifestyle), at least one of the following conditions must be met:

● The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);

● The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);

● The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

● The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;

● The processing relates to personal data which is clearly made public by the data subject;

● The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;

● The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;

● The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;

● The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or

● The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

SPECIFIED, EXPLICIT AND LEGITIMATE PURPOSES

1. The Company collects and processes the personal data set out in Part 21 of this Policy. This includes:

● Personal data collected directly from data subjects;

● Personal data obtained from third parties;

● Personal data obtained from accessing our services (Apps, Website)

2. The Company only collects, processes, and holds personal data for the specific purposes set out in Part 4 and 21 of this Policy (or for other purposes expressly permitted by the GDPR).

3. Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data.

4. Please refer to Part 12 for more information on keeping data subjects informed.

ADEQUATE, RELEVANT AND LIMITED DATA PROCESSING

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed).

ACCURACY OF DATA AND KEEPING DATA UP TO DATE

1. The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 14, below.

2. The accuracy of personal data shall be checked when it is collected and on regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

DATA RETENTION

1. The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.

2. When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

SECURE PROCESSING

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 22 to 27 of this Policy.

ACCOUNTABILITY AND RECORD-KEEPING

1. The Controller of personal data is the Board of Directors of the Company.

2. The Controller shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the GDPR and other applicable data protection legislation.

3. The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

● The name and details of the Company, the Controller, and any applicable third-party data processors;

● The purposes for which the Company collects, holds, and processes personal data;

● Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;

● Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;

● Details of how long personal data will be retained by the Company; and

● Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

DATA PROTECTION IMPACT ASSESSMENT

1. The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR.

2. Data Protection Impact Assessments shall be overseen by the Controller and shall address the following:

● The type(s) of personal data that will be collected, held, and processed;

● The purpose(s) for which personal data is to be used;

● The Company’s objectives;

● How personal data is to be used;

● The parties (internal and/or external) who are to be consulted;

● The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;

● Risks posed to data subjects;

● Risks posed both within and to the Company; and

● Proposed measures to minimise and handle identified risks.

KEEPING DATA SUBJECTS INFORMED

1. The Company shall provide the information set out in sec. 2 below to every data subject:

● Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and

● Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:

(i) if the personal data is used to communicate with the data subject, when the first communication is made; or

(ii) if the personal data is to be transferred to another party, before that transfer is made; or

(iii) as soon as reasonably possible and in any event not more than one month after the personal data is obtained.

The following information shall be provided:

● Details of the Company including, but not limited to, the identity of the Controller;

● The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;

● Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;

● Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;

● Where the personal data is to be transferred to one or more third parties, details of those parties;

● Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 28 of this Policy for further details);

● Details of data retention;

● Details of the data subject’s rights under the GDPR;

● Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;

● Details of the data subject’s right to complain to the President of the Personal Data Protection Office (the “supervisory authority” under the GDPR);

● Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and

● Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

DATA SUBJECT ACCESS

1. Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.

2. Employees wishing to make a SAR should do so using a Subject Access Request Form, sending the form to the Controller at [email protected].

3. Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.

4. All SARs received shall be handled by the Controller.

5. The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

RECTIFICATION OF PERSONAL DATA

1. Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

2. The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

3. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

ERASURE OF PERSONAL DATA

1. Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

● It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;

● The data subject wishes to withdraw their consent to the Company holding and processing their personal data;

● The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning the right to object);

● The personal data has been processed unlawfully;

● The personal data needs to be erased in order for the Company to comply with a particular legal obligation;

2. Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

3. In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

RESTRICTION OF PERSONAL DATA PROCESSING

1. Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

2. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

DATA PORTABILITY

1. The Company processes personal data using automated means. Using online forms and registrations.

2. Where data subjects have given their consent to the Company to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the right, under the GDPR, to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers).

3. To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following format:

4. Data file formats available .csv, excel and txt;

5. Where technically feasible, if requested by a data subject, personal data shall be sent directly to the required data controller.

6. All requests for copies of personal data shall be complied with within one month of the data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed.

OBJECTIONS TO PERSONAL DATA PROCESSING

1. Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.

2. Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

3. Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.

4. Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the GDPR, “demonstrate grounds relating to his or her particular situation”. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

AUTOMATED DECISION-MAKING

1. The Company uses personal data in automated decision-making processes. Personal data is used to provide customers with detailed insights about their health, wellbeing, and personalised services and products through Longevity Center websites, Apps, forms, questionnaires;

2. Where such decisions have a legal (or similarly significant effect) on data subjects, those data subjects have the right to challenge such decisions under the GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.

3. The right described in Part 19.2 does not apply in the following circumstances:

● The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject;

● The decision is authorised by law; or

● The data subject has given their explicit consent.

PROFILING

1. The Company uses personal data for profiling purposes.

2. When personal data is used for profiling purposes, the following shall apply:

● Clear information explaining the profiling shall be provided to data subjects, including the significance and likely consequences of the profiling;

● Appropriate mathematical or statistical procedures shall be used;

● Technical and organisational measures shall be implemented to minimise the risk of errors. If errors occur, such measures must enable them to be easily corrected; and

● All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 22 to 26 of this Policy for more details on data security).

PERSONAL DATA COLLECTED, HELD AND PROCESSED BY ONLINE SERVICES

1. The following personal data is collected, held, and processed by the Company:

● Contact information - first name, last name, telephone, email, postal address - for registration, creating accounts, processing orders, inquiries, authentication, providing services;

● Personal characteristics - age, sex;

● Health - health conditions, mental and physical state, quality of life, lifestyle , sleep, activity , diagnostics, body measurements, data from health and fitness devices - for providing services, monitoring and tracking health, progress, providing personalized recommendations, consultations, plans etc.

DATA SECURITY – TRANSFERRING PERSONAL DATA AND COMMUNICATION

1. The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

● All emails containing personal data must be encrypted;

● All emails containing personal data must be marked “confidential”;

● Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;

● Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;

● Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted using delete options within Microsoft Mail Exchange

2. Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;

3. Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient;

4. All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.

DATA SECURITY - STORAGE

1. The Company shall ensure that the following measures are taken with respect to the storage of personal data:

● All electronic copies of personal data should be stored securely using passwords and Passwords are encrypted;

● All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;

● All personal data stored electronically should be backed up weekly with backups stored onsite. All backups should be encrypted;

● No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of the Administrator and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and

● No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).

DATA SECURITY - DISPOSAL

1. When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of.

DATA SECURITY - USE OF PERSONAL DATA

1. The Company shall ensure that the following measures are taken with respect to the use of personal data:

● No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from CEO;

● No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of CEO;

2. Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;

3. If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and

4. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the CEO to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

DATA SECURITY - IT SECURITY

1. The Company shall ensure that the following measures are taken with respect to IT and information security:

● All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords;

● Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

● All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates as soon as reasonably and practically possible, unless there are valid technical reasons not to do so; and

● No software may be installed on any Company-owned computer or device without the prior approval of the CEO.

ORGANISATIONAL MEASURES

1. The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

● All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under this Policy;

● Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;

● All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;

● All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;

● All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;

● Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

● All personal data held by the Company shall be reviewed periodically;

● The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;

● All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;

● All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and

● Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

TRANSFERRING PERSONAL DATA TO THE COUNTRY OUTSIDE EEA

1. The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.

2. The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:

● The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;

● The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the President of the Personal Data Protection Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;

● The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);

● The transfer is necessary for important public interest reasons;

● The transfer is necessary for the conduct of legal claims;

● The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or

● The transfer is made from a register that, under EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

DATA BREACH NOTIFICATION

1. All personal data breaches must be reported immediately to the Controller.

2. If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Controller must ensure that the President of the Personal Data Protection Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

3. In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Controller must ensure that all affected data subjects are informed of the breach directly and without undue delay.

4. Data breach notifications shall include the following information:

● The categories and approximate number of data subjects concerned;

● The categories and approximate number of personal data records concerned;

● The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);

● The likely consequences of the breach;

● Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

IMPLEMENTATION OF POLICY

1. This Policy was updated and shall be deemed effective as of 1st of March, 2025. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

2. This Policy has been approved and authorised by the Board of Directors of the Company.

Name: Anna Limbach-Uryn

Position: Chief Commercial Officer

Date: 2024/07/19

Vitality for life

Longevity Center

Belwederska 9

00-761 Warsaw

[email protected]

T: +48 22 400 22 77

T: +48 884 084 040