klarify App Privacy Policy

Last update: 15 June 2020

This privacy policy provides information about how your data is processed when you download and use this “klarify” app (“app”).

If you are not happy with the terms of this privacy policy then you should stop using the app and delete it from your mobile device.

WHO ARE WE? (OUR IDENTITY & CONTACT DETAILS)

This app is provided to you, the user, by ALK e-com A/S, CVR No. 39266881, having its registered office at Bøge Allé 6-8, 2970 Hørsholm, Denmark (“ALK e-com” or “we” ).

E-Mail: support-ie@klarify.me

You can contact our Data Protection Officer via this link.

WHAT DATA IS USED & WHY

WHAT DATA WE PROCESS

We may process the following kinds of personal data about you:

First name, last name, email address, date of birth, gender, behavioural analytical data, geographical location, users’ pollen log including date and time, whether notifications are on or off, whether permission has been given to receive newsletters and any health data you have provided.

Data is usually collected directly from you. There is no obligation to provide the data if you do not want to.

HOW WE PROCESS YOUR PERSONAL DATA

In general, we only process your data where this is required for our legitimate business purposes, where we are required to do so due to relevant laws or where you provide us with your data voluntarily (i.e. by providing your consent).

We only process sensitive personal data, such as health data, where this is permitted by relevant laws or where you give us your express and informed consent.

We will not knowingly collect online data about children (minors) through the app, and in other situations we collect such data only where relevant and permitted by law.

We always need a reason ("purpose") and a legal basis, both as permitted by law, to process your personal data.

Unless specifically stated otherwise in this privacy policy, we do not process your personal data for our own use.

Any data used by the app will either be stored on your device, outside of our control, or used by Google Analytics, as described below.

When using the app, you will be asked for permission to process your data and access your location whilst using the app in order to give you more accurate air quality and pollen data and to personalise your experience while using the app. You do not have to give such permission if you do not want to, in which case your location will not be used. You can change your preference at any time in your settings. You can also download and delete the data the app has collected about you at any time in your settings, except any data we must retain for legal purposes (as detailed in the ‘ERASURE’ section below). This will not include deletion of any anonymised data used for statistical purposes.

The app will remember your settings, which you may change, and which will be deleted when you delete the app and related data from your device.

PURPOSE FOR WHICH WE WILL USE YOUR PERSONAL DATA

DATA OF THE HEALTH CARE PROVIDERS

TYPE OF DATA: contact information (such as name of the health care provider, address of the health care provider (or a place of providing health care), specialization, title, name, last name of the doctor, telephone number and e-mail address), and consultation days/hours.

PURPOSE: to provide contact details of the healthcare providers in the app for the purpose of making it easier for people with allergic symptoms to seek help at the nearest clinic/allergy service.

LEGAL BASIS: Consent. Our legitimate interest and also the legitimate interest of the app users. The legitimate interest of us is to improve, develop and provide a better personalised service to the users and the legitimate interest of the users is to have opportunity to easily find the nearest clinic/allergy service.

RETENTION PERIOD: data will only be retained for as long as you wish (see “what are your right” section below) or as long as we believe is relevant to service, whichever is the earlier. If you would like further information on our data retention periods, please contact: support-ie@klarify.me.

SOURCE OF DATA: data will be collected from the information provided in the clinic consent form.

REQUIREMENT TO PROVIDE THE DATA AND CONSEQUENCES OF NOT PROVIDING: There is not requirement for provision of these personal data. These personal data (contact information) are from the information provided by you through the clinic consent form. If you wish to change any of these information or if you wish no longer to be found in the app, please contact support-ie@klarify.me.

DATA FROM FACEBOOK AND INSTAGRAM

The following applies to the presence of ALK e-com on Facebook and Instagram (hereinafter individually or collectively for the purposes of this section iii. referred to as "these services"):

Please note that by registering on Facebook and/or Instagram, you have, among other things, given your consent to the Facebook or Instagram data policies, which also apply to the Facebook page or Instagram presence of ALK e-com A/S.

In principle, we have no influence on the data processing in these services. We would like to point out in particular that Facebook and Instagram create profiles on their own responsibility about your use of our presence there. These services use their own

analysis tool for this purpose. We receive anonymous statistics from these services. These services do not give us the possibility to deactivate this profile creation. You can find the data guidelines of Facebook here: https://www.facebook.com/policy.php. And the Instagram data policy can be found here: https://help.instagram.com/519522125107875?helpref=page_content.

If you contact us on our Facebook and/or Instagram page (by e-mail or direct message), we will process your personal data:

TYPE OF DATA: Contact details (such as name, last name, nickname, e-mail address), comments and other information you provide within our social media page (posts you mark as "I like", comments or questions you ask etc.).

PURPOSE: solely for the purpose of processing your enquiries and to provide answers to your questions or comments on our marketing communication via these services. Occasionally we embed a sign up form for our marketing communication on our Facebook page. We use your personal data exclusively to carry out the sign up process for our marketing communication and then to send you information and services tailored to your needs.

LEGAL BASIS: legitimate interest as described in the purpose.

RETENTION PERIOD: as long as needed for the purpose (data will be subject to periodic reviews).

REQUIREMENT TO PROVIDE THE DATA AND CONSEQUENCES OF NOT PROVIDING: you are not required to provide the data, and you may at any time require us not to process your personal data.

Please also note that other users can see what you post on these services and how you interact with our social media page, i.e. which posts you mark as "I like", comments or questions you ask etc. If you would like further information on how we process your personal data, please contact: support-ie@klarify.me

DURATION OF RETENTION

Data will only be retained for as long as you wish (see “what are your rights” section below) or as long as we believe is relevant to the business situation or service, whichever is the earlier.

GOOGLE ANALYTICS

This app uses Google Analytics. Please refer to “How Google uses data when you use our partners' sites or apps” for further information, (located at www.google.com/policies/privacy/partners/).

WHO WILL WE DISCLOSE YOUR PERSONAL DATA TO (RECIPIENTS OF PERSONAL DATA)

i. ALK’S EMPLOYEES & EXTERNAL PROCESSORS

The recipients of your personal data will be employees of entities belonging to ALK Group and external processors providing specific services and processing personal data on our behalf and only in accordance with our instructions. They will receive your personal data only on a need-to-know basis, being subject to the obligation of confidentiality and after signing appropriate legal documents. The complete list of entities forming ALK Group is available here. No personal data will be disclosed to third parties outside of the European Economic Area.

ii. INDEPENDENT THIRD PARTIES

We may disclose your personal data to third parties (such as attorneys) when this would be necessary for the establishment, exercise or defence of legal claims or to public authorities, when required by laws, or, when needed, to independent third party auditors.

SECURITY

We implement reasonable technical and organisational security measures to prevent unauthorised use or misuse of the app and any associated data. We also recommend that you restrict access to the mobile device on which the app is used with an access protection (e.g. pin code or fingerprint scan).

WHAT ARE YOUR RIGHTS?

If you wish to exercise any of your rights please contact us using our contact details provided at the beginning of this policy.

i. ACCESS AND RECTIFICATION

You may access your data, as well as have inaccurate data rectified. You are entitled to obtain a copy of your data, which will be provided to you in such a way as to respect the rights and privacy of other persons. You are also entitled to ask us to provide you with any relevant details concerning the processing of your personal data.

ii. DATA PORTABILITY

You are entitled to receive data you have provided to us in a portable format (structured, commonly used and machine-readable format) and to have such data transferred to you or, when feasible, directly to another entity or person you expressly choose. Please note, that the data will be provided to you in such a way as to respect the rights and privacy of other persons.

iii. RIGHT TO OBJECT

You may object to the processing of your personal data which is processed based on our legitimate interests and there is something particular about your situation which makes you want to object to processing on the grounds that you believe it impacts on your fundamental rights and freedoms. You also have the right to object when such data is processed for direct marketing purposes without giving any reasons.

iv. RIGHT TO WITHDRAW CONSENT

If you have given consent to use your personal data to us, you have the right to withdraw your consent at any time. For this purpose, you may address us at support-ie@klarify.me or please contact us using our contact details.

Your withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

v. ERASURE (‘RIGHT TO BE FORGOTTEN’)

You may ask for your personal data to be deleted and no longer processed at any time. However, we may not always be able to comply with your request for erasure for specific legal reasons (e.g. if some data still needs to be stored for tax reasons) in which case, we will notify you of these reasons and give you an indication of when that data is likely to be deleted. Note that the right to erasure does not apply to anonymous statistical data (which will not contain any personal data).

vi. RESTRICTION OF PROCESSING

Instead of erasure, you may ask to have your data restricted. Further processing of restricted data may take place only with your consent or for reasons expressly stipulated by applicable law(s).

If the restriction would not be possible, because of justified legal reasons, you will be expressly informed about such reasons, as well as before the restriction is lifted.

vii. COMPLAINTS

If you wish to complain, please contact us using our contact details or send an email at support-ie@klarify.me.

viii. RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

If you believe that the processing of your personal data infringes EU law, you are entitled to lodge complaints with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement.

CHANGES TO THIS NOTICE

This privacy policy may be updated from time to time. If we make material changes, we will notify you by means of a prominent notice in the app.