REFLEX ACTIVE APP PRIVACY POLICY
Data Privacy Policy
Version No. V1.0.8
Last updated: 22 September 2023
We take the protection of your personal data very seriously and
want you to feel secure when using our app and products. The protection of your
privacy when processing personal data is an important concern for us that we
also consider in all our business processes.
Personal data are collected, processed, and used exclusively in
accordance with legal regulations and in good faith. As far as possible, we
design our business processes in such a way that the data protection
requirements are already considered during the development of the products and
service offers and to the extent possible, personal data is pseudonymized.
Information we collect
As part of our business relationships, we process personal data
that we have received directly from you. In addition, we process personal data
which we legitimately obtain from publicly accessible sources, or which is
legitimately transmitted to us by other third parties, insofar as this data is
necessary for the provision of relevant services, we provide to you and/or within
the scope of the Purposes as set forth below.
Purposes of processing (“Purposes”) and legal basis
Your personal data will be processed in accordance with the
provisions of the GDPR and for the following purposes.
For the fulfillment of contractual obligations (Art. 6 Para. 1 b
GDPR): The processing of personal data takes place in the context of trade with
products and services in the field of consumer electronics. The Purposes of
data processing depend primarily on the specific product and its software
applications. Further details on this data processing purpose can be found in
the accompanying operating instructions, manuals and other terms and conditions
at the purchase of such specific products.
Within the framework of the balancing of interests (Art. 6 para.
1 f GDPR): If necessary, we process your data beyond the actual performance of
the contract to protect the legitimate interests of us. for the purpose of the
assertion of legal claims and defense in legal disputes; the guarantee of IT
security and the maintenance of our IT infrastructure and operation; the
prevention and clarification of criminal offenses; and for business management
purposes and the development of services and products.
Based on your consent (Art. 6 Par. 1 a GDPR): If we have your
consent to the processing of personal data for specific purposes (e.g.,
forwarding of data within the Group or evaluation of data for marketing
purposes), the legality of such processing is given based on your consent. The
given consent can be revoked at any time at our App (Settings Withdraw
Consent). The revocation of the consent does not affect the legality of the
data processed until the revocation.
Due to legal requirements (Art. 6 para. 1 c GDPR) or in the
public interest (Art. 6 para. 1 e GDPR): This includes, for example, identity
and age checks or the fulfillment of tax control and reporting obligations.
Special data protection at our Fitness tracker: We use your data
to make the use of the Fitness tracker as pleasant as possible for you and so
that you can benefit optimally from your fitness program. At the same time,
this information will improve our Service. The application stores and processes
the following data: Username, Gender, Birthday, Weight, Height, Steps, sleeping
hours, heart rates (if available), distances, calorie consumption, goals, successes,
and challenges. Your data will only be stored locally on your smartphone or
device. To ensure the compatibility of your Smart Watch with your smartphone or
device, our Smart Watch/ application accesses the following functions of your
phone:
Android
1. Read caller list
2. Taking picture and videos
3. Reading contacts
4. Receive SMS
5. Read SMS or MMS
6. Read the contents of your shared memory
7. Changing or deleting the contents of your shared memory
8. Only access the exact location when running in the foreground
9. Access the approximate location (network-based) only when
running in the foreground.
10. Accept calls
11. Retrieve phone status and identity
12. Retrieve network connections
13. Battery performance optimisations
14. Perform linking with Bluetooth devices
15. Execute foreground service
16. Access Bluetooth settings
17. Control vibration alarm
18. Access to all networks
19. Deactivate idle state
20. Play install Referrer API
iOS
1. Location
2. Photos
3. Bluetooth
4. Camera
5. Siri & search
6. Messages
7. Background update
8. Mobile data
App permissions: To provide you with the functionalities of the
app, the app must be able to access various functions and data of your mobile device.
To do this, it is technically imperative that you grant the app selected access
authorizations. Otherwise, the app cannot be used for technical reasons. Before
using the app for the first time, we will explicitly inform you of the
requested access rights. Usually the authorizations are as follows:
Location: This permission is required to determine your current
location for location-based services. This permission allows your phone to
access your GPS data, WLAN identifiers and/or Bluetooth, depending on which of
them you have enabled, to locate your location.
Push notifications: Push notifications are messages (e.g.:
WhatsApp) that are sent from the app to your device and are prioritized there.
This app uses push notifications on delivery, provided the user has consented
during the installation of the app or the first use. End user has to accept the
enable notifications for the first-time installation. Also, the reception of
push notifications can be deactivated at any time in the settings of the app.
Access smartphone contacts: This permission is required to show
the caller's name when the user received a call notification.
User behavior: Within the framework of legal regulations, we, or
companies commissioned by us, create user profiles, enter a name, or insert an
Avatar in our App. Users can click “skip” to not provide this information. The
profile data is not linked to any further information about the user. Device
information: In addition to protocol data, we may also collect information
about the device on which the app is used. These include device type, operating
system used, device settings, unique device identifiers and crash data. Whether
some or all this information is collected depends on the type of device used
and its settings. This allows error messages and system crashes to be analyzed to
improve future operation. You can find out from
https://www.gstatic.com/policies/privacy/pdf/20210701/7yn50xee/google_privacy_policy_en.pdf
how the information is processed and protected.
We are distributing our App via Apple App Store and Google Play
Store. We have also incorporated Google Maps (for Android devices), Firebase
Crashlytics, and Google Analytics in our App. GPS related sport activities and
Google Maps require Location Permissions. Firebase Crashlytics and Google
Analytics collect crash data that are not linked to any of your identity. The
purpose of use Google Maps is to provide the latitude and longitude information
from our GPS Smartwatch and to our app, then our App invoke Google Map to
display user activity trajectory on the app which is a major function of our
GPS Smartwatch. Google Analytics helps to measure and provides insight on our
Watch App usage and user engagement. Analytics integrates across Firebase
features and provides unlimited reporting for up to 500 distinct events that
you can define using the Firebase SDK. Analytics reports help you understand
users' behavior, which enables them to optimize app performance. The purpose of
using Firebase Crashlytics and Google Analytics to collect crash data is to
help to track, prioritize, and fix stability issues that erode our app quality.
Crashlytics saves our troubleshooting time by intelligently grouping crashes
and highlighting the circumstances that led up to them. Find out if a
particular crash is impacting a lot of users. Get alerts when an issue suddenly
increases in severity. Figure out which lines of code are causing crashes.
As a result, usage of our apps is also subject to the following
privacy policies:
• Apple App Store: https://www.apple.com/legal/privacy
• Google Play Store: https://policies.google.com/privacy
• Google Maps: https://policies.google.com/privacy
• Apple Maps: https://www.apple.com/legal/privacy/
• Google Crashlytics & Google Firebase Analytics: https://policies.google.com/privacy
• Open Weather: https://openweather.co.uk/privacy-policy
• Apple Health: https://www.apple.com/legal/privacy/en-ww/
• Google Fit: https://developers.google.com/fit/policy, https://policies.google.com/privacy
• Strava: https://www.strava.com/legal/privacy#full_policy
• Facebook：https://www.facebook.com/about/privacy
• Instagram：https://help.instagram.com/519522125107875
• Skype： https://support.skype.com/en/skype/all/privacy-security/
• Mailo: https://www.mailo.com/mailo/en/privacy-rules.php
Social Media: If you connect to this app via third party social
media sites (such as Facebook, Twitter, Instagram or Google+), you may be
subject to the data policy of such third-party social media sites. We do not
have access to any of your personal data stored on such third-party social
media sites.
The purpose of using weather service is that Weather is a major
function of our Smartwatch. We make use of the device longitude and latitude
information to query weather data for that location. The location information
being collected is not linked to your identity and will not be stored or used
for any other purposes. The usage of weather service and its storage duration
of data are subject to their privacy policy:
https://openweather.co.uk/privacy-policy
Data transfer to third countries or international organization
Our App is using 3rd party European based servers to provide
firmware update service. Data is transmitted to offices in countries inside the
European Union. No data will be transferred to third countries or international
organizations outside the European Union According to Article 45 GDPR,
transmission is permissible if the European Commission has decided that an
adequate level of protection exists in a third country. In the absence of such
a decision, we or the Service Provider may only transfer personal data to a
third country or to an international organization if appropriate safeguards are
provided (e.g., standard data protection clauses adopted by the Commission or
the Supervisory Authority in a particular procedure) and enforceable rights and
effective remedies are available. We have agreed contracts with these service
providers for so-called order processing, which stipulate that the principles
of data protection are always concluded with their contractual partners in
compliance with the European data protection level.
Personal data and Measurement data recorded & processed.
Username, Gender, Birthday, Weight, Height, Steps, sleeping
hours, Heart rate (if available), Running distance, Calorie consumption, Goals,
Successes and Challenges.
Data Safety
As part of the App functionality, this App may collect the
following data and upload it to your smartwatch as per your instructions and
permissions. The collected data is processed ephemerally and will not be shared
with third parties.
1. Contacts
2. Image
3. Media
4. Notifications
5. SMS
Data Protection and Limited Use
Disclosure
All data transfer and storage are encrypted
to protect this App against unauthorized or unlawful access, destruction, loss,
alteration, or disclosure.
Health Connect: The use of
information received from Health Connect will adhere to the Health Connect
Permissions policy, including the Limited Use requirements.
Storage Period
Your data is only stored on your smartphone or device. Once the
App is uninstalled, all personal data will be removed from your smartphone or
device and none of the data will be retained. The retention period of data
transmitted to third-party providers are subject to the data policy of such
third-party social media sites. We will not actively transfer your data to any
third party. The data that has been successfully transferred to a third party (e.g.:
Apple Health, Google Fit or Strava (if available)) with your permission will
follow the third-party platform and privacy policy. You can turn off third
party authorization the setting at any time and data will no longer be
transmitted. For firmware update, the data stored in European servers will be
stored during your use of our Watch App. You can contact us to delete. Once you
make a deletion request, we will delete or anonymize your information as soon
as possible, and no later than 90 days from the date of your deletion request.
The data will store around six months until a further new update is available
if a deletion request is not made.
Affected rights: Any person concerned by the processing of
personal data has the right to:
1. Information (Art. 15 GDPR),
2. Corrigendum (Art. 16 GDPR),
3. Cancellation (Art. 17 GDPR),
4. Restriction on processing (Art. 18 GDPR),
5. Data transferability (Art. 20 GDPR)
6. Opposition (Art. 21 GDPR).
There is a right of appeal to a competent data protection
supervisory authority (Art. 77 GDPR). You also have the right to lodge a
complaint with the responsible data protection supervisory authority at any
time. You can contact the responsible data protection supervisory authority
located in your country or state. You can revoke your consent to the processing
of personal data at any time. You can uninstall our App anytime if you would
like to revoke this consent. Please note that the revocation will only take
effect in the future. Processing that took place before the revocation is not
affected by this.
Automated decision making
In principle, we do not use fully automated decision making
according to Art. 22 GDPR for the establishment and implementation of the
business relationship. Should we use these procedures in individual cases, we
will inform you separately, insofar as this is required by law.
Information about your right of objection according to Art. 21
Basic Data Protection Ordinance (GDPR)
Right of objection in individual cases You have the right to
object at any time for reasons arising from your situation to the processing of
personal data concerning you, which is based on Art. 6 para. 1 e GDPR (data
processing in the public interest); this also applies to profiling based on
this provision within the meaning of Art. 4 no. 4 GDPR. If you object, we will
no longer process your personal data, unless we can prove compelling reasons
worthy of protection for the processing, which outweigh your interests, rights
and freedoms, or the processing serves to assert, exercise or defend legal
claims. Our app cannot be used if you revoke consent.
Withdraw your consent.
If you have given consent under this privacy policy to the
processing of your data by our App. You can withdraw consent from our App (Settings
Withdraw Consent-Press “OK”) and none of the data will be retained You have the
right to object at any time by writing to the following points of contact:
Notifications from the APP.
By accepting this privacy policy, you accept push notifications
from the APP which will include information about upgrades and marketing. To
opt out of receiving these notifications, you can deny permission within your
phone’s settings. By accepting this privacy policy, you accept in-app
notifications from the APP which will include information about upgrades and
marketing. To opt out of receiving these notifications, you can deny permission
within the APP’s settings.
Point of contact: If you have further questions regarding the
processing of your data or wish to exercise any of your rights under the GDPR
or pursuant to this policy, you can contact our data protection Controller at
dataprivacy.synergy@mailo.com
If you are based in Europe, you may also direct your inquiry to
the data protection officer of our representative in Europe at
dataprivacy1.synergy@mailo.com
Controller Details: Synergy Innovations Group Limited Attn: Data
Privacy Officer Room 1003, Tower 1, Lippo Centre 89 Queensway, Admiralty Hong
Kong dataprivacy2.synergy@mailo.com European Representative: A6 Europe s.a
Attn: Data Privacy Officer 127-129 Rue Colonel Bourg 1140 Brussels Belgium
dataprivacy3.synergy@mailo.com
European Representative: A6 Europe s.a Attn: Data Privacy
Officer 127-129 Rue Colonel Bourg 1140 Brussels Belgium
dataprivacy3.synergy@mailo.com
Amendments to the Privacy Policy