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App Privacy Statement

A. Privacy Statement

Bayer Consumer Care AG, Peter Merian-Strasse 84, 4052 Basel, Switzerland (hereinafter “us”, “our” and “we”), wishes to provide you with information on the processing of your personal data when you use the features of this application (“Vision Coach App”).

1. Handling of personal data

Subject to you providing your consent, we will process your personal data for the following purposes:

Account set-up and administration

We will collect and process your contact information (such as first name, last name, mailing address, email address, telephone number) and additional information (such as date of birth, responsible clinician, date of diabetes diagnosis, date of DMO diagnosis) for the purpose of setting up and administering your Vision Coach App account.

Treatment log and health diary

We will collect and process the results of your eye examinations (such as visual acuity and retinal thickness) in order to provide you and your clinician with an overview about your treatment.

Furthermore, you will be able to provide additional information about your habits, such as smoking or drinking alcohol or other activities that have an influence on your eyes and general health. This information may be shared with your clinician.

Special categories of personal data

Please note that the processing of the above mentioned personal data will involve particularly sensitive information, namely information regarding your health status, such as, but not limited to, your visual acuity, central retinal thickness and course of treatment.

On the Vision Coach App we use Google Analytics, an analytics service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States ("Google"). Google will analyse your use of the Vision Coach App on our behalf in order for us to be able to better understand how you use this App, which enables us to improve this App according to our customers' interests. The information collected by Google in connection with your use of the Vision Coach App (e.g. content of the Vision Coach App visited by you, your language settings, your operating system, your screen resolution, etc.) will be transmitted to a server of Google in the US, where it will be stored and analysed. The respective results will then be made available to us in anonymised form. Your usage data will not be connected to your full IP address during this process. We have activated the IP anonymising function offered by Google on the Vision Coach App; this will delete the last eight digits (type IPv4) or the last 80 bits (type IPv6) of your IP address. Moreover, Google is certified under the EU-US Privacy Shield, which ensures that an adequate level of data protection is maintained with respect to the processing of data by Google in the US.

Further information on Google Analytics is available in the Google Analytics Terms of Use, the Privacy and Data Protection Guidelines of Google Analytics and in the Google Privacy Policy.

We only analyse your use of this App if we have obtained your prior consent on your first access to the Vision Coach App, or if you make use of the switch to turn the app analytics on or off. You may revoke your consent at any time by sending an email to the following email address: support@visioncoach.care, or deleting your account.

2. Access and transfer of personal data

Commissioned data processing

For the processing of your personal data in the Vision Coach App, we use specialised service contractors who act as our data processors. Our data processors are carefully selected and regularly monitored by us. Based on respective data processing agreements, they will only process personal data upon our instruction and strictly in accordance with our directives.

Data Privacy firewall

In order to honour and secure your privacy, we have set up the Vision Coach App so as to ensure that we will never obtain access to, or receive your personal data in an individualised form. Instead, only our above mentioned data processors have access to your personal data in order to provide the services of the Vision Coach App to you.

We will only receive anonymised data that cannot reveal your identity to us. We will use this anonymised data to analyse the use of the Vision Coach App, in order to ensure it is continuously adding value to your treatment and the relationship between you and your clinician, and to optimise its features for that purpose.

Third parties

We will share your personal data in the Vision Coach App with the clinician of your choice for the following purpose: Subject to you providing access to your account information to a clinician of your choice, we will enable that clinician to access your Vision Coach information, including your personal data described above. For this purpose, your healthcare professional will use another application, the so-called Vision Coach Desktop.

Data location

Your personal data in the Vision Coach App will be stored in a secure cloud infrastructure of a service contractor located in London, United Kingdom. This may require your personal data to be transferred from your country of residence to a country listed here. Your personal data stored at the location of such a secure cloud infrastructure will be anonymised and transferred to another secure cloud infrastructure located in Frankfurt, Germany, where worldwide anonymised data from the Vision Coach application will be stored.

3. Retention period for personal data

Your personal data in the Vision Coach App will be stored for as long as you continue to use the Vision Coach App. We will delete your account and personal data connected with it should you cease to use the Vision Coach App for a period of three years, calculated from your last login to your account. You can delete your account at any time, in which case it will immediately be marked as deleted and your associated personal data deleted from all Vision Coach App systems after a period of 30 days.

4. Information regarding your rights

You have the right to request information from us concerning your personal data in the Vision Coach App, access to and rectification or erasure of personal data or restriction of processing concerning you, or to object to processing as well as the right to data portability. You also have the right to lodge a complaint with the data protection supervisory authority. You may at any time revoke your consent without affecting the lawfulness of processing before the withdrawal.

You are not obliged to provide your personal data and there will be no adverse consequences for you if you do not provide your personal data, provided that you do not use the features of the Vision Coach App.

Due to the above described data privacy firewall, we will not be able to identify you and will therefore not be able to handle your requests personally. Therefore, for any questions you may have with respect to data privacy and/or your consent, or if you wish to exercise your rights, please contact our commissioned data processor, who we have instructed to handle your requests on our behalf: Healthforge, 71A Great Percy Street, London WC1X 9QX (visioncoach@healthforge.io).

B. Declaration of consent

You hereby consent to Bayer Consumer Care AG, Peter Merian-Strasse 84, 4052 Basel, Switzerland (hereinafter “us”, “our” or “we”) processing your personal data for the purpose of setting up and administering your Vision Coach App account and for providing the functionalities of the Vision Coach App, namely to record and evaluate the results of your eye examinations, your habits that could potentially influence your health as well as your course of treatment, for use by you and the clinician, whom you chose to give access to your Vision Coach information, as described in more detail in the Privacy Statement.

Please note that the processing of your personal data involves particularly sensitive information, namely information regarding your health status, such as, but not limited to, your visual acuity, central retinal thickness and course of treatment.

You are free to revoke your consent at any time with future effect, and your data will be deleted after 30 days. Please address your declaration of revocation using the contact information found in the Privacy Statement.

Additionally, we would like to better understand your use of the Vision Coach App and ask you to consent to our use of Google Analytics. This enables us to improve your and other users' future experience using it. Detailed information on how you can manage or withdraw your consent at any time can be found in our Privacy Statement.