Last modified: January 2025
1. INTRODUCTION
Moony Babycare Expert Co., Ltd., a company registered and acting under
the laws of the United States with registration number 001449721, having
its registered office at 312 W 2nd St Casper, WY 82601 (“MyPulse”,
“Company”, ”we, “us”, or “our”), takes your privacy seriously. This
Privacy Policy (the “Policy”) explains our data protection commitment
and practices and describes the types of information we may process when
you use our Websites and/or install and use the MyPulse software
application for mobile devices (”the App”, “our App”).
When
we refer to personal data (or personal information), we mean any
information of any kind relating to a natural person who can be
identified, directly or indirectly, in particular by reference to such
data or to an identification number (“Personal Data”).
Our
Privacy Policy applies to all users and others who access the App
(”Users”), this website, and other Company’s websites and landing pages
(the “Website(s)”) and/or persons whose Personal Data we may process as
a result of our business activities. We also refer to such persons by
“you” in the text. The reference to the App and the Website(s) is the
“Services”.
For the purposes of the General Data Protection
Regulation (EU) 2016/679 and applicable national legislation
implementing the GDPR and, if applicable, the UK Data Protection Act
2018 and the UK GDPR (hereinafter collectively the “GDPR”), we are the
data controller, unless otherwise stated. We compiled this Privacy
Policy and adjusted our processes towards Personal Data in compliance
with GDPR as the highest standard for the protection of our users`
personal data rights.
PLEASE READ THE FOLLOWING PRIVACY
POLICY FOR INFORMATION REGARDING THE WAYS YOUR PERSONAL INFORMATION MAY
BE PROCESSED CAREFULLY.
2. SCOPE
This Privacy Policy applies to Personal Data obtained through our
Website(s), App, or when you otherwise interact with us.
The
Company’s Website and App may contain links to other websites not under
our control. We are not responsible for other websites' information
practices or content. You should always review the policies of
third-party products and services to make sure you are comfortable with
how they collect and use your information.
3. INFORMATION WE PROCESS
Your privacy is our high priority, so we prefer, to the maximum possible
extent, using instruments that disable the collection of clearly
identifiable information and provide us with information in aggregated,
encrypted, anonymized, and/or pseudonymized (non-identifiable) form.
However, we understand that some categories of such information we use
may be deemed Personal Data, in particular, for the purposes of GDPR.
With regard to such Personal Data, the rules set out in this Privacy
Policy are always strictly followed.
3.1. Information that
you submit
You may provide personal information directly when you
use our App. This information is necessary to adequately perform the
contract between you and us. Without such information, it is impossible
to provide the complete functionality of the App and perform the
requested services. Depending on the App's functionality, the following
information can be processed:
General Information. You may
fill it in when you choose to track physical parameters for your
convenience, and/or share by connecting the other app to our App:
Gender;
Date of birth or age;
Race;
Weight;
Height.
Contact Information. You may share it when you log in or create a
profile in our App or Website or contact us via email:
Name;
E-mail address, and any other content included in the email;
Password or passcode;
Other information you decide to share when you log in via third-party services; it may also include technical identifiers necessary for the authentication service to run.
Health and well-being. The App may estimate various metrics such
as:
Heart rate;
Heart rate variability;
Physical stress level;
Energy level;
Tension level;
Balance score;
Readiness score;
Sleep efficiency score;
Recovery score;
Sleep quality.
These indicators are based on RR intervals and other metrics the App
collects when executing a measurement or importing the data from Apple
Health if you decide to connect Apple Health to our App. You can always
decline to save a measurement or delete a previously saved measurement
through the App.
For measuring, the App technically accesses
your camera required as a light sensor to estimate your heart rate.
During a measurement, images from the camera feed are processed locally
on your device and deleted immediately afterward. We cannot collect,
store or use the data contained in your camera roll.
You may
also allow us to connect to third-party services, such as Apple Health,
to enable us to import Personal Data about your health and activities
into the App, as provided by its features. When you choose to have this
data imported, you are subject to Apple Health privacy policies and
practices. We may collect, once you allow us, the following data from
Apple Health:
Weight
Heart Rate Variability
Heart Rate
Date of Birth
Sleep changes
Height
Sleep
Gender
Activity and workouts
The health and well-being information you submit is stored locally on your device. If you have a MyPulse account, we transfer your health data to the server storage to provide services.
You can remove or alter your personal information at any time.
Once you uninstall the App, your personal information (including
Personal Data) will be stored and used for a period needed to achieve
the purposes set out in Section 4 of this Policy.
Information you submit via web landing pages. If you access our
landing pages on our Website, we may ask you to indicate some Personal
Data on these pages necessary to proceed with your request to get our
services. For example, you may need to indicate your age, gender,
parameters, cholesterol level, desired activities, goals etc. Please
note that we will not have access to this information, because it is not
transmitted to our service providers or databases. Instead, it is
processed locally in your web browser and deleted immediately after you
close the landing page. If you further share your email with us or
choose to install our App, we may collect and process other categories
of your Personal Data as described herein.
Information you
submit during the onboarding process in the App. Our App may include
functionality for personalizing the App prior to full access to the
App`s features. While completing the quiz, you may need to pick or
submit some categories of Personal Data, so we can personalize the App
for you. At this stage, we will not access or collect your health,
gender, age, or other sensitive information about you and it will be
processed locally on your device. Instead, we will rely on a contract
basis and our legitimate interest to process some technical identifiers
and log information necessary for the App to function and for us to
provide you with the requested service. Once you complete the onboarding
process we will ask you for your consent to process the full scope of
Personal Data for the purposes described in this Policy.
Other
data you may submit to us. Also, we may collect other data that you
submit to our Websites or App as you participate in any interactive
features of them, participate in a survey, contest, promotion,
sweepstakes, activity, or event, apply for a job, request customer
support, communicate with us via third party social media sites or
otherwise communicate with us.
Notice for employees. If you
are our current, formal, or prospective employee or individual
subcontractor, we also ask you to provide consent for collecting
education-, career-related, and other background information
(“Employment information”), which we process according to this Policy
and/or our notice related to processing recruitment data that is
provided in your contract or as a separate document by our
HR-specialists.
Other persons` Personal Data. If you are
providing information (including Personal Data) about someone else, you
must have the authority to act for them and to consent to the collection
and use of their Personal Data as described in this Privacy Policy.
3.2.
Information collected automatically
Information from the App. When
you use the App, information about your device and user behavior may be
collected and processed automatically. This information is generally
non-personal, i.e. it does not, on its own, permit direct association
with any specific individual. However, a set of this information may
allow us to identify you as a separate user of our Services, therefore
we treat such information as Personal Data and protect it as prescribed
by law. We process Personal Data based on the contract between you and
us or our legitimate interest in improving our App and giving our users
the best experience. If we do not access such data, we may not be able
to provide you with all the App`s features. To process your Personal
Data for our marketing purposes, we rely either on legitimate interest
or your consent basis, as the case may be.
Device Details.
When you use a mobile device to access our App, some details about your
device are reported subject to your privacy choices as provided by iOS
functionality. For example, device identifiers and other metadata.
Device identifiers are small data files or similar data structures
stored on or associated with your mobile device, uniquely identifying
your mobile device (but not your personality). Device identifier enables
generalized reporting and analytics. In this regard, the following
information may be collected and processed:
Information about the device itself: type of your device, type of operating system, and its version, model, and manufacturer.
Information about the internet connection: mobile carrier, IP address, timestamp, and duration of sessions.
Location-related information: IP address, the country code/ region/ state/ city associated with your SIM card or your device, language setting, and time zone.
Device identifiers and technical identifiers (e.g. IDFA).
Information about the App: name, API key (identifier for application), version, and App properties can be reported for automated processing and analysis.
Cookies and similar technologies. When you use the App, cookies and similar technologies may be used (pixels, web beacons, scripts). A cookie is a text file containing small amounts of information downloaded to your device when you access the App. The text file is sent back to the server each time you use the App. This enables us to operate the App more effectively. For example, we will know how many users access specific areas or features within our App and which links they clicked on. We use this aggregated information to understand and optimize how our App is used, improve our marketing efforts, and provide content and features that interest you. We may ask advertisers or other partners to serve ads or services to the App, which may use cookies or similar technologies.
Log file information. Log file information is automatically reported each time you request to access the App. It can also be provided when the App is installed on your device. When you use our App, analytics tools automatically record certain log file information, including the time and date when you start and stop using the App and how you interact with the App.
In-app events. When you use our App, analytics tools automatically record in-app information (tutorial steps, leveling up, payments, in-app purchases, custom events, progression events, etc.).
Please remember that some services are engaged in personal data
profiling and may obtain information related to your personality and/or
your device by using technologies that do not belong to our scope of
responsibility. For example, when your user ID is linked to your
Facebook account, Facebook may use your device information in
association with categorized data already recorded in its databases
(e.g. your age, gender or other demographic indication). We do not
control, supervise or stand surety for how the third parties process
your personal data that might be collected by their means (not through
our App). Any information request regarding the disclosure of your
personal information should be directed to such third parties.
Payment
Information. Our e-commerce providers responsible for billing,
processing, and charging for in-app purchases and web subscriptions,
handle your Personal Data and keep it safe and secure. We cannot access
or use your credit or debit card information.
Information
collected through the Website(s). When you access and use our Websites,
we may, once we obtain your consent or under another legitimate basis,
automatically process the following data:
Web Logs. As is true with most websites and services delivered over the Internet, we may gather certain information and store it in log files when you interact with our Websites. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, the information you search for, locale and language preferences, identification numbers associated with your device, your mobile carrier, and system configuration information.
Analytics information from Websites. We collect anonymized and aggregated analytics information when you use our Websites to help us improve our products and services.
Google Analytics. Our Services use Google Analytics, a web analytics service of Google Ireland Limited. The use includes the "Universal Analytics" operating mode. This facilitates the assignment of data, sessions, and interactions across several devices to a pseudonymous user ID and, thus, the analysis of a user's activities across devices. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
3.3. Information received from third parties
We may also
obtain information from third parties, such as:
Our authorized resellers, distributors, and partners if there is a lawful basis to do so. For example, we get analytic information from the Apple App Store.
Other third parties, such as email campaigns, marketing partners, and publicly available sources. We may use this information to enhance the information we already maintain about you, in addition to other purposes described in this Privacy Policy.
Social media and authentication services. We may have access to certain information from a third-party social media or authentication service if you log into our App or Website through the service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party social or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third-party service, you authorize us to access and store your name, email address(es), profile picture URL, and other information that the third-party service makes available to us, and to use and disclose it under this Privacy Policy. You should check your privacy settings on these third-party services to understand and change the information sent to us through these services.
4. THE LEGAL BASES AND PURPOSES OF PROCESSING YOUR PERSONAL DATA
Without first notifying you, we will not collect or use your Personal Data. We will handle your Personal Data using one or more of the following legal bases, depending on which features of our Services you use:
Contract. We use your Personal Data to fulfill our contractual obligations and provide the Services to you.
Consent. For example, after installing the App on the welcome screen, we may ask you to permit us to process your Personal Data.
Legitimate interest. We may process your Personal Data in relation to our interests in providing the Services to you, our legitimate commercial interests, our interest in protecting the security and integrity of the Services, and wider societal benefits, as allowed under the law.
Legal obligations. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.
Our mission is to improve our App and constantly provide new user
experiences. As part of this mission, we may use your Personal Data for
the following purposes and under the applicable legal basis:
Purpose
of processing
To make our service available
Legal basis for
processing
Contract
Example
We use your Personal Data
(measurements data, technical and device identifiers, payment
information, in-app events, other device information, IP address, App
settings information etc.) to provide you with all requested Services
Purpose
of processing
To communicate with you and send you system and
transactional messages
Legal basis for processing
Contract,
legitimate interest
Example
We use your contact and device
information to send you system notifications, and reminders, let you
know about our policies and terms, and send you billing information, if
applicable. We may use push notifications, which you can disable anytime
in your device settings or the App using the consent toggle screens, if
any. We also use your contact information to respond to you when you
contact us, to provide you with user support, and to respond to your
comments, questions, and requests related to your use or intention to
use our App.
Purpose of processing
To improve,
test, and monitor the effectiveness of our App
Legal basis for
processing
Consent, legitimate interest
Example
We use
information that is processed automatically to understand user behavior
and trends better, detect potential outages and technical issues,
operate, protect, improve, and optimize our App. We also use some
automatically collected data for content performance and features
testing (A/B testing).
Purpose of processing
To
provide you with a personalized experience within our Services
Legal
basis for processing
Consent, contract
Example
We use
your Personal Data from different sources to discover your preferences
and interests within our Services, propose personalized content, and
provide the best possible user experience
Purpose of
processing
To send promotional communications
Legal basis for
processing
Consent, legitimate interest
Example
We use
the contact information you provided to us to inform you about services,
features, surveys, newsletters, offers, promotions, contests, and events
and send updates about our App, provide other news or information about
our selected partners and us that may be interesting to you, including
by email, push notification or otherwise, as permitted by law. In cases
when we cannot refer to the legitimate interest basis according to
applicable law, we will send you marketing communications only after you
give us explicit consent to do so.
Purpose of
processing
To promote and market our App
Legal basis for
processing
Consent
Example
We use information (including
Personal Data) processed automatically, and/or obtained from (or by) our
marketing service providers or partners, to build our marketing strategy
and advertise our Services. The information we use and share for this
purpose generally does not include personally identifiable information
and never includes any health data.
Purpose of
processing
To enable interest-based (behavioral) advertising or
other targeted content
Legal basis for processing
Consent
Example
We
or our service providers may use information processed automatically for
marketing purposes (to show ads that may interest you or others based on
your preferences). Service providers we use may provide personalized
content and information to you, including online ads or other forms of
marketing. We never share your health data for this purpose. Please
refer to “How to opt-out from tracking in the App” Section below to
discover the ways of ceasing this type of advertising.
Purpose
of processing
For internal business purposes
Legal basis for
processing
Consent, legitimate interest
Example
We use
the information you submitted to us, information collected
automatically, and information we obtained from third parties for data
analysis, audits, conducting research, analysis, studies or surveys, and
identifying usage trends solely for internal business purposes. If the
results of such activities contain your Personal Data, we will anonymize
or aggregate it before disclosing them.
Purpose of
processing
To keep basic data to identify you and prevent further
unwanted processing
Legal basis for processing
Legitimate
interest
Example
If you ask us to delete your data or to be
removed from our marketing lists and we are required to fulfill your
request
Purpose of processing
To verify your
age
Legal basis for processing
Legal obligations
Example
We
may ask for your identification documents to confirm that your age
complies with our age restrictions to use our Services
Purpose
of processing
To comply with legal obligations and legal processes
and respond to requests from public and government authorities,
including public and government authorities outside your country of
residence
Legal basis for processing
Legal obligation
Example
We
may share your Personal Data to comply with our legal obligations when
we are lawfully requested to do so
Purpose of
processing
To enforce the Terms of Use, protect our operations,
protect our rights, privacy, the safety of property, and/or that of you
or others, and allow us to pursue available remedies or limit the
damages that we may sustain
Legal basis for processing
Legitimate
interest
Example
We may process your Personal Data according
to our legitimate interest when we need to provide security and safety
of data, protect our rights and fulfill our obligations before other
people and entities.
The following purpose applies solely
with regard to HR activities:
Purpose of processing
To
conduct HR activities, ensure and perform our rights and obligations as
an employer or a customer if you act as an individual contractor
Legal
basis for processing
Consent, legitimate interest
Example
We
will use the Employment information of Personal Data subjects for HR
activities and, accordingly, within the business collaboration or
employment relations, if such arises
If we need to
process your information for a specific purpose not clearly outlined in
this Policy and not concerning our ability to provide you with all
requested Services and features of the App, or a justified legitimate
interest, we will ask you for consent while amending the list of
purposes above.
Where required by law, we will only send you
marketing communications if you consent to us doing so when you provide
us with your Personal Data or if we obtain your consent to receive
marketing information separately. You may opt out of receiving such
emails by following the instructions in each promotional email we send
you or, if this doesn`t work, by contacting us at
[email protected]. We will continue to contact you via email
regarding your use of our Services and to respond to your requests only.
5. SHARING OF YOUR INFORMATION
General principles and prohibitions. We will only share your information
with third parties in the ways described in this Privacy Policy. Without
your permission, we do not share Personal Data with third parties for
their marketing purposes (including direct marketing). We do not share
identifiable health data with third parties for marketing and other
purposes not related to providing you access to our Services. We will
not rent or sell your Personal Data to any third parties.
Personnel.
We share your Personal Data only with our employees and contractors,
agents, and auditors who need to know or otherwise access Personal Data
according to their scope of professional responsibilities and who are
bound in writing by confidentiality and other obligations sufficient to
protect Personal Data under this Privacy Policy.
Protection
measures. While integrating external services, we choose service
providers that can assure they apply all necessary technical and
organizational measures to protect users` personal data. However, we
cannot guarantee the security of any information transmitted from us to
any such processor due to technical accidents that may arise out of our
reasonable control. Provided that we followed all demands of applicable
personal data protection legislation, we are not responsible for any
accidental loss or unauthorized access to your Personal Data through the
fault of third parties.
5.1. Disclosures made by you
Certain
features of our Services allow you to make some of your measurements
public, in which case it will become readily accessible to anyone. We
urge you to consider the sensitivity of any data you share at your
discretion.
5.2. Service providers and subcontractors
Processing
to make the App run
We occasionally engage outside businesses to
process your Personal Data on our behalf. They are the “processors” of
your Personal Data. Processors assist us in managing the Services,
facilitate our communication with you, and carry out other related
tasks. To complete these objectives, they may process specific Personal
Data on our behalf, acting under our instructions and subject to demands
of applicable data protection laws. To the degree applicable legislation
requires, we will execute data processing agreements with our processors
and maintain responsibility for their actions.
We may engage
the following third-party service providers to provide us with the
necessary infrastructure for the delivery and improvement of our
services:
Processor`s name and location
Amazon Web
Services EMEA SARL; EU, USA
Services
Cloud storage and
integration services
Privacy statement and Data Processing
Addendum
Privacy Statement
Data Processing Addendum
Personal data collected/shared
All Personal Data that you
submit to us and all data contained in the App, namely, User ID, name,
email, profile picture, date of profile creation, in-app events, IP
address, subscription status, individual identifiers, billing
information, subscription ID, measurements data, measurements data
source
Purpose of sharing
Storage of all Personal Data when
you use the App
Processor`s name and location
Firebase
(Google LLC); EU, USA
Services
Hosting, storage, and technical
management services
Privacy statement and Data Processing
Addendum
Privacy Policy
Cloud Data Processing Addendum
Firebase Data Processing and Security Terms
Personal data collected/shared
All Personal Data
Purpose
of sharing
Storage of all Personal Data when you use the App, cloud
computing to perform the App`s functionality
Processor`s
name and location
App Store Connect, App Store, Test Flight (Apple
Inc.), USA
Services
Technical, payment processing, and
analytics services
Privacy statement and Data Processing
Addendum
App Store & Privacy
App Analytics & Privacy
Personal data collected/shared
Payment information, personal
identifiers
Purpose of sharing
To collect and process payments
for subscription to the App, and for analytic purpose. Note that we do
not access your banking information or payment requisites when you
purchase subscriptions in the App.
Processor`s name and
location
OneSignal, Inc., USA, EU
Services
Push
notifications and analytics service
Privacy statement and Data
Processing Addendum
Privacy Policy
Data Processing Addendum - to be provided on data subject`s
demand, if applicable
Personal data collected/shared
Device
identifiers, external user IDs, and in-app events
Purpose of
sharing
To enable reminders and push-notification as part of our
App`s functionality and Services
Processor`s name and
location
SendGrid (SendGrid, Inc.), USA
Services
Email
notifications
Privacy statement and Data Processing Addendum
Privacy Policy
Data Processing Addendum
Personal data collected/shared
Email address
Purpose of
sharing
To communicate with you regarding your purchase of our
Services, send you our newsletters, surveys, and other related
notifications
Processor`s name and location
Amplitude,
Inc., USA
Services
Analytical tools
Privacy statement and
Data Processing Addendum
Privacy Notice
Data Processing Addendum
Personal data collected/shared
App usage data (e.g., device
identifiers (not Apple ID), operating system, and IP addresses)
Purpose
of sharing
To understand how you use the App and the Services,
engage with particular features and what you like or dislike the most to
engineer product experiences
Processor`s name and
location
Hotjar Ltd. (EU)
Services
Analytical tools
Privacy
statement and Data Processing Addendum
Privacy Policy
Data Processing Agreement
Personal data collected/shared
Hotjar Unique User ID;
device
screen resolution;
device type (unique device identifiers),
operating system, and browser type;
console logs and errors;
geographic
location (country only);
preferred language used to display the
Hotjar-enabled site;
mouse events (movements, location and
clicks);
keypresses (suppressed by default);
referring URL and
domain;
pages visited;
date and time when Your website was
accessed and specific event on Your website occured;
user
attributes that you may choose to share with us via Identify API
Purpose
of sharing
To understand how you use the App and the Services,
engage with particular features and what you like or dislike the most to
engineer product experiences
Processor`s name and
location
Google Analytics, Google Search Console (Google Inc,
USA)
Services
Analytical tools
Privacy statement and Data
Processing Addendum
Google Analytics Privacy
Google Ads Data Processing Terms
Google Controller-Controller Data Protection Terms
Personal data collected/shared
Google Analytics collects
first-party cookies, data related to the device/browser, IP address
(when collecting data, Google Analytics 4 does not log or store IP
addresses), on-site/app activities and advertising cookies. Cookies on
the Websites are collected upon your separate consent for the use of
cookies on your device.
Through Google Search Console we access
data about our Websites traffic. This data include type and settings of
your browser, unique identifiers.
Purpose of sharing
To
measure and report statistics about user interactions on the Websites
and in the App for further improvement of our Services
Processor`s
name and location
Stripe (Stripe, Inc.), USA
Services
Payments
Privacy
statement and Data Processing Addendum
Privacy Policy
Data Processing Agreement
Personal data collected/shared
Payment Account Details, bank
account details, billing/shipping address, name, date/time/amount of
transaction, device ID, email address, IP address/location, order ID,
payment card details, tax ID/status, unique customer identifier,
identity information including government issued documents (e.g.,
national IDs, driver’s licenses and passports) Note that Stripe does not
share your payment and banking information with us; we receive only
events and identifiers data about you and your purchases via Stripe
payment services.
Purpose of sharing
To collect and process
payments for certain web Services. Note that we do not access your
banking information or payment requisites when you purchase
subscriptions on the web
Processor`s name and
location
PayPal, Inc. and its affiliated companies
Services
Payments
Privacy
statement and Data Processing Addendum
Privacy Statement
Data Protection Addendum
Personal data collected/shared
Name, amount to be charged,
date/time, bank account details, payment card details, CVC code,
postcode, country code, address, email address, fax, phone, website,
expiry data, shipping details, tax status, unique customer identifier,
IP Address, location, and any other data received by PayPal. Note that
PayPal does not share your payment and banking information with us; we
only receive events and identifiers data about you and your purchases
via payment services.
Purpose of sharing
To collect and
process payments for certain web Services. Note that we do not access
your banking information or payment requisites when you purchase
subscriptions on the web
Processor`s name and
location
AppsFlyer (AppsFlyer, Inc), USA
Services
App
analytics services
Privacy statement and Data Processing
Addendum
Services Privacy Policy
Data Processing Addendum
Personal data collected/shared
• Technical Information, such
as: browser type, device type and model, CPU, system language, memory,
OS version, Wi-Fi status, time stamp and zone, device motion parameters
and carrier
• Technical Identifiers that generally only identify a
computer, device, browser or App. For example, device or advertising
identifiers such as IDFA (identifier for advertisers); Google Advertiser
ID; and App IDs.
• Network Generated Data such as IP address and
User agent.
Purpose of sharing
To perform analytics activities
aimed at monitoring and improving our Services
Processor`s
name and location
Google Inc, USA
Services
User
authentication services
Privacy statement and Data Processing
Addendum
Privacy&Terms
Data Processing Addendum
Personal data collected/shared
When you use Sign in with
Google to access our Services, Google only shares with us the following
information associated with your Google Account:
• Your name
•
Your email address
• Your profile picture
This data is only
shared after you give permission. If you want to use Sign in with
Google, you can't exclude any of these pieces of data.
Purpose of
sharing
To enable Sign in with Google in our Services
Processor`s
name and location
Apple Inc, USA
Services
User
authentication services
Privacy statement and Data Processing
Addendum
Apple ID & Privacy
Sign in with Apple & Privacy
Personal data collected/shared
When you use Sign in with
Apple ID to access our Services, Apple only shares with us the following
Personal Data associated with your Apple Account:
• Your email
address
This data is only shared after you give permission. If you
decide not to share with us any of your Personal Data, we will get only
a unique identifier necessary for login, which does not identify you
personally.
Purpose of sharing
To enable Sign in with Apple ID
in our Services
Processing for marketing and marketing
analytics purposes
With your consent, we may share some of your
non-health Personal Data with our marketing and promotional service
providers. We do this to market our App and Services, to help new users
find out about us, and to develop our business by increasing awareness
about the Services.
These are processors we engage for the
above purpose:
Processor`s name and location
AppsFlyer
(AppsFlyer, Inc), USA
Services
Marketing and marketing
analytics services
Privacy statement and Data Processing
Addendum
Services Privacy Policy
Data Processing Addendum
Personal data collected/shared
• Technical identifiers: IP
address (which may also provide general location information), User
agent, IDFA (Identifier for advertisers), Customer-issued user ID and
other similar unique technical identifiers;
• Engagement
Information such as: clicks on our ads, ad impressions viewed, audiences
or segments to which an ad campaign is attributed, the type of ads and
the webpage or application from which such ads were displayed, the
webpages on our Website visited by you, the URL from the referring
website, downloads and installations of the App.
• Your
subscription status;
• The fact of application launch.
Purpose
of sharing
To analyze and obtain reports of how to optimize our
marketing campaigns; for analytical purposes. In order to discover you
or users who are similar to you on other platforms, including social
networking websites, AppsFlyer may provide your Personal Data to some of
its integrated partners (such as Pinterest, Google Ads, Apple Search
Ads, FB marketing network, and others). These partners review your
Personal Data to display pertinent information about MyPulse to those
who might be interested in it or prompt you to use the App again if you
haven't in a while.
You can withdraw your consent or opt-out from
the sharing of your Personal Data with AppsFlyer for marketing and
promotional purposes anytime by adjusting your device settings.
Processor`s
name and location
Facebook (Meta), USA
Services
Analytics
/ ad management services
Privacy statement and Data Processing
Addendum
Privacy Policy
Data Processing Addendum
Personal data collected/shared
Technical identifiers and raw
data, namely, event status, event revenue, and currency, event source,
campaign ID, site ID, region, country, state, city, IP address, Customer
User ID, Advertising ID, IDFA, IDFV; data about your device, namely,
device category, platform, OS version, App version, and ID.
Purpose
of sharing
To promote our Services and obtain marketing analytics
data
Processor`s name and location
Mintegral North
America Inc., USA
Services
Marketing services
Privacy
statement and Data Processing Addendum
Privacy Pilcy and Data Protection Addendum
Personal data collected/shared
Technical identifiers and raw
data, namely, event status, event revenue and currency, event source,
campaign ID, site ID, region, country, city, IP address, AppsFlyer ID
(if applicable), Advertising ID, IDFA, IDFV; data about your device,
namely, device category, platform, OS version, App version, and ID.
Purpose
of sharing
To promote our services and place ads on the Internet
Processor`s
name and location
TikTok Pte. Ltd, Singapore
Services
Analytics
/ ad management services
Privacy statement and Data Processing
Addendum
Privacy Policy
Data processing addendum
Personal data collected/shared
Personal information accessed
or collected in connection with an event on TikTok inventory and
properties, including a user’s non-intentional interaction with our ads,
including hovering over, muting, pausing, or closing our ads; and any
derivations or combinations of such personal information
Purpose of
sharing
To promote our services and place ads on Tik Tok
platform
Processor`s name and location
Unity
Technologies S.F., (USA)
Services
Analytics / ad management
services
Privacy statement and Data Processing Addendum
Privacy Policy
Data Processing Addendum
Personal data collected/shared
• End Users data including
voice (if applicable), advertising identifiers or device IDs (e.g. IDFA
GAID), User IDs, IP address, gameplay, in-app purchase, and device data,
including device identifiers,
• Information related to the ad
content or attribution data sent by MyPulse or MyPulse`s agent
Purpose
of sharing
To promote our services and place ads on Unity
platform
Processor`s name and location
Apple
Search Ads platform (Apple Inc.), USA
Services
Analytics / ad
management services
Privacy statement and Data Processing
Addendum
Privacy Policy
General Apple Privacy Policy
Personal data collected/shared
To ensure delivering the most
relevant ads, Apple Search Ads may use the following:
• Account
Information. This includes the information a customer includes in their
Apple ID account (is not shared with MyPulse).
• App Store Data.
This includes information provided by developers to define and
categorize their apps. It also includes insights derived from
non-personal historical search terms, App Store downloads, App Store
browsing activity, and in-app purchases made through the App Store.
•
App Transaction Data. This includes historical information about users’
transactions on the App Store, including apps they’ve downloaded and
in-app purchases they’ve made.
• Contextual Information. This
includes a user’s device type, iOS version, time of day, device
location, search query, and information about the page they’re viewing,
or app they're downloading.
Purpose of sharing
To promote our
Services and place ads on Apple Search Ads platform
Processor`s
name and location
ironSource Mobile Ltd.
Services
Analytics
/ ad management services
Privacy statement and Data Processing
Addendum
Privacy Policy
Data Protection Addendum
Personal data collected/shared
Device ID, IP address, Online
unique identifiers, User ID, if provided by us
Purpose of
sharing
To promote our Services and place ads on ironSource
platform
Processor`s name and location
Google Ads
service, (Google Inc.)
Services
Analytics / ad management
services
Privacy statement and Data Processing Addendum
Google Privacy & Terms
Google Ads Data Processing Terms
Personal data collected/shared
Secure Signals; Names, email
addresses, phone numbers, addresses, client identifiers, online
identifiers, including internet protocol addresses; partner-provided
identifiers; cookie identifiers, device identifiers;
Purpose of
sharing
To promote our services and place ads on Google
Processor`s
name and location
Snapchat Ads (Snap Inc.)
Services
Advertising
services
Privacy statement and Data Processing Addendum
Snapchat Privacy Policy
Data Processing Agreement
Personal data collected/shared
Mobile ad ID (IDFA/AAID); IP
address; cookie id; browser user agent; actions and events taken on
websites and apps, including pages viewed, purchases, searches,
check-out events, wish lists, installs, and user registration
methods.
Purpose of sharing
We use this service from time to
time to promote our services and place ads
Processor`s
name and location
X (Twitter) (Twitter, Inc., Twitter International
Unlimited Company)
Services
Advertising and ad
management/analytics services
Privacy statement and Data Processing
Addendum
Privacy Policy
Data Processing Addendum
Personal data collected/shared
Conversions data - app
installs, website visits and product purchases
Purpose of
sharing
We use this service from time to time to promote our
services and place ads. Please learn how to disable targeted behavioral
advertising for X
here, or you can just limit Ads tracking on your iOS device.
Processor`s
name and location
AppLovin Corporation (USA)
Services
Advertising
and ad management/analytics services
Privacy statement and Data
Processing Addendum
Privacy Policy
Data Processing Addendum
Personal data collected/shared
Mobile device advertising
identifiers (e.g., IDFA/Google Ad ID, IP address);
Device data such
as make, model, operating system, device properties and settings, coarse
location data;
Click attribution data and transactional data;
Purpose
of sharing
We work with AppLovin to deliver ads. For more
information about AppLovin’s collection and use of your information,
visit: https://www.applovin.com/privacy/
These lists
may be amended or modified from time to time according to our business
needs, on our sole discretion and without giving notice to you, but
provided that such extension in sharing of your Personal Data do not
require your consent as legal basis for processing. If so, we will ask
you for consent while informing you of modifications for further
processing.
How to opt-out from tracking in the App
If
you don't want third-party service providers to personalize ads on the
basis of your interests, please choose option "Limit Ad Tracking" on
your iOS device in Settings/ Privacy/ Advertising, please find
additional information here: https://support.apple.com/en-us/HT202074
You
can also disable Tracking for MyPulse App in the Settings of your
phone.
Remember that when you opt out of certain
interest-based advertising, you may still receive contextual ads based
on other non-personal information, such as ads related to the content of
other digital products you are using.
Our App does not track
your precise location data.
5.3. Third-party websites and
social media widgets
Our Services may contain links to third-party
websites/services, or you may login in the App or a Website via a
third-party service. We are not responsible for the privacy practices of
these third-party sites or services linked to or from our App, including
the information or content contained within them. Our Services may also
include social media features, such as Twitter, Facebook, and Instagram
buttons. These features may collect your IP address and which page you
visit on our site and may set a cookie to enable the feature to function
properly. Your interactions with these features are governed by the
privacy statements of the company providing them.
5.4.
Business transfers, legal requirements, and protection of our rights
We
may disclose your personal information if it is needed for objective
reasons, due to the public interest, or in other unforeseen
circumstances:
to the extent permitted and as restricted by law, in response to subpoenas, court orders, or legal processes, including to meet national security or law enforcement requirements;
when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or enforce our agreements, policies, and terms of service;
if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via prominent notice in our App of any change in ownership or your personal information usage, as well as any choices you may have regarding your personal information.
Depending on the circumstances, we may rely on legitimate interest or
legal obligation as a legal basis for the above processing
activities.
5.5. Aggregated or anonymized data
We may
share aggregated or anonymized information that does not directly
identify you with other third parties, not mentioned above, such as our
partners and research entities, for statistical, analytic, and
scientific purposes. Anonymization and further use of anonymized
information are done under our legitimate interest and aimed at
contributing scientific value in our activities to increase awareness
about heart health and general well-being across society worldwide.
6. YOUR PRIVACY RIGHTS
We are committed to giving you extensive privacy rights in relation to
your Personal Data, regardless of the nation or region you are from.
This includes all individuals in the EEA, the UK and/or Switzerland.
Please
refer to Section 4 of this Policy to discover legal bases and specific
purposes for processing of your Personal Data.
Your rights
under the GDPR:
the right of access. If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of the personal data along with certain other details.
the right to rectification. If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible.
the right to erasure. You may ask us to erase your Personal Data in some circumstances, such as when we no longer need it, or you withdraw your consent. If we share your Personal Data with others, we will alert them to the need for erasure where possible.
the right to restriction of processing. You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restrictions on processing. If we share your Personal Data with others, we will tell them about the restriction where possible.
the right to data portability. You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that we processed with automated means. We will give you your Personal Data in a structured, commonly used, machine-readable format. You may reuse it elsewhere.
the right to object. You may ask us at any time to stop processing your Personal Data, and we will do so:
— if we are relying on a legitimate interest to process your Personal
Data – unless we demonstrate compelling legitimate grounds for the
processing, or your Personal Data is needed to establish, exercise, or
defend legal claims; or
— in certain circumstances, if we are
processing your Personal Data for direct marketing purposes.
the right to withdraw consent. If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
the right to make a complaint with the data protection authority. If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
Your rights under California Consumer Privacy Act of 2018 (CCPA):
The CCPA provides California residents with the right to know what categories of personal information we have collected about them and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information in Section 5 of this Policy.
“Sales” of Personal Information under the CCPA. Without limiting our ability to disclose information as described in the section of our Privacy Policy entitled “Business transfers”, for purposes of the California Consumer Privacy Act we do not and will not sell your Personal Data, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.
Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.
Your rights under Virginia Consumer Data Privacy Act (VCDPA):
Opt out of the Processing of your Personal Data for Targeted Advertising. Please note that we do not process personal data for purposes of (1) the sale of personal data, as defined by the VCDPA, or (2) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
Confirm whether your Personal Data is being Processed. You may confirm whether your personal data is being processed by emailing us.
Appeal a Case with regard to your Request. In the case where we declined to take action on your data rights request or have rejected your request, you may contact us to initiate an appeal of this decision. Once we receive your appeal, we will notify you in writing within 60 days of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
If your appeal is denied, you may contact the Office of the Virginia
Attorney General by these means:
Office of the Attorney General
| Virginia.gov
www.virginia.gov/agencies/office-of-the-attorney-general/#vagov
202 North Ninth Street
Richmond, VA 23219
Notice
for Nevada residents:
If you are a resident of Nevada, you have the
right to opt-out of the sale of certain personal information to third
parties who intend to license or sell that personal information. Please
note that we do not currently sell your personal information as sales
are defined in Nevada Revised Statutes Chapter 603A.
How to
exercise your rights:
You may contact us at [email protected]
to exercise your rights. Please be as accurate as possible in defining
the subject line and filling the body of your request email; otherwise,
we may not be able to respond to it properly. Moony Babycare Expert Co.
will be responsible for responding to your requests, including under the
GDPR and the local states data protection laws. Please bear in mind that
we ensure the above-mentioned rights only with respect to the
information that we physically access and store or if we have a
technical opportunity to ensure your rights.
7. INTERNATIONAL TRANSFERS OF PERSONAL DATA
We work in the cross-border area and provide our App and Services to our
users around the world.
We and third-party organizations that
provide data processing technologies for the Services or our third-party
advertising partners may transfer the processed information across
borders and from your country or jurisdiction to other countries or
jurisdictions worldwide.
If you are located in the European
Union or other regions with laws governing data processing that may
differ from U.S. law, please note that we may transfer information,
including personal information, to a country and jurisdiction that does
not have the same data protection laws as in your jurisdiction. This
means that your personal information can be transferred to a third
country, a territory, or one or more specified sectors within that third
country or to an international organization where data protection and
confidentiality regulations may not provide the same level of personal
data protection as your country does.
We try to ensure that
the recipient of any personal data provides proper protection of the
personal data received, in accordance with the current legislation on
protecting such information. By agreeing with this Policy, you agree
that we may transfer your personal data to any third country, a
territory, or one or more specified sectors within that third country or
to the international organization.
For the purposes of data
processing, we recourse to the third-party services or the hosting
organizations. We take your privacy seriously and, therefore, encrypt
your personal data - if possible - before sending it to our service
providers. Please note that we cooperate only with those service
providers that have passed our security and reliability check. If
applicable, we are party to data transfer agreements/data processing
addendums or equivalent legal instruments with each of our service
providers, and we will (i) keep each document up to date with current
law and (ii) only engage in personally identifiable information
transfers from safeguards area to outside safeguards area in accordance
with such an agreement or an alternative means of transfer in compliance
with data protection legislation. Where we transfer your Personal Data
as described above, we will take steps to ensure that your Personal Data
receive adequate security protection where it is processed, and your
rights continue to be protected pursuant to the applicable data
protection law, including through the use of Standard Contractual
Clauses approved by the European Commission.
8. RETENTION
We generally retain your personal information for as long as is necessary for performing the functional service of the App and to comply with our legal obligations. If you no longer want us to use your Personal Data that we physically access and store, you can either:
if you don`t have a MyPulse account, you can uninstall the App;
if you have a MyPulse account, you can delete your data by deleting your account on the profile page or in account settings in the App; or
request that we erase your personal information and close your account.
Unless you demand us otherwise, if you have a MyPulse account and don`t
delete it before uninstalling the App from your mobile device, we will
retain your Personal Data for a period of 1 year in case you decide to
re-activate the Services or re-install the App.
Even if you
requested the erasure or deleted your account or the App, some data may
still be stored for a certain time period (but no longer than the
storage purpose requires) if the information is necessary to comply with
legal obligations (taxation, accounting, audit), or in order to maintain
safety and data backup settings, prevent fraud or other malicious acts,
or keep your choices about privacy, for example, if you unsubscribed
from our marketing communications.
9. SECURITY
The security of your personal information is highly important to us.
Services we use to maintain the App follow generally accepted industry
standards to protect the personal information submitted to us, both
during transmission and once we receive it. Please note that our App is
available for download via authorized App Store (Apple App Store) only;
if you download a copy of our App via other sources, we cannot guarantee
the availability, security and proper functioning of such a product.
Your access to our Services via unauthorized means will be deemed
improper and entails us to act correspondingly to cease unauthorized
use.
We take reasonable and appropriate measures to protect
Personal Data from loss, misuse, and unauthorized access, disclosure,
alteration, and destruction, taking into account the risks involved in
the processing and the nature of the personal information.
We
implement appropriate technical and organizational measures, which are
designed to implement data-protection principles, such as data
minimization, in an effective manner and to integrate the necessary
safeguards into the processing. We seek your Personal Data to be
encrypted with proper and strong encryption algorithms, including
hashing where possible.
Please notice that by choosing and
keeping your password carefully, not disclosing your password, and
avoiding unauthorized access to your mobile device, you can help keep
your information secure. Unfortunately, no method of transmission over
the Internet or method of electronic storage is 100% secure. We do our
best to protect your personal data, but we cannot guarantee its absolute
security. In the event that your personal information is compromised as
a breach of security, we will promptly notify you in compliance with
applicable law. We will also take specific steps to address the breach
as necessary in the given situation. These steps may include logging you
out of all devices, resetting a password (sending you a temporary
password to use), and carrying out other activities and actions that are
deemed to be reasonably necessary.
If you suspect or become
aware of any security incident within the Services, please let us know
at [email protected].
10. CHILDREN'S PRIVACY
General limitation. The Services are not intended for children and we do
not knowingly collect or solicit any personal information from children
under 12. If we learn that we have collected personal information from a
child under age 12 without verification of parental consent, we will
erase that information as quickly as possible. If you believe that we
might have any information from or about a child under 12, please
contact us at support [email protected].
Limitations
for users from the European Economic Area and the United Kingdom. The
use of the Services by residents of EEA or the UK younger than 16 years
old is prohibited. If you know that a person under 16 is using the
Services, please contact us at [email protected] and we will take
measures to delete such information and/or delete the child’s account.
11. MEDICAL DISCLAIMER
11.1. The App are offered for educational and entertainment purposes
only, and in no way intended to diagnose, cure, or treat any medical or
other condition or to be a substitute for professional medical care. The
App is not a clinical pulse oximeter. If knowing your pulse rate (heart
rate) is critical to your health, you need to have your pulse taken by a
medical professional.
11.2. Moony Babycare Expert Co., Ltd.
IS NOT A LICENSED MEDICAL CARE PROVIDER. NOTHING WITHIN THE SERVICES
PROVIDED BY THE APP OR THE WEBSITE(S) IS ASSOCIATED WITH, SHOULD BE
TAKEN AS, OR UNDERSTOOD AS MEDICAL ADVICE OR ASSISTANCE, NOR SHOULD IT
BE INTERPRETED IN SUBSTITUTION FOR ANY MEDICAL ADVICE OR ASSISTANCE, OR
USED OR REFERRED TO INSTEAD OF SEEKING APPROPRIATE MEDICAL ADVICE OR
ASSISTANCE FROM HEALTH CARE PROVIDERS. PLEASE CONSULT WITH A LICENSED
PHYSICIAN OR OTHER QUALIFIED HEALTHCARE PROVIDER BEFORE MAKING ANY
DECISIONS OR TAKING ANY ACTIONS THAT MAY AFFECT YOUR HEALTH AND SAFETY
OR THAT OF YOUR FAMILY. NEVER DISREGARD PROFESSIONAL MEDICAL ADVICE OR
DELAY IN SEEKING IT BECAUSE OF SOMETHING YOU HAVE READ IN CONNECTION
WITH THE APP OR WEBSITE(S). WE DISCLAIM LIABILITY FOR ANY ERRORS OR
OMISSIONS, OR FOR UNINTENDED TECHNICAL INACCURACIES, OR TYPOGRAPHICAL
ERRORS IN THE PROVIDED MATERIALS, AS WELL AS VIOLATION OF ANY ETHICAL OR
MORAL STANDARDS APPLICABLE IN YOUR COMMUNITY TO FITNESS AND HEALTH
EDUCATION AND RELATED MATERIALS. NOTHING IN THIS AGREEMENT EXCLUDES OR
LIMITS IN ANY WAY OUR LIABILITY TO YOU WHERE IT WOULD BE UNLAWFUL TO DO
SO.
12. CHANGES TO THE PRIVACY POLICY
This Privacy Policy is updated regularly.
Whenever we change
this Privacy Policy, we will post those changes to this Privacy Policy
and other places that we consider appropriate. Additional forms of
notice of modifications or updates as appropriate under the
circumstances may be provided to you.
13. HOW TO CONTACT US
If you have any questions about this Privacy Policy, please feel free to contact us via email at [email protected].
Previous version as of January 2025