Privacy Policy Medico Amico EVO

Privacy Policy
This Application collects some Personal Data from its Users.

Data Controller:
Khymeia Srl – Via San Marco 11/C – 35129 Padova (Italy) Data Controller email address: info@khymeia.com

Types of Data collected
Among the Personal Data collected by this Application, either independently or through third parties, there are: Cookies and Usage Data. Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data are collected. Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Application. Unless otherwise specified, all Data requested by this Application is mandatory. Failure to provide this Data may make it impossible for this Application to provide its Services. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability or operation of the Service. Users who have doubts about which Data are mandatory are encouraged to contact the Owner. Any use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to any other purposes described in this document and in the Cookie Policy, if available. The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he or she has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.

Methods of Processing Collected Data
The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data. Processing is carried out using computer and/or electronic means, following organizational methods and procedures strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the operation of this Application (administrative, sales, marketing, legal, and system administrators) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, and communications agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors may be requested from the Data Controller at any time.

Legal basis for processing
The Data Controller processes Personal Data relating to the User if one of the following conditions applies:

the User has given consent for one or more specific purposes; Note: Under some jurisdictions, the Data Controller may be authorized to process Personal Data without the User’s consent or any other of the legal bases specified below, until the User objects to such processing (” opt -out”). However, this does not apply if the processing of Personal Data is regulated by European data protection legislation;

– processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;
– processing is necessary for compliance with a legal obligation to which the Data Controller is subject; – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller; – processing is necessary for the pursuit of the legitimate interests pursued by the Data Controller or by third parties.

However, it is always possible to ask the Data Controller to clarify the specific legal basis for each processing and, in particular, to specify whether the processing is based on the law, provided for by a contract, or necessary to conclude a contract.

Location:
The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located. For further information, please contact the Data Controller. The User’s Personal Data may be transferred to a country other than their own. To obtain further information on the place of processing, the User can refer to the section containing details on the processing of Personal Data. The User has the right to obtain information regarding the legal basis for Data transfers outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data. If any of the transfers described above take place, the User can refer to the relevant sections of this document or request information from the Data Controller by contacting him/her using the contact details provided above.

Retention period
The Data is processed and stored for the time required by the purposes for which it was collected.
Therefore:

– Personal Data collected for purposes related to the performance of a contract between the Owner and the User will be retained until such contract has been fully performed.
– Personal Data collected for purposes related to the Owner’s legitimate interest will be retained until such interest has been fulfilled. The User may obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When processing is based on the User’s consent, the Data Controller may retain Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, Personal Data will be deleted. Therefore, upon expiration of this period, the right to access, erasure, rectification, and the right to data portability can no longer be exercised.

Purpose of Processing Collected Data
User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Interaction with social networks and external platforms and Statistics.

To obtain further detailed information on the purposes of the processing and on the Personal Data specifically relevant to each purpose, the User can refer to the relevant sections of this document.

Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:

Interaction with social networks and external platforms
This type of service allows interaction with social networks, or other external platforms, directly from the pages of this Application. The interactions and information acquired by this Application are in any case subject to the User’s privacy settings relating to each social network. If a service for interaction with social networks is installed, it is possible that, even if the Users do not use the service, it may collect traffic data relating to the pages on which it is installed.

Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network, provided by Facebook, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy. Privacy Shield participant.

YouTube button and social widgets (Google Inc.)
The YouTube button and social widgets are services allowing interaction with the YouTube social network, provided by Google Inc. Personal Data collected: Usage data. Place of processing: United States – Privacy Policy. Privacy Shield participant.

LinkedIn button and social widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network, provided by LinkedIn Corporation. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy. Privacy Shield participant.

Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to track User behavior.

Google Analytics (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected to track and examine the use of this Application, compile reports, and share them with other Google services. Google may use Personal Data to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

User Rights
Users may exercise certain rights with respect to the Data processed by the Data Controller. In particular, the User has the right to:

– withdraw consent at any time. The User may withdraw previously expressed consent to the processing of their Personal Data.
– object to the processing of their Data. The User may object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are provided in the section below. – access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing, and to receive a copy of the processed Data. – verify and request rectification. The User can verify the accuracy of their Data and request its updating or correction. – obtain restriction of processing. Under certain conditions, the User may request restriction of processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than its storage. – obtain the deletion or removal of their Personal Data. Under certain conditions, the User may request that the Data Controller delete their Data. – receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transmitted to another controller without hindrance. This provision applies when the Data is processed by automated means and the processing is based on the User’s consent, on a contract to which the User is a party, or on contractual obligations related to it. – lodge a complaint. The User can lodge a complaint with the competent data protection authority or take legal action.

Details on the right to object.
When Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users are informed that, if their Data is processed for direct marketing purposes, they can object to the processing without providing any justification. To learn whether the Data Controller processes data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to exercise your rights
To exercise your rights, Users may direct a request to the Data Controller’s contact details provided in this document. Requests are submitted free of charge and will be processed by the Data Controller as quickly as possible, in any case within one month.

Further information on processing
Defense in court
The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages leading to its establishment for the defense against abuse in the use of this Application or related Services by the User. The User declares to be aware that the Data Controller may be required to disclose the Data by order of the public authorities.

Specific information
Upon request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests
This Application does not support “Do Not Track” requests. To find out whether any third-party services it uses support them, the User is invited to consult their respective privacy policies.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to Users on this page and, if possible, on this Application and, if technically and legally feasible, by sending a notification to Users via one of the contact details available to the Data Controller. Please check this page regularly, referring to the date of the last modification indicated at the bottom.
If the changes affect processing based on consent, the Data Controller will collect the User’s consent again, if necessary.

Definitions and legal references

Personal Data (or Data)
Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data
is information collected automatically through this Application (including third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects to this Application, the URI ( Uniform Resource Identifier ) addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server’s response (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page) and the details relating to the path followed within the Application, with particular reference to the sequence of pages visited, the parameters relating to the operating system and the User’s IT environment.

User
The individual who uses this Application who, unless otherwise specified, coincides with the Data Subject.

Interested Party
The natural person to whom the Personal Data refers.

Data Controller (or Controller)
The natural person, legal person, public administration or any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools used, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application
The hardware or software tool by which the Personal Data of Users is collected and processed.

Service
The Service provided by this Application as defined in the relevant terms (if any) on this site/application.

European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.

Cookie
Small portion of data stored within the User’s device.

 

Face Tracking Data Processing

The Application uses the MediaPipe framework exclusively to detect facial landmarks required for the execution of rehabilitation exercises.

The Application does not collect, store, or process biometric face data, facial images, or any other personally identifiable facial information.

Facial landmarks are processed exclusively on the user’s device and are used solely during the execution of an exercise to enable the face tracking functionality.

This information:
• is not stored on the device;
• is not transmitted to remote servers;
• is not shared with third parties;
• is not retained after processing.

Facial landmark processing occurs entirely in real time, and the data is immediately discarded after each video frame has been processed.

Inertial Sensor Data Processing

The Application can connect via Bluetooth Low Energy (BLE) to Xsens DOT and Xsens Awinda wearable inertial sensors to acquire motion data required for rehabilitation exercises.

These sensors provide inertial measurements such as body orientation, acceleration and movement, which are used exclusively to monitor rehabilitation exercises and provide real-time feedback to the user.

The data acquired from the sensors:
• is used exclusively during the execution of the exercise;
• is not stored on the device;
• is not transmitted to remote servers;
• is not shared with third parties;
• is not retained after processing.

The inertial sensor data is processed exclusively in real time and is used solely to enable the rehabilitation functionalities provided by the Application. Once the exercise has ended, all sensor data is immediately discarded.

 

Legal References
This privacy policy is drawn up on the basis of multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679. Unless otherwise specified, this privacy policy applies exclusively to this Application.