Privacy Policy
1. Data Privacy Policy
We value your privacy and are committed to protect your Personal Information in accordance with the guidelines of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data, the free movement of data and the lifting of Directive 95/46 / EC). We understand it is important to you and we want you to know how we collect, use, share, and protect your information. This Privacy Policy tells you what information we collect from visitors of websites owned and users of mobile applications and Service owned and controlled by SCARLETRED, how we use that information, how we may share that information, how we protect your information, and your choices regarding your Personal Information. It is important that you read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat and safeguard your information. This Privacy Policy applies to our Products and Service. This Privacy Policy does not extend to websites operated by third parties or other offline sources. SCARLETRED is therefore not liable for their privacy policies, procedures and practices. This Privacy Policy may be updated at any time. When the Privacy Policy is changed, modified, and/or amended, the revised Privacy Policy will be posted on our app and the effective date will be noted. You accept any such modifications to this Privacy Policy by continued use of our app after such modifications are made; provided however, you have the right to refuse and reject such amendment for 30 days after its effectuation and terminate the agreement. By accessing or using our Product and Service you agree to this Privacy Policy. If you do not agree with the terms of this privacy, please do not use our Product or other Service.
1.1 Information we collect
While most of our services are completely anonymous to you, others require the collection of two categories of information from our users: (1) personal information and (2) general information. Some of our Services require to collect two categories of information from users: (1) Personal Information and (2) General Information. “Personal Information” is information through which you can be personally identified. Personal Information that we collect may include your full name, e-mail address, age, phone number, organization, profession, gender and any other information or data that you provide when using our software Products or Service. We only collect Personal Information that you voluntarily provide to us, including through registrations, order information, applications, surveys or other inquiries. In rare exceptional cases, we collect a special category of personal data from you, namely health data. Your health data is not collected and processed automatically, but must be actively provided by you in the course of using special software services such as initialized by using the eCOVID19 questionnaire and it serves only to protect the vital interests of the person concerned or if necessary for the protection of another natural person. If after this step a direct contact with a medical expert via one of our services is desired and established for you, you will also be asked also to transfer your current geolocation, this additional action must be carried out by you actively and therefore with renewed consent. In very special and thus very exceptional cases, such as in order to prevent the spread of life-threatening infectious disease, this geolocation data can also be processed in other ways, such as to protect others. We do not collect information that would identify you unless you choose to actively provide it to us a part of one of our Services. You can choose not to provide us with certain information, but please be aware that may impact the Service provided to you. “General Information” is information we obtain automatically from your connection, interaction with our software Products and Service and the use of Cookies and other technologies. General information does not identify you personally. General information we collect when you use our App may include but is not limited to the domain and host from which you access the Internet, the Internet protocol address of the computer or smartphone you are using (“IP Address”), the browser software you are using, the operating system you are using, the date and time that you access our App, the specific pages or features you use, and the number of visits you make to our App.
1.2 How we use your Information
We may use your Personal Information to provide Products and Service to you, including the App, respond to your inquiries, provide information on Products and Service or have a representative contact you regarding our Products or Service. Unless you have otherwise opted out of receiving email communication from us, you agree by using the App or Service, to allow us to use your email for customer communication and provision of Service consistent with this Privacy Policy, when the law permits us to do so. We may also use your Personal Information to update you on special offers related to our Products or Service, and to improve our Products and Service. Similarly, we may use your Personal Information to provide product announcements, information regarding health topics, or to deliver other information we believe you may consider informative or useful. Furthermore, we may also use your Personal Information in any other way that we may describe to you when you provide the information to us or to which you consent. We may occasionally contact you to gather customer service information to help us determine how we can improve our Service and products to better meet your needs. Because we provide Products and Service for the coordination or management to health, wellness and related clinical research Service, we collect the sort of personal and medical information needed in order to further develop and provide our Products and Service.
In this context, we can also use data that we collect about our users of the app and / or platform for various business, scientific and / or research-related purposes including Product development, Service development or software program development and software program improvement. We may combine or cross-reference your Personal Information with other information we acquire about you directly or through third party sources, (e.g. Apple, Google) to help customize the information, Products or Service we provide to you. By accepting this Privacy Policy, you allow us to combine and cross-reference your information. Only those employees who need access to your Personal Information to fulfil their employment duties will have access to it. We may use tools to collect information about use of our Apps, Platform or Website including but not limited to, Google Analytics or other similar Service. Such tools collect anonymous information regarding how users use our App or Platform, what information they view when they do so, and what other sites and/or apps our users have used prior to coming to our App, Platform or Website. We use the information we get from such tools only to improve our Products and Service, tailor content, deliver a better user experience and manage our advertising and campaigns. Google’s use of information it acquires about you or your use of SCARLETRED is governed by Google Analytics Terms of Use and the Google Privacy Policy. We may also collect, aggregate and maintain anonymous information about the visitors to our mobile App and Platform and share such aggregate information with advertisers, business partners, sponsors and other Third-Parties. With respect to the collection and use of General Information, you have the ability to disable or manage the use of cookies on your computer using controls in your browser. However, you are not able to opt out of the uses of General Information otherwise collected as set forth in this policy. Please note that certain features may not be available when cookies are disabled. Please see the Third-Party Websites and Ad Service section below to learn more about opting out of certain advertisement Service.
1.2.1 Data Deletion
You may request deletion of your account and Personal Information at any time by contacting our support desk at support.scarletred.com, or by emailing support@scarletred.com. We verify your identity and process deletion requests in line with GDPR, HIPAA (where applicable), and other relevant laws. Some data may be subject to mandatory retention under law, regulatory obligation, contractual commitment, or clinical research requirements (for example, records tied to an active clinical trial). Where this applies, we will tell you which data is retained and why.
1.2.2 Data Retention
We retain Personal Information only as long as necessary to provide the service, comply with legal and regulatory obligations (including clinical-record and quality-management requirements under ISO 13485:2016), resolve disputes, and enforce our agreements. Where retention periods are set by law or regulation or sponsors, we will inform you of the applicable period on request.
1.3 With whom we share your Information
Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not sell or rent your Personal Information to third parties or disclose any Personal Information we gather from you on through our App or Platform to Third-Parties. In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of SCARLETRED, in whole or in part, your information may be transferred as part of the transaction, including during the due diligence process, as long as, the party acquiring such information agrees to be bound by the terms of this Privacy Policy. We may also release your Personal Information to third parties as required by law, when we believe disclosure is necessary to comply with a legal or regulatory requirement, judicial proceeding, court order or legal process served on us, to protect the safety, rights or property of patients, customers, the public or SCARLETRED or defend SCARLETRED and its officers, directors, employees, attorneys, agents, contractors and partners, in connection with any legal action, claim, or dispute.
1.4 How we keep your Information Secure
Your Personal Information is stored on servers hosted within the European Union according to The General Data Protection Regulation (GDPR) (EU) 2016/679 which entered into force in the EU on 25 May 2018. We may add additional server locations in other regions by applying world leading EU data protection standards. We seek to safeguard the security of your Personal Information and have implemented reasonable security measures consistent with applicable laws, safe harbors, and accepted practices in the healthcare industry to protect the confidentiality of your Personal Information. We have put in place a variety of information security measures to protect your Personal Information, including encryption technology, to protect your Personal Information during data transport and at rest. We limit the access to your Personal Information to employees who needs it for the execution of their duties. Despite our efforts, however, we cannot guarantee the absolute security of your Personal Information, nor can we guarantee that information that you provide will not be intercepted while being transmitted to us over the Internet. There is always some residual risk that an unauthorized third party may find a way around our security systems or that transmissions of your Personal Information over the Internet will be intercepted. Therefore, we urge you to also take every precaution to protect your Personal Information when you are on the Internet or using the App and/or the Platform. Hence never share your username or password and always log out of the App or/and the Platform when you are finished using the service. We will store and maintain your information in accordance with this Privacy Policy and as required to provide you Service through the App and/or the Platform and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
1.5 Right to acces and correct
On written request and subject to proof of identity, you may consult the Personal Information that we have collected, and ask that any necessary corrections be made, where applicable, as authorized or required by law. However, to make sure that the Personal Information we maintain about you is accurate and up to date, please inform us immediately of any change in your Personal Information with the information at the bottom of this Privacy Policy.
1.6 Updates
Our Privacy Policy may be updated from time to time to reflect changes made to our practices. We therefore invite you to use our Product and Services from time to time to stay informed of the latest developments. The date of the last update is the one that appears at the top of this Privacy Policy.
1.7 Other Important Notices
If received, we remove your identity from your Personal Information (contact, health and/or financial) and may work with it as anonymous (“de-identified”) information. De-identified individual information is information about a user presented in a form where information about one anonymous user would be indistinguishable from information relating to other anonymous users. De-identified individual information is not in a form that allows anyone studying the information to personally identify any user. E-Mail communications: Do not send e-mail communications containing personal health information to us. We cannot secure any Personal Information sent by e-mail because such information can be accessed also by other internet users. If you send us a question by e-mail, our use and disclosure of that information will be limited to the minimum necessary to respond to your question. Third-Party Websites and Ad Service: Please be aware that our App may have links to third-party websites that may collect Personal Information about you. When you click on one of these third-party links, you are entering another website. We encourage you to read the privacy policies of all such websites since their privacy policies may be materially different than our Privacy Policy. Aggregate information is information that describes the habits, usage patterns and/or demographics of users as a group but does not reveal the identity of particular users. Your anonymous data is combined with the anonymous data of other users and becomes statistics. We may use aggregate information to understand the needs of our user community and determine what kinds of our Products and Services we can offer to you. Aggregate information may be also provided or sold to third parties. Absolutely no personal identifying information is included in the aggregate reports; each individual remains anonymous. Locator information is your name, e-mail address, physical address, and/or other data that enables someone to personally identify you. We may use locator information as is necessary to enforce any of the terms of this Privacy Policy. Law Enforcement and Protection of Users and the Site: To the extent permitted by law, we may disclose Personal Information to governmental authorities or third parties pursuant to a legal request, subpoena or other legal process. We may also use or disclose your Personal Information as permitted by law to apply or enforce this Privacy Policy, or protect our rights, interest, or property as well as those of our affiliates, customers. Following such disclosure to any third party, your Personal Information may be accessible by others to the extent permitted or required by applicable law.
1.8 Contact Information
Please send any comment, question or complaint regarding our Privacy Policy or any request to access or correct your Personal Information by mail or email using the following contact information. You may also send written requests to rescind your consent to our use of your information to the below contact information:
SCARLETRED Holding GmbH
Media Quarter Marx 3.4
Maria Jacobi Gasse 1, 8th floor
1030 Vienna, Austria
office@scarletred.com
Commercial registration number: FN 420719 f
Court of jurisdiction: Vienna (Austria)
VAT: ATU68970624
We value your privacy and are committed to protect your Personal Information in accordance with the guidelines of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data, the free movement of data and the lifting of Directive 95/46 / EC). We understand it is important to you and we want you to know how we collect, use, share, and protect your information. This Privacy Policy tells you what information we collect from visitors of websites owned and users of mobile applications and Service owned and controlled by SCARLETRED, how we use that information, how we may share that information, how we protect your information, and your choices regarding your Personal Information. It is important that you read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat and safeguard your information. This Privacy Policy applies to our Products and Service. This Privacy Policy does not extend to websites operated by third parties or other offline sources. SCARLETRED is therefore not liable for their privacy policies, procedures and practices. This Privacy Policy may be updated at any time. When the Privacy Policy is changed, modified, and/or amended, the revised Privacy Policy will be posted on our app and the effective date will be noted. You accept any such modifications to this Privacy Policy by continued use of our app after such modifications are made; provided however, you have the right to refuse and reject such amendment for 30 days after its effectuation and terminate the agreement. By accessing or using our Product and Service you agree to this Privacy Policy. If you do not agree with the terms of this privacy, please do not use our Product or other Service.
1.1 Information we collect
While most of our services are completely anonymous to you, others require the collection of two categories of information from our users: (1) personal information and (2) general information. Some of our Services require to collect two categories of information from users: (1) Personal Information and (2) General Information. “Personal Information” is information through which you can be personally identified. Personal Information that we collect may include your full name, e-mail address, age, phone number, organization, profession, gender and any other information or data that you provide when using our software Products or Service. We only collect Personal Information that you voluntarily provide to us, including through registrations, order information, applications, surveys or other inquiries. In rare exceptional cases, we collect a special category of personal data from you, namely health data. Your health data is not collected and processed automatically, but must be actively provided by you in the course of using special software services such as initialized by using the eCOVID19 questionnaire and it serves only to protect the vital interests of the person concerned or if necessary for the protection of another natural person. If after this step a direct contact with a medical expert via one of our services is desired and established for you, you will also be asked also to transfer your current geolocation, this additional action must be carried out by you actively and therefore with renewed consent. In very special and thus very exceptional cases, such as in order to prevent the spread of life-threatening infectious disease, this geolocation data can also be processed in other ways, such as to protect others. We do not collect information that would identify you unless you choose to actively provide it to us a part of one of our Services. You can choose not to provide us with certain information, but please be aware that may impact the Service provided to you. “General Information” is information we obtain automatically from your connection, interaction with our software Products and Service and the use of Cookies and other technologies. General information does not identify you personally. General information we collect when you use our App may include but is not limited to the domain and host from which you access the Internet, the Internet protocol address of the computer or smartphone you are using (“IP Address”), the browser software you are using, the operating system you are using, the date and time that you access our App, the specific pages or features you use, and the number of visits you make to our App.
1.2 How we use your Information
We may use your Personal Information to provide Products and Service to you, including the App, respond to your inquiries, provide information on Products and Service or have a representative contact you regarding our Products or Service. Unless you have otherwise opted out of receiving email communication from us, you agree by using the App or Service, to allow us to use your email for customer communication and provision of Service consistent with this Privacy Policy, when the law permits us to do so. We may also use your Personal Information to update you on special offers related to our Products or Service, and to improve our Products and Service. Similarly, we may use your Personal Information to provide product announcements, information regarding health topics, or to deliver other information we believe you may consider informative or useful. Furthermore, we may also use your Personal Information in any other way that we may describe to you when you provide the information to us or to which you consent. We may occasionally contact you to gather customer service information to help us determine how we can improve our Service and products to better meet your needs. Because we provide Products and Service for the coordination or management to health, wellness and related clinical research Service, we collect the sort of personal and medical information needed in order to further develop and provide our Products and Service.
In this context, we can also use data that we collect about our users of the app and / or platform for various business, scientific and / or research-related purposes including Product development, Service development or software program development and software program improvement. We may combine or cross-reference your Personal Information with other information we acquire about you directly or through third party sources, (e.g. Apple, Google) to help customize the information, Products or Service we provide to you. By accepting this Privacy Policy, you allow us to combine and cross-reference your information. Only those employees who need access to your Personal Information to fulfil their employment duties will have access to it. We may use tools to collect information about use of our Apps, Platform or Website including but not limited to, Google Analytics or other similar Service. Such tools collect anonymous information regarding how users use our App or Platform, what information they view when they do so, and what other sites and/or apps our users have used prior to coming to our App, Platform or Website. We use the information we get from such tools only to improve our Products and Service, tailor content, deliver a better user experience and manage our advertising and campaigns. Google’s use of information it acquires about you or your use of SCARLETRED is governed by Google Analytics Terms of Use and the Google Privacy Policy. We may also collect, aggregate and maintain anonymous information about the visitors to our mobile App and Platform and share such aggregate information with advertisers, business partners, sponsors and other Third-Parties. With respect to the collection and use of General Information, you have the ability to disable or manage the use of cookies on your computer using controls in your browser. However, you are not able to opt out of the uses of General Information otherwise collected as set forth in this policy. Please note that certain features may not be available when cookies are disabled. Please see the Third-Party Websites and Ad Service section below to learn more about opting out of certain advertisement Service.
1.2.1 Data Deletion
You may request deletion of your account and Personal Information at any time by contacting our support desk at support.scarletred.com, or by emailing support@scarletred.com. We verify your identity and process deletion requests in line with GDPR, HIPAA (where applicable), and other relevant laws. Some data may be subject to mandatory retention under law, regulatory obligation, contractual commitment, or clinical research requirements (for example, records tied to an active clinical trial). Where this applies, we will tell you which data is retained and why.
1.2.2 Data Retention
We retain Personal Information only as long as necessary to provide the service, comply with legal and regulatory obligations (including clinical-record and quality-management requirements under ISO 13485:2016), resolve disputes, and enforce our agreements. Where retention periods are set by law or regulation or sponsors, we will inform you of the applicable period on request.
1.3 With whom we share your Information
Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not sell or rent your Personal Information to third parties or disclose any Personal Information we gather from you on through our App or Platform to Third-Parties. In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of SCARLETRED, in whole or in part, your information may be transferred as part of the transaction, including during the due diligence process, as long as, the party acquiring such information agrees to be bound by the terms of this Privacy Policy. We may also release your Personal Information to third parties as required by law, when we believe disclosure is necessary to comply with a legal or regulatory requirement, judicial proceeding, court order or legal process served on us, to protect the safety, rights or property of patients, customers, the public or SCARLETRED or defend SCARLETRED and its officers, directors, employees, attorneys, agents, contractors and partners, in connection with any legal action, claim, or dispute.
1.4 How we keep your Information Secure
Your Personal Information is stored on servers hosted within the European Union according to The General Data Protection Regulation (GDPR) (EU) 2016/679 which entered into force in the EU on 25 May 2018. We may add additional server locations in other regions by applying world leading EU data protection standards. We seek to safeguard the security of your Personal Information and have implemented reasonable security measures consistent with applicable laws, safe harbors, and accepted practices in the healthcare industry to protect the confidentiality of your Personal Information. We have put in place a variety of information security measures to protect your Personal Information, including encryption technology, to protect your Personal Information during data transport and at rest. We limit the access to your Personal Information to employees who needs it for the execution of their duties. Despite our efforts, however, we cannot guarantee the absolute security of your Personal Information, nor can we guarantee that information that you provide will not be intercepted while being transmitted to us over the Internet. There is always some residual risk that an unauthorized third party may find a way around our security systems or that transmissions of your Personal Information over the Internet will be intercepted. Therefore, we urge you to also take every precaution to protect your Personal Information when you are on the Internet or using the App and/or the Platform. Hence never share your username or password and always log out of the App or/and the Platform when you are finished using the service. We will store and maintain your information in accordance with this Privacy Policy and as required to provide you Service through the App and/or the Platform and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
1.5 Right to acces and correct
On written request and subject to proof of identity, you may consult the Personal Information that we have collected, and ask that any necessary corrections be made, where applicable, as authorized or required by law. However, to make sure that the Personal Information we maintain about you is accurate and up to date, please inform us immediately of any change in your Personal Information with the information at the bottom of this Privacy Policy.
1.6 Updates
Our Privacy Policy may be updated from time to time to reflect changes made to our practices. We therefore invite you to use our Product and Services from time to time to stay informed of the latest developments. The date of the last update is the one that appears at the top of this Privacy Policy.
1.7 Other Important Notices
If received, we remove your identity from your Personal Information (contact, health and/or financial) and may work with it as anonymous (“de-identified”) information. De-identified individual information is information about a user presented in a form where information about one anonymous user would be indistinguishable from information relating to other anonymous users. De-identified individual information is not in a form that allows anyone studying the information to personally identify any user. E-Mail communications: Do not send e-mail communications containing personal health information to us. We cannot secure any Personal Information sent by e-mail because such information can be accessed also by other internet users. If you send us a question by e-mail, our use and disclosure of that information will be limited to the minimum necessary to respond to your question. Third-Party Websites and Ad Service: Please be aware that our App may have links to third-party websites that may collect Personal Information about you. When you click on one of these third-party links, you are entering another website. We encourage you to read the privacy policies of all such websites since their privacy policies may be materially different than our Privacy Policy. Aggregate information is information that describes the habits, usage patterns and/or demographics of users as a group but does not reveal the identity of particular users. Your anonymous data is combined with the anonymous data of other users and becomes statistics. We may use aggregate information to understand the needs of our user community and determine what kinds of our Products and Services we can offer to you. Aggregate information may be also provided or sold to third parties. Absolutely no personal identifying information is included in the aggregate reports; each individual remains anonymous. Locator information is your name, e-mail address, physical address, and/or other data that enables someone to personally identify you. We may use locator information as is necessary to enforce any of the terms of this Privacy Policy. Law Enforcement and Protection of Users and the Site: To the extent permitted by law, we may disclose Personal Information to governmental authorities or third parties pursuant to a legal request, subpoena or other legal process. We may also use or disclose your Personal Information as permitted by law to apply or enforce this Privacy Policy, or protect our rights, interest, or property as well as those of our affiliates, customers. Following such disclosure to any third party, your Personal Information may be accessible by others to the extent permitted or required by applicable law.
1.8 Contact Information
Please send any comment, question or complaint regarding our Privacy Policy or any request to access or correct your Personal Information by mail or email using the following contact information. You may also send written requests to rescind your consent to our use of your information to the below contact information:
SCARLETRED Holding GmbH
Media Quarter Marx 3.4
Maria Jacobi Gasse 1, 8th floor
1030 Vienna, Austria
office@scarletred.com
Commercial registration number: FN 420719 f
Court of jurisdiction: Vienna (Austria)
VAT: ATU68970624