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Privacy Policy

At Marsolab, we care about the privacy of your data and are committed to protecting it. This Privacy Policy explains what information we collect about you and why, what we do with that information, and how we handle that information. We’ll also explain what choices you have with respect to the information.

Applicability Of This Privacy Policy

This Privacy Policy applies to ADHD Scan desktop and mobile applications (collectively, the “Products”), adhdscan.com and marsolab.com and other Marsolab websites (collectively, the “Sites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Marsolab. If you do not agree with the terms, do not access or use the Products, Sites or any other aspect of Marsolab business.

This policy applies to the Company’s employees, contractors and officers.

The Company has a contract with all Data Processors that it uses in compliance with Article 28 & Article 29 of the GDPR, and ensures that all Data Processors are compliant with Data Protection Legislation.

The policy does not apply to third party services. Where third party services are used, and the third party is not a Data Processor, no Relevant Data (as defined below) is shared with them, or the Relevant Data has been anonymised such that the GDPR does not apply. Information collected by third parties is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

In addition, a separate agreement governs delivery, access and use of the Products (the “User Agreement”),

This policy applies to Relevant Data received and processed only.

Definitions

Capitalized terms used in this Policy and not otherwise defined shall have the meanings provided below:

Relevant Data - Personal Data and Special Categories of Data are the Relevant Data covered by this policy and as defined in the Data Protection Legislation.

Personal Data - any information relating to an identified or identifiable natural person.

Special Categories of Data - Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data and data concerning health or a person’s sex life or sexual orientation.

Processing/Processed - any operation on personal data, whether automated or not.

Information We Collect and Receive

When you interact with our Sites and Products, we collect Information that, alone or in combination with other data, could be used to identify you (Personal Data). Some of the Information we collect is stored in a manner that cannot be linked back to you (Non-Personal Data).

Marsolab collects, generates and/or receives the following Information:

Usage Information

Certain data about the devices you use to connect with Marsolab and your use of the Site and/or Product are automatically logged in our systems, including:

The detailed information on the basis for collection, storage and processing of each type of personal information is provided in Lawful Basis for Personal Data Processing section of Privacy Policy.

Cookies

Marsolab uses cookies and similar technologies in our Site and Services that help us collect Other Information. The Site and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Site and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie Policy.

Third Party Data

Marsolab may receive data about Site visitors, marketing campaigns and other matters related to our business from affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

Additional Information Provided to Marsolab

We receive Other Information when submitted to our Site or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Marsolab.

Collection of Information from Children

Marsolab does not knowingly collect personal information from children under the age of 13. If we determine we have collected personal information from a child younger than 13 years of age, we will take reasonable measures to remove that information from our systems. If you are under the age of 13, please do not submit any personal information through the Site and/or Products. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Sites and/or Products without their permission.

Using Your Information by Marsolab

We use, process, and store your information as necessary to perform our contract with you and for our legitimate business interests, in operating our Sites, Products, Services, and business including:

If information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Marsolab may use it for any business purpose.

How We Share And Disclose Information

We only disclose Personal Data to third parties when:

Marsolab does not share your Personal Data/personally identifiable information with third parties for the purpose of enabling them to deliver their advertisements to you.

Marsolab does not sell or rent your Personal Data.

Third Parties’ Applications and Products

Some third-party applications and services that work with us may ask for permission to access your information. Those applications will provide you with notice and request your consent in order to obtain such access or information. Please consider your selection of such applications and services, and your permissions, carefully.

Some third parties’ embedded content or plugins on our Sites and/or Products, such as Facebook “Like” buttons, may allow their operators to learn that you have visited the Sites, and they may combine this knowledge with other data they have collected about your visits to other websites or online services that can identify you.

Data collected by third parties through these apps and plugins is subject to each parties’ own policies. We encourage you to read those policies and understand how other companies use your data.

E-mailing by Marsolab

From time to time, we may want to contact you with information about product announcements, software updates, and special offers. We also may want to contact you with information about products and services from our business partners.

We only send marketing communications to users with your prior consent.

All Marsolab account holders will continue to receive transactional messages related to our Products, even if you unsubscribe from promotional emails.

Data storage, transfer, retention, and deletion

Data Storage and Transfers

Information submitted to Marsolab will be transferred to, processed, and stored in the United States. We also process your Personal Data in Germany. Data stored and processed by Marsolab may sometimes be moved between these zones (in a secure manner). When you use the Product on your computing device, user content you save will be stored locally on that device and synced with our servers. If you post or transfer any information to or through our Site and/or Product, you are agreeing to such information, including Personal Data and user content, being hosted and accessed in the United States, and Germany.

Duration of Information Storage

As the general rule, we retain your data while you are a customer and will delete your information within 30 days of either party’s termination of the Terms of Use or upon written request. You can remove your Personal Data from Marsolab at any time by emailing us with the respective request: [email protected]. However, we may keep some of your Personal Data for as long as reasonably necessary for our legitimate business interests, including fraud detection and prevention and to comply with our legal obligations including tax, legal reporting, and auditing obligations.

Safeguards

When you give us personal information, we take steps to make sure that it’s treated securely.

Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

We use industry-standard encryption to protect your data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology.

Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards. The security of the data stored locally in any of our Product installed on your computing device requires that you make use of the security features of your device. We recommend that you take the appropriate steps to secure all computing devices that you use in connection with our Site and Product.

The Company takes the security of your data very seriously and works to protect your data from loss, misuse and unauthorised access or disclosure.

All staff and officers who handle Relevant Data are aware of this policy and have been given training in how to correctly collect, process, store and delete data. The Company holds a log of when staff training was undertaken and updates it on an annual basis.

Data Breaches

All breaches will be reported to the relevant supervisory authority within 72 hours, unless the data was anonymised or encrypted or if it has a particularly high risk.

Breaches of this policy by staff, contractors, officers of the Company will be dealt with under the Company’s grievance and disciplinary policy and may lead to a disciplinary sanction.

If Marsolab learns of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on the Site. Depending on where you live, you may have a legal right to receive such notices in writing.

Lawful Basis for Personal Data Processing

Marsolab uses, processes, and stores Personal Data, as necessary to perform our contract with you, and based on our legitimate interests in order to provide the services in connection with the Product and maintaining Product’s functionality, namely:

We rely on your consent to process Personal Data:

In some cases, Marsolab may process Personal Data pursuant to legal obligation or to protect your vital interests or those of another person.

Your Rights

You have the following rights in respect to your personal information, including the right to access, correct, or delete Personal Data we process through your use of the Site and/or Product. You can:

Data Protection Officer

To communicate with our Data Protection Officer, please email [email protected].

Changes to our Privacy Policy

We may need to update this Policy to keep pace with changes in our Sites, Products, and Services, our business, and laws applicable to us and you. We will, however, always maintain our commitment to respect your privacy. We will notify you of any material changes that impact your rights under this Policy by email (to your most recently provided email address) or post any other revisions to this Policy, along with their effective date, in an easy-to-find area of the Sites, so we recommend that you periodically check back here to stay informed of any changes. Please note that your continued use of Marsolab after any change means that you agree with, and consent to be bound by, the new Policy. If you disagree with any changes in this Policy and do not wish your information to be subject to it, you will need to stop using the Sites and/or Products.