Dooinwell SAS (“we”, “our” or “us”) operates a service that allows elderly users to submit check-ins and activity updates, that under certain circumstances will be made available to other users in their family or care group (the "Relatives"), which is made available through mobile apps (the "Service"). More specifically, elderly users will use the Dooinwell App while the invited Relatives will use the Dooinwell Link app. These two apps are both delivering the Service and were designed as separate apps to better customize the experience of users of the Service.

This Privacy Policy explains our practices regarding the collection, use, disclosure, and protection of information ("personal information") that is collected through our Service, as well as your choices regarding the collection and use of information.

Our Service is available in many different countries, which may have different standards and requirements in respect of the information we provide in the Privacy Policy and how we use personal information.

Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in the part of this Privacy Policy that is relevant to you.

‍Special note for users accessing our Service from the European Economic Area or Switzerland : Dooinwell SAS is the data controller of the personal information we hold about you, this role being defined by the Article 4 of the European Union General Data Protection Regulation.
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1.1    We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, create or edit your user profile on the Service, update your preferences, invite Relatives, check-in or submit information about your out-of-home activities, correspond with us by e-mail, chat or otherwise, or use some other feature of our Service.

1.2    We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.

1.3    The following table (Exhibit 1) sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information.
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Exhibit 1
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1.4    We also automatically collect personal information indirectly about how you access and use the Service and information about the devices you use to access the Service.

1.5    The following table (Exhibit 2) sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
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Exhibit 2
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1.6    We may link or combine the personal information you submit about you and the information we collect automatically. This allows us to provide you and your Relatives an improved Service and experience.
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1.7    We may de-identify any of the personal information we collect (so that it does not directly identify you) and use it for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features.
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1.8    We will store the personal information we collect about you for no longer than necessary for the purposes set out in 1.3 and 1.5 and in accordance with our legal obligations and legitimate business interests.
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2.1    We may share your personal information with the following:

(a)     Other users of the Service: we may share your personal information, including your name, check-ins and outside activities data, with other users of our Service at your request and in accordance with your preferences. More specifically, this will only happen between an elderly user and the group of Relatives he has invited, and also inside this group of relatives (for example, a relative may mark an alert as “Resolved”, and other relatives in the Relatives group will be made aware).

(b)    Service providers, business partners and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, web hosting, or providing analytic services.

(c)     Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

(d)     Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of Dooinwell SAS, its users or others.

We do not share your data with third parties for their marketing and marketing-related purposes and won’t try to get your consent to do so at any moment when you use the Service.
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3.1    From time to time, we may contact you with information about our products and services. Most of the marketing messages we send will be by email or through push notifications on your device.

3.2    We will only send you marketing messages if you have given us your consent to do so. We will ask you if you would like to receive these messages when we first collect your contact details.

3.3    You can change your preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing newsletters.

3.4    Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of our Service – notably, check-in reminders for the elderly users and alerts for the group of Relatives.
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4.1    Security: We implement appropriate, commercially reasonable technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

4.2    International Transfers of your Personal Information: Although we’re a EU-based company, any information we collect from you will be collected and stored in the United States of America (U.S.). If you are in the EU or EEA, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy. Currently, all the recipient of your personal data in the U.S. complies with the EU Standard Contractual Clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament.

The table below (Exhibit 3) sets out the current list of recipients of your Personal Information and the legal agreement that governs this transfer.
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Exhibit 3
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4.3    Onward Transfer: Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third-party processes personal information for limited and specified purposes and in a manner consistent with this privacy policy. Where the transfer is to a third-party agent acting on our behalf, we may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage. In certain situations, we may be also required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

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5.1    In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
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(a)   Right of access. You have the right to obtain:
(I)    confirmation of whether, and where, we are processing your personal information;
(ii)    information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
(iii)    information about the categories of recipients with whom we may share your personal information; and
(iv)    a copy of the personal information we hold about you.
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(b)    Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c)    Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d)    Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e)    Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

‍(f)    Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.


‍5.2    If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy.

5.3    You may also review and edit your contact and profile information by logging into your account on the app, and opt out of certain processing activities. Please note that we may not be able to provide some functionalities of our Services to you if you opt-out of the collection and/or sharing of some data.

5.4    You also have the right to lodge a complaint to your national data protection authority.
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6.1    We are not required to obtain your consent for most of the processing activities that we undertake in respect of your personal information.

6.2    We may, however, need your consent for certain processing activities. If we need your consent, we will notify you of the personal information we intend to use and how we intend to use it.

6.3    If you have provided consent for certain processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our processing of your personal information before your withdrawal.
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Our Service may, from time to time, contain links to and from third party websites or apps, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites or apps, please note that these websites or apps have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites or apps.
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We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the beginning and end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
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If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.
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10.1    Please contact us at support@dooinwell.app if you have any questions, comments and requests regarding this Privacy Policy.

10.2    We commit to resolve complaints about your privacy and our collection or use of your personal information. Inquiries or complaints regarding this privacy policy should first contact us at support@dooinwell.app.
Dooinwell SAS takes all concerns about privacy and use of personal information very seriously, and shall endeavour to reply to you within 45 days of receiving a complaint.
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