This privacy statement explains how we, LIFE (“Life”, “us”, “we” or “our”) use your personal data to provide you with the Life mobile application (The “Life App”) and website (www.lifeworthliving.app).
We are committed to protecting and respecting your privacy. We ask that you read this Privacy Statement carefully as it contains important information about what personal data we collect from you and how we will use it. Any questions you may have regarding this Privacy Statement are welcomed and should be sent to firstname.lastname@example.org.
This Privacy Statement should be read in conjunction with our Terms & Conditions. We strongly encourage you to review this Privacy Statement and Terms & Conditions carefully and ensure that they contain nothing that you are not prepared to agree to, before you decide to accept the Terms & Conditions and use our Life App or our website (www.lifeworthliving.app).
LIFE is a company registered in Estonia with company registration number 16237603. Our registered office is at Kentmanni 4/Sakala 10, 10116 Tallinn, Harjumaa, Estonia. For the purpose of the General Data Protection Regulation (EU) 2016/679 and the Data Protection Act 2018 (together “Data Protection Legislation”), we are the ‘data controller’ (i.e. the company which determines the purposes and means of the processing of your personal data).
Life has appointed a Data Protection Officer, who can be contacted at email@example.com.
How We Process Your Data
To register an account, you have to enter your email address and choose a password. Once you have registered, you will benefit from automatic backup to our secure servers, as well as the ability to restore and recover your account and its associated data on another device.
When you use the Life app or when you go on our website, some personal and non-personal data is collected, stored, and analyzed using internal and third-party tools.
There are two main purposes for which we process personal data and the type of data that is processed to fulfill each purpose:
1. To provide our services and understand your needs
First and foremost it is vital for us to stress that we do not and will never share any personal data about you to third parties, unless we have an explicit permission from you to do so. However you may still feel uncomfortable storing personal and health information to a connected device. Therefore, you should consider the safety and privacy of your personal data before using the Life app generally. You should refrain from exporting data unless you are certain that the receiving device or email address is authorized, credible, and secure.
When you use the Life app, or when you go on our website, Life collects, stores, and uses some personal and non-personal data. We mainly do this to provide you with our services, and our lawful basis for this processing is that it is necessary for the performance of a contract with you (i.e. our Terms and Conditions).
We may also occasionally send you informational and promotional messages as well as reminders to your smartphone via push notifications. We will only send you such messages with your prior consent, unless they are critically needed for the purpose of providing the service.
We are very thoughtful and selective about what we communicate and how often. You always remain in full control of your communication preferences with Life. You can change the settings within the app at any time.
We also process your personal data in order to understand your needs and your use of our app and website, to analyze bugs and fix issues, and to bring you more useful features. To sum it up, we process this data to provide you the best and most reliable experience of our services. These processing activities are based on our legitimate interests in providing a reliable service to you, and improving it.
We avoid processing personal data that directly identifies you as a person (such as your first name, surname, email) as much as possible and do it only if it clearly required to provide you the service.
These are the types of data we collect for the above purposes:
To deliver personalized insights
The data you track in Life about your mental and emotional state and activities is considered sensitive personal data. Life does not store sensitive personal data without your explicit consent. It is only when you give us explicit consent by creating a Life account, and giving us your consent declaration, that we start storing all your health and sensitive data on our secured servers.
You can withdraw your consent at any time by simply requesting us to delete your account and any information collected about you.
Here is the type of data we collect and store when you create an account:
Personal data used for account creation
We need some of your personal data (only your email address) in order to create your Life account.
Health and sensitive data
We store health data, such as your mood and other factors you track in the app (e.g. sleep quality, exercise, and general daily activities such as work, tv, grocery shopping etc.).
The provision of this information is entirely voluntary, and it is up to you how much information to input.
Principles of Processing
Data minimization and purpose limitation. We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Data that is not needed for the mentioned purposes. For any new purpose of processing we will ask your separate consent.
If you create an account with Life, your personal data, including sensitive data and data related to your health, is stored on your device and is also stored and processed on Life’s servers. This is done so we can offer you the option of backing up your data and to enable additional features (such as the ability to transfer, restore, and recover data between Apple and Android devices).
By creating an account with Life you explicitly consent that:
i. Life may store and process personal data you provide through the usage of the Life app and through the account creation process solely for the purpose of providing Life’s services to you and to improve Life’s service features. Such Life services may include sending you information and reminders through the Life app, e.g. via push notifications or to the email address you provided to Life, where you have separately agreed to receive such messages.
ii. The personal data you provide to Life through the account creation process for the purpose of providing Life’s service includes personal data you enter into the Life app, such as your account data (e.g. your email address), and your health data which may include your mood levels and individual symptom levels, your medication and supplements and other health factors you track in the app (e.g. sleep quality, exercise, diet and food diary, general daily activities such as work, tv, meditation etc.). All of your health data is encrypted on the server end.
You may withdraw your consent to this use of your data at any time by deleting your Life account. This can be requested by e-mailing firstname.lastname@example.org.
We believe that data privacy is a basic human right. At Life we strive to ensure that your rights are respected.
Here are some key facts about your privacy that we would like you to know:
i. Our products and services have been designed to minimize the use of your personal data. We only collect and process your personal data for the purposes that have been previously outlined.
ii. Your data is highly secured on our servers. You can contact us at email@example.com if you have any questions about the security of our services.
iii. We do not retain your personal data in an identifiable format for longer than necessary to deliver our services.
iv. Life does not engage in any automated decision-making or profiling activities.
As a user of Life’s services and website, you may exercise your user rights to:
i. Request information on, or a copy of, your personal data processed by Life. Upon your request, this information will be provided to you electronically.
ii. Correct your personal data and health data in the app settings and in the tracking categories available in the Life app.
iii. Withdraw your consent from data processing at any time by deleting your account and/or deleting the Life app from your smartphone, and/or unsubscribing from our newsletter by clicking the link at bottom of the email.
iv. Request the complete deletion of your data, including all past data sent to third-party services used for tracking and analysis, by reaching out to firstname.lastname@example.org. Your data will be deleted within 30 days.
v. Object to our processing of your personal data, or ask us to restrict your personal data pending a decision on whether we can lawfully continue to process it. vi. File a complaint with the relevant supervising authority if you believe Life is processing your personal data under violation of applicable data protection regulations.
We apply security measures to protect against the misuse, loss, and/or alteration of personal data under our control. Though we cannot ensure or guarantee that misuse, loss or alteration of information will never occur, we use all reasonable efforts to prevent it. Although we make good faith efforts to store the non-public information entered into the App in a secure operating environment that is not available to the public, we cannot guarantee complete security. We cannot and do not guarantee that our security measures will prevent third party “hackers” from illegally accessing our site or App and obtaining access to content or information thereon.
How Life Stores Your Personal Data
If you have an account with Life, your personal profile data and your health and activity data (mood, activities, your customized personal factors) are stored in encrypted way. It makes it impossible to connect any of the data to you as a user for anyone else than you via the app.
Your data is transmitted between your device and Life’s servers using the HTTPS protocol for encryption. HTTPS is the same technology used to create secure connections for your web browser and is indicated by a padlock icon in the URL bar of your browser.
Disclosure of Your Data
We will share some of your data with third parties outside Life only where it is strictly necessary to provide our services to you, where required by law or where we have another legitimate interest to do so. Data may be shared in the following circumstances:
- Technical Service Providers: For example: technology service providers, payment providers, data storage providers, and marketing platforms (e.g. for sending marketing emails),
- Third Party Apps: some of your personal data may be shared with such Apps.
- When required to do so by law, regulation or court order;
- in response to a legitimate request for assistance by the police or other law enforcement agency;
- to seek legal advice from Life’s external lawyers or in connection with litigation with a third party; or
- in connection with the sale, purchase or merger of our business.
Life’s recommendations for protecting your personal data
We believe the biggest threat to the security and privacy of your personal data is if someone, probably someone you know, gains access to any of your devices. The data you enter into Life is private and it should stay that way. We have outlined some ways to keep your devices secure below.
Protect your device:
i. Activate either PIN, TouchID (iPhone 5S models onwards), or FaceID (iPhone X onwards) authentication for your device. This prevents any person from using your device without your permission.
ii. Set up a feature that will allow you to erase all the data from your device if it’s been lost or stolen. For iOS, activating this feature is a two-step process: first, you need to Activate “Find My iPhone” via iCloud (see instructions on Apple Support pages) and then enable “Erase your device” (see instructions on Apple Support pages).
DATA TRANSFER OUTSIDE THE EU AND TO THIRD-PARTY APPS
Any personal data collected from you may only be transferred to countries outside the European Union / the European Economic Area (EEA) observing applicable privacy regulations and ensuring that your privacy rights remain protected. This includes ensuring that all such transfers are subject to approved safeguards which meet the requirements of Data Protection Legislation (for example, through the use of EU Commission approved standard contractual clauses).
Cookies, Tracking and Payment Data
Information on your usage of our website or of the Life app may be collected and processed by Life, or a third party engaged by Life using a unique identification number assigned to you. Information about your usage will be deleted as soon as this information is no longer required for the purpose collected, and will always be anonymized before sharing with third parties besides those mentioned underneath.
Your Consent for Life Tracking and Analysis
You may withdraw your consent at any time, by either disabling cookies on your device or following the instructions on how to withdraw your consent individually for each third party provider Life uses for its third party tracking and analysis services.
Marketing and Communications
Life uses your personal data, such as your email address, to contact you with notifications, emails, and newsletters. These include push notifications, in-app messages and emails to deliver health content and occasional promotional materials that may be of interest to you.
Newsletters are only provided to you if you have signed up for the newsletter via our website, or signed up within the Life App itself. You consent to push notifications when you activate Life’s push notifications in your device settings. You also consent to Life contacting you via email if you have contacted Life for questions or support requests in connection with our services or the Life app. You can withdraw your consent at any time. You can unsubscribe from our newsletter by clicking the unsubscribe link at the bottom of the message, and you can disable notifications sent by Life in your device settings.
In order to provide these services, Life may forward data such as your email address or consolidated activity data to third-party providers in order to carry out such newsletter services, surveys or notifications. Our marketing emails will be sent out very selectively and thoughtfully, and might include details about offers on the paid Life App service, as well as general updates on App developments (such as new features).
Life does not knowingly collect or use personal data from children under the age of 18. By registering to a Life account you are required to confirm that you are at least 18 years old.
If Life gains actual knowledge that the information has been collected from children under the age of thirteen in the United States in contradiction with the Children’s Online Privacy Protection Act of 1998 and the regulation thereunder, Life will not disclose this data and reserves the right to immediately delete the account and wipe all related information, including health and sensitive data of the user, from our servers.
If you are located in the EU, you can only use our services if you are over the relevant age at which you can provide explicit consent to the processing of your data under the laws of your country. If you are a parent and learn that your child is using Life without your permission or if you have any specific question about data privacy at Life, do not hesitate to get in touch with us at email@example.com.