We thank you for your trust and do our best to honor it. We process the personal data you entrust to us to help you improve your health with the utmost care. Respect for privacy is a core principle that we place at the heart of our strategy for developing our Products and Services. We are committed to a process of continuous improvement to ensure the utmost respect for your personal data. If you have any questions please contact us.
The personal health data you entrust to us is sensitive data that we process in accordance with identified legal bases and with the highest security standards.
Personal Data is collected when you visit our website, use our Products and Services, browse on the application and contact customer support.
Your consent is collected in specific cases. You may withdraw it at any time.
We process all Personal Data (as identified below) for a specific purpose and on an identified and necessary legal basis. We retain Personal Data for a specified period of time.
When you use the Products and Services in USA, your Personal Data is hosted in USA and Health Data is not transferred outside the USA.
You can contacting us at privacy 1stepcareAll@gmail.com.
The present privacy policy is subject to the General Terms and Conditions.
This Privacy Policy applies to the use of the 1STEP App published by 1STEPCARE. 1STEP App is a free application (web and mobile) that focuses on three areas: (i) health monitoring, (ii) motivation maintenance, (iii) installation of 1STEP products. 1STEP App can be used alone or in conjunction with our products. The personal health data you entrust to us is sensitive data that we process in accordance with identified legal bases and with the highest security standards.
Personal Data relating to you
《Anonymized Data》means data resulting from the processing of personal data in such a way as to prevent the identification of the data subject in an irreversible manner, taking into account the techniques that can reasonably be implemented.
《Pseudonymized Data》means Personal Data that is not directly linked to a natural person without the use of additional information.
《Personal Data》means any information relating to an identified or identifiable individual. This includes all kinds of information: last name, first name, postal address, e-mail address, etc. It also covers the notion of Personally Identifiable Information (PII) provided for by the American regulation.
《Health Data》means personal data relating to your past, present or future state of health (physical or mental). Health Data is particularly sensitive data and is therefore subject to special protection measures.
Personal Data is collected when you visit our website, use our Products and Services, browse on the application.
2.1. Our website. Regarding the data collected on the website of 1STEP, please refer to our Cookies Policy.
2.2. Use of Products and Services. The use of our Products and Services generates the creation of personal data in the following cases.
a. Account creation. When you create a 1STEP account, you fill in personal data relating to your identity, such as your name, surname(s), age, email address. This account allows you to access the Personal Data generated during the use of the Products and Services, and it also allows you to modify certain data.
b. Use of our Products and Services. When you use our Products and Services, Personal Data is collected (such as oxygen level, pulse rate, weight, sleep). The data collected will depend on the device you use and how you use it. You may consult the Privacy User Guide to learn about all categories of Personal Data processed by the Product.
c. Partner Applications. When you connect your 1STEP App account with third-party applications or products, data from 1STEP App will be synchronized with those applications. You can also consent so 1STEP may also collect data from these third-party applications or products to improve your experience and our Services. You can modify or withdraw your consent directly in the settings of your 1STEP App. Please note that editors of third-party applications become data controllers once data has been transmitted. We invite you to read the privacy policy of these third-party applications. This policy applies only to Products and Services offered by 1STEPCARE.
d. Customer Support. When you contact customer support, certain Personal Data relating to your 1STEP account may be momentarily accessible by our teams depending on the problem encountered, such as data relating to the Products you use. No Health Data is accessible to our customer support staff without your prior consent.
e. Event tracking. Some Personal Data is collected automatically when you use the Products and Services, including through the use of tracking devices. We collect technical information such as: IP addresses, language, operating system, location (as authorized by you), and smartphone information (model, version…).
Your consent is collected in specific cases. You may withdraw it at any time.
3.1. COLLECTION OF YOUR CONSENT. We collect your consent to process Personal Data for：
Creating your 1STEP App account;
Participating in our research programs;
Sharing your Data with third-party partner applications;
Enabling dual authentication (2FA);
Marketing communications.
3.2. WITHDRAWAL OF YOUR CONSENT. At any time, you can withdraw your consent. To do so, simply：
Delete your account;
Uncheck "Research Center" in your notification center;
Remove the connection with third-party applications ;
Remove double authentication in your account settings;
Uncheck "Promotional offer" in your notification center.
4.1. NECESSITY OF PROCESSING.We collect Personal Data from you in order to provide the different purposes listed below. If you do not wish to provide it, you will not be able to access certain parts of the Products and Services, or services offered by our customer support.
4.2. LIST OF PROCESSING.
A) USE OF OUR PRODUCTS AND SERVICES
1. Purchase and delivery of your 1STEPCARE products and services via our website
PROCESSES DATA: Name / First name / Email address / Postal address / Phone number / Credit card number / IP address / MAC address of the purchased product
LEGAL BASIS: Performance of the contract (acceptance of the Sales conditions)
2. 1STEP App account creation
PROCESSED DATA: Email address / Date of birth / First and last name / Password (optional) / IP address / MAC address / Profile picture (optional) / Height / WeightLEGAL BASIS: Performance of the contract (acceptance of the Terms of Use)
RETENTION PERIOD: Data is retained until you delete your 1STEP App account
3. Graphic presentation of your Data, including Health Data, via 1STEP App
PROCESSED DATA: Physiological and technical data collected when using our Products and Services.
LEGAL BASIS: Performance of the contract (acceptance of the Terms of Use)
RETENTION PERIOD: Data is retained until deletion of your 1TEPS App account. You may also delete certain data via your 1STEP App
4. Optional sharing of Personal Data with third-party applications
PROCESSED DATA: The data shared vary depending on the product used
LEGAL BASIS: Your consent to the sharing of Personal Data relating to you
RETENTION PERIOD: Data is shared until sharing is deactivated or the user account is deleted
B) COMMUNICATION & SUPPORT B）
1. Marketing Communication
PROCESSED DATA: E-mail address
LEGAL BASIS: Consent to this processing when creating your account
RETENTION PERIOD: Data is retained as long as your account is active or when you no longer wish to be notified
2. Improvement of the navigation on the Site
DATA PROCESSED: Connection data (see Cookie Policy)
LEGAL BASIS: Consent obtained through the cookie banner
PERIOD OF RETENTION: 3 months
3. Customer support - Requests made on our Help Center
DATA PROCESSED: E-mail address / Name / First name / Content of the request.
LEGAL BASIS: Necessary for the execution of the contract (acceptance of the Terms of use / Sales conditions)
DURATION OF RETENTION: The data associated with the ticket is kept for a maximum of 3 years or until the user account is deleted.
4. Customer support - Requests made via 1STEPCARE official social networks accounts
DATA PROCESSED: Name / First name / Content of the request / Username.
LEGAL BASIS: Legitimate interest
DURATION OF RETENTION: The data associated with the ticket is kept for a maximum of 3 years or until user account is deleted.
5. Feedback on the Customer support experience
DATA PROCESSED: E-mail address
LEGAL BASIS: Legitimate interest
DURATION OF RETENTION: The data associated with the ticket is kept for a maximum of 3 years.
C) SECURITY AND EXERCISING YOUR RIGHTS
1. Activation of the double authentication (2FA)
PROCESSED DATA: Phone number
BASIS FOR THE PROCESSING: Your consent when activating this feature
RETENTION PERIOD: The phone number is retained until the user account is deleted or this feature is deactivated
2. Prevention and fight against computer fraud and cyberattacks
PROCESSED DATA: Pseudonymized data relating to the different actions performed by the User
BASIS FOR THE PROCESSING: Legitimate interest
RETENTION PERIOD: One year from the date of registration of the action
4.3. DATA SHARING. We only share such data in circumstances described below:
a. Your control over the Data. You may ask us to disclose information to others, such as when you use our community features like forums or programs that require sharing with third parties. You can change your choices at any time by changing your account settings or by visiting our Help Center.
b. Internal and Legitimate Sharing. Personal Data may be processed by the employees of 1STEPCARE SAS and its subsidiaries, within the limits of their respective responsibilities and exclusively for the purposes described in this Policy.
c. Use of our subcontractors. We share certain Data with subcontractors, who are experts in their field, in order to supply the Products and Services. Our subcontractors are required to comply with both the GDPR. They process the shared Data only for the intended purpose. Our subcontractors help us to provide you with high quality products and services, please find the list of subcontractors here.
d. Legal reasons. We may share Personal Data relating to you when required by law, upon request of a court, in connection with a legal proceeding, or if we believe in good faith that disclosure is reasonably necessary to (a) investigate, prevent, or take action regarding suspected or actual unlawful activities, or to assist public authorities; (b) investigate and defend against any third-party claims or accusations; or (c) protect our Services’ security or integrity. We will notify you of any legal proceedings that require access to your Data, unless we are prohibited by law from doing so. Where a court order specifies a period of non-disclosure of the request to data subjects, we will send you a deferred notification after the non-disclosure period has expired.
5.1. RETENTION PERIOD. The retention period indicated in the list of treatments depends on the type of data, the purpose or our legal obligations. If you ask us to do so, 1STEPCARE will delete your data from its servers and will ask its subcontractors involved in the processing to perform the same operation. We use subcontractors to manage backup data. This data will be used in case of operational problems to ensure the continuity of our services and products. Please note that, for security reasons, we are not able to reflect the deletion or modification of data on backups already made, in order to protect the integrity of the backup data.
5.2. ANONYMIZED DATA. 1STEPCARE may anonymize your data in accordance with the applicable security standards and regulations. Once anonymized, it no longer identifies you and is no longer Personal Data. 1STEPCARE uses the data in this form to participate in research projects.
5.4. DATA SHARED WITH THIRD PARTIES. If you have chosen to share your data from 1STEP Products and Services with third parties, we cannot ensure the deletion or anonymization of such data. We invite you to contact the third party for more information.
You may exercise your rights by contacting us at privacy 1stepcareAll@gmail.com.
6.1. YOUR RIGHTS. You may exercise the following rights independently or with our assistance.
a. Right of Access. ou can access the Personal Data about you processed, collected or stored by 1STEP. You can find this information directly from your account or via Customer support.
b. Right of rectification. If you find that the data about you is inaccurate, you have the right to request its correction. Some personal data can be changed directly from your 1STEP App account.
c. Right of Limitation and Right to Object. If you find that any data about you is inaccurate, you may ask us to stop processing that data until the situation is corrected. You may also ask Us to stop processing Data relating to you.
d. Right to Erasure. You may request the deletion of Personal Data relating to you. We will assist you in deleting Personal Data your account or Customer Support.
6.2. ASSISTANCE IN EXERCISING YOUR RIGHTS.
You may exercise your rights at any time by writing to privacy 1stepcareAll@gmail.com. Proof of identity may be requested if we have no other way to verify that you are the owner of the account to which the data relates.
The present privacy policy is subject to the General Terms and Conditions
Updated on 11 July 2024.
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