PURI Privacy Policy

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Updated 17, June 2023

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This Privacy Policy describes how PURI collects, uses, and shares your personal data.

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You can view this information at any time, either in PURI and/or online at https://puriapp.com/privacy-policy/.

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This Privacy Policy can be navigated via the headings below:

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What Is Personal Data
Your Privacy Rights
Personal Data We Collect
Personal Data We Receive
Our Use of Personal Data
Our Sharing of Personal Data
How We Protect Personal Data
Children and Personal Data
Cookies and Other Technologies
Transfer of Personal Data Between Countries
Our Commitment to Your Privacy
Privacy Questions

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What Is Personal Data

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Personal Data ("Personal Data") means data that directly identifies you, and also data that does not directly identify you, but that can reasonably be used to identify.

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Aggregated data is considered non-personal data for the purposes of this Privacy Policy.

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This Privacy Policy covers how Koch SaMD GmbH (collectively, "Company", "We", "Us" or "Our") handles personal data on our websites, through our app PURI ("PURI", "App"), via email, or in person. We may also link to third parties on our Services or make our apps available for use and/or download. Our Privacy Policy does not apply to how third parties define personal data or how they use it. We encourage you to read their privacy policies and know your privacy rights before interacting with them.

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Your Privacy Rights

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We respect your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data. We provide you the ability to exercise these privacy rights. Where you are requested to consent to the processing of your personal data, you have the right to withdraw your consent at any time. To exercise your privacy rights and choices please use the functions within Our Services, or contact us.

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To help protect the security of your personal data, you must sign in to your account and your identity will be verified. If you want to obtain a copy of, or delete, your personal data, please contact Us, or download, or delete your data directly from Our App or website.

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There may be situations where we cannot grant your request to delete your data, for example, if you ask us to delete transaction data and We are legally obliged to keep a record of that transaction to comply with law. We will decline to grant a request where doing so would undermine our legitimate rights to the use of data.

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Other reasons your privacy request may be denied are if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical. If you live in California and you cannot access Our privacy information, you or your authorized agent can make a request at https://puriapp.com/customer-support/.

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Personal Data we collect

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To use Our services we collect personal information to secure your account. We aim to collect only the personal data we need. When you create a PURI account or interact with Our website, make a purchase, or download a software update, connect to our services, contact us (including by social media), participate in an online survey, or otherwise interact with Us, we may collect a variety of information, including:

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Account Information: Each account is secured by a unique email address and an authentification method which includes password or via 3rd party authentification with Google, Facebook or Apple. To create an account we require a valid email address, country of residence, and age.
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Device Information: Data from which your device could be identified, such as device serial number, or about your device, such as browser type, operating system and hardware.
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Contact Information: Data such as name, email address, physical address, phone number, or other contact information
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Payment Information: Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information
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Transaction Information: Data about purchases of Our products and services or transactions facilitated by Us, including purchases on Our Services
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Usage Data: Data about your activity on and use of our Services, such as app launches within our services, including browsing history; search history; product interaction; crash data, performance and other diagnostic data; and other usage data
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Location Information: In order to create an account in PURI we ask you provide your country of residence. This is needed to determine legal requirements for managing your account. During the purchase of a subscription or product in our ecommerce site you may be asked to provide a shipping and/or invoice address. This is needed for tax and shipping purposes. We may also track your location information via IP addresses. We do not track or require GPS data from your device.
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Health, Medical and Fitness Information: The use of our servcies are based on providing you with the ability to store and review Data relating to your health, medical and/or fitness status. Health, Medical and Fitness also includes data that can be used to make inferences about, or detect, your health status. The sharing of your personal medical, health or fitness information and usage of Our Services is entirely voluntary on your behalf.
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Studies and trials: From time to time we may offer you the opportunity to participate in studies or trials. These studies and trials will be governed by separate terms that will be made available to you at the time of registration for such studies and trials.
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Other Information You Provide to Us: Details such as the content of your communications with Us, including interactions with customer support and contacts through social media channels
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You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests you may have.

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Personal Data We Receive from Other Sources

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We may receive personal data about you from other individuals, from businesses or third parties acting at your direction, from our partners who work with us to provide our products and services and assist us in security and fraud prevention, and from other lawful sources.

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Individuals: we may collect data about you from other individuals — for example, if that individual has sent you a product or voucher, invited you to participate in one of Our Services, or shared content with you.
3rd party authorisation: You may direct other individuals or third parties to share data with Us. For example, if we allow API integration with 3rd party products and you wish to import this data into Our App, then you can authorize such 3rd parties to share data with Us
Operational partners: We may validate the information you provide — for example, when creating an Account, with a third party for security, and for fraud-prevention purposes. This may include 3rd party authentification APIs, or anti-spam products such as Google Captcha.
Research partners: For research and development purposes, we may use datasets such as those that contain images, voices, or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law, including law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to reidentify individuals who may appear therein.

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Our Use of Personal Data

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We use personal data to enable us to provide Our Services to you, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent.

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Depending on the circumstance, We may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations. More information is available in the product-specific information embedded in our products and features as described above.

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If you have questions about the legal basis of our use of Personal Data, you can contact Our Data Protection Officer at https://puriapp.com/customer-support/

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Service provision: We collect personal data needed to provide you Our Services, which may include personal data collected to improve our offerings, risk management, post market surviellanced, for internal purposes such as auditing or data analysis, or for troubleshooting.
Transaction processing: To process transactions, We must collect data such as your name, purchase, and payment information.
Communicate with You: To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is required for your interaction with Us, you may not opt out of receiving important notices about your account with Us. You do have the option to opt out of marketing communications.
Security and Fraud Prevention: To protect individuals, employees, and Us and for loss prevention and to prevent fraud, including to protect individuals, employees, and Us for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.
Personalization Data: If you choose to personalize Our Services or communications where such options are available, We will use information that we collect so that we can offer you those personalized services or communications.
Comply with Law: To comply with applicable law, for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request.

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We do not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review. We do not use or disclose sensitive personal data for any purposes that would require a user to exercise a right to limit processing according to California law. We retain personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law.

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We retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy summaries. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal data for the shortest possible period permissible under law.

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Our Sharing of Personal Data

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We may share personal data with affiliated companies, service providers who act on our behalf, our partners, developers, and publishers, or others at your direction. We do not share personal data with third parties for their own marketing purposes.

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Service Providers: We may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing data, including personal data, in connection with your use of our services and delivering products to customers. Our service providers are obligated to handle personal data consistent with this Privacy Policy and according to our instructions.
Partners: At times, We may partner with third parties to provide services or other offerings.
Distribution partners: If you download and/or purchase a subscription from Google Play, or the Apple App Store, we may receive and be required to share Personal Data to enable the transaction.
Others Sharing: We may share personal data with others at your direction or with your consent. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.

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We do not sell your personal data including as “sale” is defined in Nevada and California. We do not “share” your personal data as that term is defined in California.

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How we protect Personal Data

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We secure and protect Personal Data via our security practices. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure. We implement in our Apps, websites and services, security by design, and have implemented internal and external testing and auditing to verify our safeguards.

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Children and Personal Data

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Our Services require Users to be at least 18 years of age. Age is enforced during the account creation process and an account will not be created given you are under the age of 18 years.

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Cookies and Other Technologies

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Our websites, online services, interactive applications, and advertisements may use “cookies” and other technologies such as web beacons. These technologies help us to better understand user behavior including for security and fraud prevention purposes, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches, and facilitate us in gaining data to verify and validate product risks and collect post market surveillance data to be used to improve the performance, safety and quality of our Services.

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Communications Cookies: These cookies are used to enable network traffic to and from Our systems, including by helping us detect any errors.
Strictly Necessary Cookies: These cookies are set as required to provide a specific feature or service that you have accessed or requested. For example, they allow us to display our websites in the proper format and language, to authenticate and verify your transactions, and to preserve the contents of your ecommerce transactions.
Other Cookies; These cookies are used to understand how visitors interact with our websites and online services, including by helping us to assess the effectiveness of advertisements and web searches. We also uses these cookies to remember choices you make while browsing, so we can provide you with a customized experience.

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If you prefer We do not use cookies, you can disable cookies on your web browser. Given cookies are disable then certain features of Our Services may not be available.

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In addition to cookies, We use other technologies that help us achieve similar objectives.

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In some email messages We send to you, we provide a “click-through URL” that links you to content on the Our website and/or apps. When you click one of these URLs, they pass through a separate server before arriving at the destination page on our website. We track this click-through to help us determine interest in particular topics and measure whether we are communicating with you effectively. If you prefer not to be tracked in this way, you should not click graphic or text links in email messages.

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We generally treats data we collect using these cookies and similar technologies as non-personal data except in the case we have the ability to correlate such data with a Personal Data held by Us. When we combine non-personal data collected from these technologies with other personal data We hold, then we treat the combined data as personal data for purposes of this Privacy Policy.

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Transfer of Personal Data Between Countries

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To enable access to our products and offerings anywhere in the world, it may be possible, that your personal data may be transferred to or accessed by entities around the world, including Us, suppliers, and other 3rd party companies, who perform processing activities such as those described in this Privacy Policy in connection with your use of our products and services.

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We comply with laws on the transfer of personal data between countries to help ensure your data is protected, wherever it may be. The entity that controls your personal data may differ depending on where you live.

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Our Commitment to Your Privacy

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To make sure your personal data is secure, we communicate our privacy and security guidelines to our employees and enforce process & technology privacy controls within the company and ensure employees are trained. Additionally we may conduct internal and external audits to assess our level of our privacy compliance and control within the Company.

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Privacy Questions

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If you have questions about Our Privacy Policy or privacy practices including, or you would like to contact our Data Protection Officer, you can contact us at https://puriapp.com/customer-support/. You can also ask us questions about how to submit a privacy complaint and we will endeavor to help. For all substantive complaints we aim to deliver a response within seven days. If we require additional information or that We need more time to respond you will be notified.

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Where your complaint indicates an improvement could be made in our handling of privacy issues, we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person, we will take steps to address that with you or that other person. You may at any time refer your complaint to the applicable regulator. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

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Changes to this policy

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When there is a material change to this Privacy Policy, you will be given the option to accept the new terms or to delete your account and delete personal datat. We will aim to give least one week notice in advance of changint this policy and you may be notifeid via email, on the website or in the App.

Privacy

Document Details

PURI Privacy Policy