SQUEGG’S PRIVACY POLICY

As of 5^th May 2021

When you use our Services, we collect the following types of information:

ACCOUNT  INFORMATION

Information you have provided in order to create an account on our App, such as your username, email address, and password are the only information we are requiring.

ADDITIONAL INFORMATION

To help improve your experience, you may choose to provide us with additional information like your age, sex, and dominant hand. You may also connect with other users on the App or invite friends who have not yet joined by providing their email addresses, accessing social networking accounts, or using the contact list on your mobile device. We do not save your contact list and delete it after it is used for the above purpose.

If you contact us or participate in a survey, contest, or promotion, we collect information you submit such as your name, contact information, and message.

PAYMENT AND CARD INFORMATION

The App supports payments and transactions with third parties. If you activate this feature, you must provide certain information for identification and verification, such as your name, credit, debit, or other card information, card expiration date, and CVV code. This information is encrypted and sent to your card network, which upon approval sends back to your device a token, which is a set of random digits for engaging in transactions without exposing your card number. For your convenience, we store the last four digits of your card number and your card issuer’s name and contact information. You can remove the token from your account using your account settings. We do not store your transaction history.

If you purchase the Device from our website, you provide your payment information, including your name, credit or debit card number, card expiration date, CVV code, and billing address. We do not store this payment information. We only store your shipping address to fulfill your order. Please be informed that third-party payment processors may retain this information in accordance with their own privacy policies and terms.

INFORMATION FROM YOUR USE OF THE DEVICE

The App collects data through your use of the device to estimate a variety of metrics like grip strength, grip count, dominant hand, blood pressure data, and data collected through various in-app activities. These may include but are not limited to your participation in the activity, your score for each activity, compliance and other details needed for us to provide your better information about your progress. When your device syncs with our App or software, the data recorded is transferred from your mobile device to our servers.

The App includes features that use precise geolocation data, including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs. We collect this type of data if you give us access to your location. You can remove our access using your App or in your mobile device’s settings. We may also derive your approximate location from your IP address.

When you access the App, we receive certain usage or network activity information. This includes information about your interaction with the Device and Services, for example, when you play games and what games you play using the Device.

We also collect data about the device you use to access the App, including your IP address, language, operating system, device and application identifiers, location, and cookie information.

INFORMATION FROM THIRD PARTIES

If you choose to connect your account or Device to another service or application, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address, and friends list. You may also choose to grant us access to your activity data from another service. You can stop sharing the information from the other service with us by removing our access to that other service.

We may partner with third parties, such as other tech companies that offer to integrate our Device into their platform. In such cases, these companies may provide us with your de-identified data, including your age, sex, dominant hand, and other data they collect in connection with your use of our Device. Should you so choose, they may also share with us your email address so that we can invite you to participate or determine your eligibility for particular benefits, such as discounts.

HOW SQUEGG USES YOUR INFORMATION

Your information is used and collected for the following purposes:

       To provide and maintain the services

Using the information we collect, we are able to deliver the Services available to you and honor our Terms and Conditions contract with you. For example, we need to use your information to provide you your Device activity, and to give you customer support.

Improve, Personalize, and Develop the Services

The information we collect is also used to help improve and personalize the Services and the App and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and services.

We also use your information to make inferences and show you more relevant content. For example, based on the games you play with the most frequency, we may make activity goals for you to help improve your grip strength.

Communicate with You

We also use your information when needed to send you notifications and respond to when you contact us. We also use your information to promote new features or products that we think you would be interested in. You can control marketing communications and most notifications by using your notification preferences or via the “unsubscribe” link in an email.

Promote Safety and Security

The information we collect is also used to promote the safety and security of the App, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.

We also use cookies and other similar technology for the purposes as described above. For more information, please read our Cookie Use statement.

HOW SQUEGG SHARES YOUR INFORMATION

WE NEVER SELL THE PERSONAL INFORMATION OF OUR USERS. We also do not share your personal information except in the following circumstances:

         When you agree or direct us to share

You may direct us to disclose your information to others. For certain information, we provide you with privacy preferences to control how your information is visible. Just remember that if you choose to participate in a challenge, information like your profile photo and personal statistics is not governed by your privacy preferences and will be visible to all other challenge participants.

You may also direct us to share your information in other ways, like when you give a third-party application access to your Device. Remember that their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with third party applications.

For external processing

We transfer information to our corporate affiliates, service provides, and other partners who process it for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research, and surveys.

For legal reasons

We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights, or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or any threats to the security of the App or the physical safety of any person.

Please keep in mind that our policy is to notify you of legal processes seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court specifies a non-disclosure period, we provide delayed notice, after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances.

We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about exercise and activity, to partners under agreement with us, or as part of the benchmarking information we provide to users who use the App.

If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to a new entity.

HOW YOU CAN ACCESS AND CONTROL YOUR PERSONAL DATA

We give you tools to access and control your personal data, as described below, regardless of where you live. If you live in certain jurisdictions, you may have legal rights with respect to your information, which our tools will allow you to exercise, as outlined below:

         Accessing and Exporting Data

By logging into your account, you can access much of your personal information, including your dashboard with your daily exercise and activity statistics. Using your account, you can also download information in a commonly used file format, including data about your activity.

Editing and Deleting Data

By logging into your account, you can change and delete your personal information. For instance, you can edit or delete the profile data you provide and delete your account if you wish. If you choose to delete your account, please be advised that while most information will be deleted within 5 days, it may take up to 10 days to delete all of your information, like data recorded in the App and other data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons.

Objecting to Data Use

We give you tools to control our data use. You can limit how information is visible to other users of the Service, the notifications you receive from us, and revoke the access of third party applications that you previously connected your Device to. You can also use the App to unpair your Device from your account at any time.

DATA RETENTION

We keep your information as long as your account is in existence because we need it to operate your account. In some cases, when you give us information for a feature of the App, we delete the data after it is no longer needed for the feature.

We keep other information, like your activity data, until you use the tools provided to delete the data or your account because we use this data to provide you with your personal statistics. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, and for legal purposes.

SERVICES PROVIDED BY OTHERS

We work with partners who provide us with analytics and advertising services. This includes helping us understand how users interact with the Services, serving advertisements on our behalf across the internet, and measuring the performance of those advertisements. These companies may use cookies and similar technologies to collect information about your interactions with the App and other websites and applications.

POLICIES FOR MINORS

Squegg allows parents to set up accounts for their children to use the Device with the App. Parents or guardians must consent to the use of the minor’s data in accordance with this policy in order to create such an account.

Persons considered minors in their jurisdiction are not permitted to create accounts unless their parent or guardian has consented in accordance with the applicable law. If we learn that we have collected the personal information of a minor without parental consent, we will take steps to delete the information as soon as possible. Parents who believe that their minor children have submitted personal information to us and would like to have it deleted may contact us at hello@mysquegg.com.

YOUR INFORMATION’S SECURITY

We always strive to keep your data safe. To do this, we resort to using technical, administrative, and physical controls to maintain the security of your data. However, no method of transmitting or storing data is completely secure. So if you have a concern relating to security, please contact us at hello@mysquegg.com

DATA TRANSFERS AND INTERNATIONAL OPERATIONS

We operate internationally and transfer information to the United States and other countries for the purposes described in this policy. We rely on several legal bases to lawfully transfer personal data around the world. These include your consent and US and EU Commission approved model contractual clauses, which require certain privacy and security protections.

Please note that the countries where we operate may have privacy and data protection laws that differ from, and are potentially less protective than the laws of your country. You agree to this risk when you create your account, irrespective of which country you live in. If you change your mind and would like to withdraw your consent, you can delete your account.

Squegg is subject to the oversight of the US Federal Trade Commission and remains responsible for the transfer of personal information to others who process the same on our behalf and under our direction.

THE GDPR

If you live in the European Economic Area, UK, or Switzerland, please review these additional privacy disclosures under the EU’s General Data Protection Regulation (GDPR).

YOUR DATA CONTROLLER

The BioSparrow Inc., a corporation organized under the laws of Florida, is your data controller and provides the Services if you live in the EEA, UK, or Switzerland. For our contact information please visit us at mySquegg.com

 

HEALTH AND OTHER SPECIAL CATEGORIES OF PERSONAL DATA

To the extent that information we collect is health data or another special category of personal data subject to the GDPR, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data. You can use the tools in the App to withdraw your consent at any time, including by stopping use of a feature, removing our access to a third-party service, unpairing your device, or deleting your data or your account.

 

OUR LEGAL BASES FOR PROCESSING PERSONAL DATA

For personal data subject to the GDPR, we rely on several legal bases to process the data, including:

 

– Your consent, which you may withdraw at any time using the App or other tools provided to you;

 

– When the processing of data is necessary to enter into a contract with you; and

 

– Our legitimate business interests, as enumerated in the HOW SQUEGG USES YOUR INFORMATION section.

 

HOW TO EXERCISE YOUR LEGAL RIGHTS

Please read the HOW YOU CAN ACCESS AND CONTROL YOUR PERSONAL DATA section to understand how you are allowed to exercise your rights under the GDPR to access and control your personal data.

In addition to the various controls that we offer, in certain circumstances, you can seek to restrict our processing of your data, or object to our processing of your data based on our legitimate interests. Under the GDPR, you have a general right to object to the use of your information for direct marketing purposes. Please note that you can always delete your account at any time.

 

If you need further assistance regarding your rights, please contact our Data Protection Officer at hello@mysquegg.com attention: Data Protection Officer, and we will consider your request in accordance with applicable laws. You also have a right to lodge a complaint with your local data protection authority or with the US Federal Trade Commission.

 

CHANGES TO THE PRIVACY POLICY

 

We will notify you through email or through the App if any material changes should be made to this policy to give you an opportunity to review such changes before deciding if you would like to continue using the App. You can email us at hello@mysquegg.com to ask for previous versions of our Privacy Policy.

 

HOW TO CONTACT SQUEGG

 

Should you have any questions about this policy or need help in exercising your rights in relation to this policy, please contact our Data Protection Officer at hello@mysquegg.com.

 

You may also contact us at:

The BioSparrow, Inc. d/b/a SQUEGG

Attn: Legal Department (Privacy Policy)

1114NW 131st Ave.,

Pembroke Pines

Florida 33028, U.S.A.