At Innova Medical Group, we know that people care about their privacy and data protection — so do we. This privacy notice explains how we may collect, use and share personal information when you use Innova’s Phronesia Products.

Innova Medical Group is committed to complying with all relevant data protection legislation, in this case EU and UK General Data Protection Regulation (GDPR). Innova Medical Group is the “Data Controller” as defined in the GDPR.

Readers of this Notice

In this Notice:

• “We,” “us,” and “our” means Innova Medical Group, and
• “Third-party” means someone who is not you or us.

In this Notice, “you” means you as a customer who:

• has used the QR code on the Phronesia Smart Ovulation Test packaging to download the Phronesia’s Fertility companion app, or
• has created a Phronesia Fertility account to use the companion app

The Phronesia Fertility App uses a discreet clip-on attachment for your phone to hold test strips in front of the camera, where the Phronesia Fertility App automatically measures the hormone concentration and displays the test result on the screen of phone. The Phronesia Fertility App tracks the previous results and your record to discover the personal biological rhythm, giving a heads-up of upcoming fertile days on the Fertility Calendar. The Phronesia Fertility App also reminds you of upcoming tests and fertile days by sending notifications.

Data Collected when Using the QR Code

The personal information we collect is your location (city and country). We use this information to measure the success of the product usage and to help to us plan our marketing activities.

The legal basis for collecting this data is your consent. We will keep this personal data for only six (6) months, after which it will be removed.

No personal data is transmitted outside of the EU. Aggregate data summarising QR code usage by location per time period, which is completely anonymous, may be shared with other Innova Medical Group subsidiaries and entities in other countries.

We use a third party to provide the QR Code, direct you to the relevant application download site and to record the data collected specified above. This third party is qrd°by which is based in Austria.

See further down this notice for information about your rights and how to exercise them.

Data Collected When Using the Phronesia Fertility App

Information you give to us

The following information is collected when you have downloaded and created an account:

• Your e-mail address
• Year of birth
• Height & weight (BMI)
• How long you have been trying to conceive
• Average period length
• Average cycle length (the longest and the shortest cycle length)
• Daily calendar – today is period day or not
• Daily calendar – the menstrual flow status
• Daily calendar – further information (intercourse Y/N; basal body temperature (BBT); mood; other notes).

We use this data to:

• to register you with our service and maintain your account
• to build your user profile
• to provide you with the following Phronesia Fertility App functions: to predict next period and to display results; and
• to make notifications to you (reminding you of upcoming tests and fertile days).

Information that is automatically collected

We also need to collect the following information about your device in order to ensure the app display is adapted to your device: Language & Region, OS version, app version, device model name.

The app has been developed by our partner iXensor who is based in Taiwan. In order to improve app performance we collect the time spent on each page of the apps and which buttons you have pressed.

Where the data goes, what is the legal basis and how long we will keep it

The account related data (e-mail, health information …) stays within the EU. The adaptive display and app performance data is shared with iXensor. Innova Medical Group has put in place appropriate safeguards with iXensor to ensure the security of the data sent to Taiwan, including Standard Contractual Clauses and specifying the security measures that iXensor must have in place. You may request further details regarding the security measures by contacting our Data Protection Officer (see contact details below).

Aggregate data on the total number of users, locations etc. may be shared with other Innova Medical Group subsidiaries and entities in other countries

The legal basis for using all the data above is consent.

The data will be retained until one of the following:

• You use the app functionality to delete the data, or
• You have not used the app for 12 months and not responded to an email reminder about the app after 7 days.

In both cases your data will be completely removed and no longer accessible to us or you.

How we protect you data

We ensure the third parties mention here have appropriate IT and other security measures in place within the contract we have with them.

Your Rights

You have the following rights:

• The Right to Information – which is provided by this privacy notice, though you may contact us for further information
• The Right of Access – to receive a copy of the information we hold about you
• The Right to Rectification – to correct any erroneous information
• The Right to Erasure – to request us to erase your information, though you can use the delete data functionality of the app as well
• The Right to Restriction of Processing – you may ask us to restrict the data processing in some manner
• The Right to Object – you may ask us to stop the data processing
• The Right to Data Portability – you may request your data in a machine-readable format. However, this right may be restricted
• The Right to Avoid Automated Decision-Making – whilst this right exists in theory, it does not apply in this case as there is not automatic decision-making

You can withdraw consent at any time and use the delete functionality of the app.

If you wish to exercise any of these rights you can contact us at: dpo@innovamedgroup.com

Making a Complaint

If you are dissatisfied with anything in this notice or any response we give you to a rights request or any other matter you may complain to your country’s data protection authority. A list of the authorities is maintained here: https://edpb.europa.eu/about-edpb/about-edpb/members_en

Our Contacts Details

The contact details for us are:

INNOVA MEDICAL GROUP SAS

14 rue Beffroy

92 200 Neuilly-Sur-Seine

France

+331 86 70 83 10 http://innovamedgroup.eu

You can contact out Data Protection Officer at: dpo@innovamedgroup.com