Privacy policy

INTRODUCTION

This Privacy Policy sets out the terms under which NEN EVIDENCE BASED SOLUTIONS, S.L.U. uses and protects the information and Personal data that are provided by Users when using [nendo] and [nendo parents].

Personal data collected through [nendo] and [nendo parents] will be processed solely and exclusively for the purposes described in this Privacy Policy and will not be used for any other purpose.

“[nendo parents] User” means a person over the age of 18 who uses the application and maintains control over the minor who is connected to the User’s profile on the [nendo] application.

“Minor” means a person under the age of 18 at the time of installation and use of the [nendo] application.

I.- DATA CONTROLLER.

The Data Controller is NEN EVIDENCE BASED SOLUTIONS, S.L.U. (hereinafter, “NEN”, “we”), address 08197 – Sant Cugat del Vallés (Barcelona), street Brollador number 25, VAT number B67833608, email hola@nen.health.

NEN has appointed a Data Protection Officer in accordance with Regulation 2016/679 (“GDPR”) on the protection of natural persons with regard to the processing of Personal data.

You can contact NEN’s Data Protection Officer at the following email address: nen.health-dpo@chino.io.

II.- PERSONAL DATA.

NEN processes the following Personal data, provided by [nendo] and [nendo parents] Users, related both to the device and to app usage:

• Minor’s name and date of birth, parent’s / legal guardian email address.
• Health-related data, specifically cancer-related symptoms data, date of diagnosis, type of diagnosis and other characteristics of the disease.
• Type of device used by both Users and Minors, operating system, resolution, app version, and other mobile device identifiers (such as device ID and IP address).
• Information related to the usage of the [nendo] and [nendo parents] platform.
• User information and data collected from third-party devices and applications when you choose to connect with [nendo] and [nendo parents].

In addition, NEN will collect Personal data related to the language settings, date and time at which the Users access [nendo] and [nendo parents], as well as User’s and Minor’s app usage data, such as the frequency and consistency of their use, the subscriptions and the functionalities that have been used.

Personal data is collected directly from both Users. However, if you choose to sign up for [nendo] and [nendo parents] through your personal Gmail account or Apple ID, some Personal data may be collected directly from Google or Apple, as applicable.

III.- PURPOSES OF THE PROCESSING.

In accordance with GDPR, “processing” means any action, such as collection, storage, modification, transfer, carried out in an automated or non-automated manner, performed on Personal data.

We process Personal data for the following purposes:

1. Provision of the Service

[nendo] and [nendo parents] allow Users and minors to provide certain specific information in order to manage their account and to get an overview of their activities and goals. In the process of creating the profile of Users and minors, NEN will process the following information:

• Minor’s name/nickname and date of birth.
• Diagnosis of the disease and diagnosis date.
• Any observations that Users may deem necessary to make.

Users and Minors will have the option to perform tasks related to food, movement, body and mind while using [nendo] and [nendo parents]. Users and Minors will record the results of each task and will be able to receive feedback from [nendo] and [nendo parents] on the information recorded. NEN will process some Personal data related to the Minor’s mood, diet, food records, exercise records, attention, routine, energy level, and stress level, with respect to the tasks performed.

2. Improvement of the Service

NEN, in addition to the information that the User can provide in order to use the service itself, also processes information related to the usage of [nendo] and [nendo parents] apps.

At NEN we process Personal data provided to us by the User and the Minor while using [nendo] and [nendo parents] in order to offer them the best experience in the use of both applications.

Personal data collected for this purpose may be used to improve the content offered by [nendo] and [nendo parents], to better manage business relationships, and to improve your experience with the service.

NEN also carries out research projects related to the development and efficacy of its products. In order to gather relevant information, required to compare test results and conduct research, NEN will collect the following Personal data from Users and Minors:

• Users’ name/nickname, email address, and ID.
• Patient-reported outcome (PRO), i.e., Users’ health information, including information about symptoms, test results, questionnaire responses, and adverse reactions.

3. Answer User questions

In addition, we may use your Personal data to answer your queries and requests sent through [nendo] and [nendo parents].

IV.- LEGAL BASIS FOR PERSONAL DATA PROCESSING.

1. For the purpose of providing you with [nendo] and [nendo parents], the legal basis is the performance of a contract between the User and NEN, entered into force when [nendo] and [nendo parents] apps were downloaded and the Legal Notice and Terms of Use were explicitly accepted.

Special categories of Personal data related to your children’s health are processed to provide you with our services and only with your explicit consent. Failure to provide the aforementioned categories of data will result in the inability to provide you with [nendo] y [nendo parents].

You can revoke your consent for this purpose at any time by deleting your account.

[Data processed for this purpose: minor’s name and birthday; e-mail of the adult holding parental responsibility; language; User information and data from third party devices and applications; data related to the minor’s health; mobile device identifiers].

2. For the purpose of improving [nendo] and [nendo parents], the legal basis is our legitimate interest to assess the efficacy of our services. We process personal data automatically when you use our services, and you may oppose the processing at any time by contacting us at the addresses provided above. Special categories of Personal data may be processed based on our legitimate interest to assess the efficacy of our services and only with your explicit consent. You are not required to provide us with this data and, even if you do, you can revoke your consent at any time by managing your preferences on your profile.

[Data processed for this purpose: mobile device identifiers; [nendo] and [nendo parents] app usage information; User information and data from third party devices and applications when you choose to connect to [nendo] and [nendo parents], language, the date and time the User accesses the application and the User’s and minor’s behavior in using the application, such as frequency and consistency of use, subscriptions and features that have been used.

3. For the purpose of answering requests sent via the app, the legal basis for this processing is our legitimate interest in communicating with you. You are not required to provide your data for this purpose.

[Data processed for this purpose: email address of the adults holding parental responsibility, data that you communicate to us through your requests.

V.- DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES.

NEN does not share minor’s personal data with any third parties and does not display advertising of any kind.

In general, NEN will not disclose Personal data provided by [nendo] and [nendo parents] Users to third parties, unless the provision of the service implies the need for a contractual relationship with a data processor and this relationship is strictly necessary to manage and maintain the service. NEN Processors will process data only for the duration of the Agreement with NEN, and under the same conditions and with the same responsibilities required for the Data Controller. Upon termination of the Agreement, the processor shall return the Personal data to the Controller and delete any copies in its possession.

On the other hand, only third parties to whom NEN has a legal or contractual obligation to provide such Personal data, including, for example, the Judges and Courts involved in proceedings related to the claims filed, shall have the right to access such Personal data.

NEN requires all natural or legal persons with whom it shares information containing Personal data to apply the same level of data protection.

VI.- DATA SUBJECTS RIGHTS.

NEN guarantees the exercise of the rights of access, rectification, deletion, portability, restriction, opposition and to be informed, in the terms provided in the current legislation. The Users of [nendo] and [nendo parents] will be able to exercise his rights sending a request, together with a copy of their ID, via:

E-Mail: hola@nen.health

DPO E-mail: nen.health-dpo@chino.io.

Postal mail: 08197 – Sant Cugat del Vallés (Barcelona), calle Brollado, 25.

You can exercise your rights free of charge; NEN will take charge of your requests as soon as possible and will answer to you always within one month.

Users may contact the competent local authority for data protection and other competent public bodies for any claim arising from the processing of his/her Personal data, including the Spanish Data Protection Agency.

To request the Personal data deletion for any reason, the User may contact NEN at the e-mail address [nen.health-dpo@chino.io] and NEN will proceed in taking all necessary steps to promptly delete such Personal data from the records.

VII.- DATA RETENTION PERIOD.

Personal data is stored for as long as it is needed in order to be used for the purpose for which it was collected, and in accordance with the legal basis for its processing in compliance with applicable law.

NEN stores and manages the Personal data and information collected through [nendo] and [nendo parents], with appropriate confidentiality, for as long as the User uses [nendo] and [nendo parents]. As long as you are a registered User of [nendo] and [nendo parents], your data will be retained and processed in order to provide you with the best possible service. In case of inactivity of the User on [nendo] and/or [nendo parents], the data collected will be deleted one year after the last connection.

User’s Personal data will only be retained for as long as necessary for the purposes for which it was collected. However, Personal data may be processed for a longer period if required by applicable law.

However, the Data Controller may keep the data, duly blocked, to meet possible administrative or jurisdictional responsibilities.

VIII.- DATA SECURITY.

The security, integrity and confidentiality of your Personal data is of vital importance to NEN. Appropriate technical, administrative and physical security measures have been implemented to safeguard Users’ Personal data against unauthorized access, use, alteration and disclosure, including the implementation of access controls and encryption. NEN periodically reviews security procedures to assess whether additional measures should be implemented or existing procedures should be improved.

IX.- TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANIZATIONS.

Your data will not be transferred to countries outside the European Union. In the event that your data is transferred outside the European Union, this will be done, in accordance with the GDPR, on the basis of an Adequacy Decision of the European Commission or, in the absence of an Adequacy Decision, with the adoption of standard contractual clauses approved by the European Commission and appropriate complementary safeguards.

X.- EXTERNAL LINKS.

[Nendo] and [Nendo Parents] apps do not include any links to third party websites.

XI.- UPDATES TO THIS PRIVACY POLICY.

This Privacy Policy may be updated periodically, in whole or in part, to reflect changes in NEN’s processing of Personal data. We will post a prominent notice on [nendo] and [nendo parents], notifying you of any significant changes to the Privacy Policy and indicating at the bottom of this Policy when it was last updated. We will also notify you by e-mail when appropriate.

If you have any questions about this Privacy Policy, you may contact NEN directly through the designated channels described in this Privacy Policy.

Last updated: 22/11/2023.