HAALE Smart Ring App

1. Privacy Policy

Last Updated: 2025-02-15

Controller: HAALE Ring AB, Sweden

1.1 Scope

This Privacy Policy applies to users of the HAALE Smart Ring, mobile application, APIs, website and related services ('Services'). By using the Services, you agree to the processing described herein.

1.2 Categories of Data Collected

Account Data: Name, email address, date of birth, optional gender, account ID.

Device & Technical Data: IP address, device identifiers, OS version, usage logs, diagnostics.

Health & Biometric Data (Special Category under GDPR Art. 9): Heart rate, HRV, temperature trends, sleep metrics, movement/activity, stress indicators, recovery metrics, derived scores and predictions and related.

Derived & Inferred Data: Algorithmic assessments and predictive insights generated using proprietary AI systems.

1.3 Legal Basis

Processing is based on explicit consent (health data), contractual necessity, legitimate interest (security, analytics, product development), and legal obligations. Consent may be withdrawn at any time.

1.4 How We Use Data

Data may be used to deliver functionality, generate wellness insights, improve algorithms, train AI models, develop new features, conduct research, perform analytics, ensure security, detect fraud, and comply with legal requirements.

1.5 AI & Algorithm Development

User data may be used to train machine learning models, enhance predictive analytics, and develop new commercial services. Data is pseudonymized or anonymized where feasible. Anonymized data may be retained indefinitely.

1.6 Data Sharing

Data may be shared with cloud providers, analytics providers, AI infrastructure vendors, payment processors, support systems, and authorities when legally required. We do not sell identifiable personal data. Anonymized data may be shared for research or commercial purposes.

1.7 International Transfers

Transfers outside EU/EEA rely on Standard Contractual Clauses, adequacy decisions, or other approved safeguards.

1.8 Data Retention

Personal data is retained while accounts remain active, as required by law, or for legitimate business interests. Anonymized data may be retained without limitation.

1.9 User Rights

Users have the right to access, rectify, erase, restrict processing, data portability, object, and withdraw consent under GDPR. Contact details: www.haalering.com

1.10 Medical Disclaimer

The HAALE Smart Ring and App are not medical devices and do not provide medical advice. They are intended for general wellness and informational purposes only. HAALE disclaims liability for health decisions based on app data. Always consult a licensed healthcare professional.

1.11 Limitation of Liability

Services are provided 'as is' without guarantees of accuracy. HAALE shall not be liable for indirect damages. Use of the Services is at the user's own risk.

2. Terms of Service

By using the Services, you agree to these Terms. If you do not agree, do not use the Services.

2.1 User Responsibilities

Users agree not to misuse the device, reverse engineer, resell the app, or extract algorithmic models.

2.2 Intellectual Property

All software, algorithms, AI models, branding, and designs are exclusive property of HAALE Ring AB.

2.3 Account Termination

HAALE may suspend or terminate accounts for violations, fraud, or security risks.

2.4 Governing Law

These Terms are governed by Swedish law. Disputes shall be resolved in Swedish courts.

3. End User License Agreement (EULA)

Users are granted a limited, non-exclusive, non-transferable, revocable license to use the App.

Users may not modify, reverse engineer, extract code, or copy proprietary algorithms.

4. Cookie Policy

The App may use essential cookies, analytics cookies, performance tracking, and marketing identifiers (if enabled). Users can manage preferences in settings.

5. Onboarding Consent Flow Requirements

Users must explicitly agree to:

- Terms of Service (mandatory checkbox)

- Privacy Policy (mandatory checkbox)

- Explicit consent to health/biometric data processing (separate checkbox)

- Optional consent for anonymized AI and research use

6. Data Protection Impact Assessment (DPIA)

Due to processing of health data and predictive analytics, HAALE shall conduct and document a DPIA including risk assessments, encryption standards, access controls, and incident response procedures.

7. Data Processing Agreements (DPA)

HAALE shall maintain DPAs with cloud providers, payment processors, analytics vendors, including Standard Contractual Clauses and security obligations.