EU REGULATORY COMPLIANCE

Class I Medical Device

MEDICAL DEVICE — CLASS I Regulation (EU) 2017/745

CE Marking

EU DECLARATION OF CONFORMITY: available upon request

Basic UDI-DI : 3770041619GAITWINE5 — EMDN : Z12062502

Respect for your privacy

We thank you for your trust and are committed to upholding it. We handle the personal data you entrust to us to help you improve your health with the utmost care. Respect for privacy is a fundamental principle that we place at the heart of our strategy for developing our Products and Services. We are committed to a process of continuous improvement to ensure the highest level of respect for your personal data.

COMPREHENSIVE AND UNIFORM APPLICATION

This Policy applies uniformly to all Users of the Age Impulse app and Gaitwin, regardless of where you live. We comply with the data protection regulations applicable in the markets where Age Impulse sells its Products and Services.

TABLE OF CONTENTS

I. SOME KEY CONCEPTS

The personal data you provide to us is sensitive data that we process in accordance with identified legal bases and in compliance with the highest security standards.

II. SOURCE OF THE PERSONAL DATA WE PROCESS

Personal data is collected when you visit our website, use our products and services, navigate within the app, and contact customer support.

III. YOUR CONSENT

We obtain your consent for specific processing activities. You may withdraw your consent at any time.

IV. PROCESSING OF PERSONAL DATA

We process all Personal Data (as identified below) for a specific purpose and on an identified and necessary legal basis. We retain Personal Data for a specified period.

V. DATA RETENTION

When you use the Products and Services in Europe, your Personal Data is hosted in France.

VI. DATA HOSTING, TRANSFER, AND SECURITY

Your Personal Data is hosted in France, and Health Data is not transferred outside the EEA. Age Impulse will take several measures in the event of a data breach.

VII. EXERCISING YOUR RIGHTS

You may exercise your rights under the GDPR by contacting us at privacy@age-impulse.com. You may also file a complaint with the data protection supervisory authority.

VIII. PRIVACY POLICY FOR PATIENT USERS

Specific provisions regarding the collection and use of your Personal Data, its security, and its sharing with third parties apply to you if you use our remote patient monitoring (“RPM”) services.

I. SOME KEY CONCEPTS

This Privacy Policy applies to the use of the Age Impulse and Gaitwin apps published by Age Impulse. Age Impulse and Gaitwin are free mobile apps that focus on three areas: (i) tracking physical activity, (ii) maintaining motivation, and (iii) preventing the risk of falls. The Gaitwin app can be used on its own or in conjunction with our products. We process the personal data you provide to us in accordance with identified legal bases and the highest security standards.

1.1. DATA ABOUT YOU

“Anonymized data” refers to data resulting from the processing of personal data intended to irreversibly prevent the identification of the data subject, taking into account techniques that can reasonably be implemented.

“Pseudonymized data” refers to personal data that is not directly linked to a natural person without the use of additional information.

“Personal data” refers to any information relating to an identified or identifiable individual. This includes all types of information: last name, first name, mailing address, email address, etc.

1.2. GDPR GLOSSARY

Legal basis refers to the grounds authorizing the Data Controller to process personal data (including the data subject’s consent, the performance of a contract, Age Impulse’s legitimate interest, the protection of vital interests, and compliance with a legal obligation).

Legitimate interest refers to the pursuit of the Data Controller’s core mission (Age Impulse processes non-identifying data to improve research on the basis of legitimate interest).

GDPR refers to the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. It is applied by Age Impulse worldwide.

II. SOURCE OF THE PERSONAL DATA WE PROCESS

Personal data is collected when you visit the website, use our products and services, and navigate the app.

2.1. OUR WEBSITE. For information regarding data collected on the Age Impulse website, please refer to our cookie policy.

2.2. USE OF PRODUCTS AND SERVICES. The use of our Products and Services results in the collection of personal data in the following situations:

a. Account creation. When you create an Age Impulse account, you provide personal data such as a username, age, and email address. This account allows you to access the personal data about you generated while using the Products and Services, and it also allows you to modify certain data.

b. Use of Our Products and Services. When you use our Products and Services, personal data is collected (such as the number of steps, distance traveled, calories burned, your weight, and, in some cases, your location). The data collected varies depending on the app and device you use, as well as how you use them.

c. Customer Support. When you contact customer support, certain personal data related to your Age Impulse account may be temporarily accessible to our teams depending on the issue you are experiencing, such as data regarding the Products you use.

d. Event Tracking. Certain Personal Data is collected automatically when you use the Products and Services, particularly through the use of trackers. We collect technical information such as: IP addresses, language, operating system, location (depending on the permissions you have granted us), and information about the smartphone used (model, version, etc.).

III. YOUR CONSENT

We obtain your consent for specific processing activities. You may withdraw your consent at any time.

3.1. OBTAINING YOUR CONSENT. We obtain your consent to process your data for the following purposes: Creating your Age Impulse account

3.2. WITHDRAWING YOUR CONSENT. You may withdraw your consent at any time. To do so, simply email us at privacy@age-impulse.com

IV. PROCESSING OF PERSONAL DATA

4.1. NECESSITY OF PROCESSING. We collect your personal data in order to carry out the various purposes listed below. If you do not wish to provide us with this information, you will not be able to access certain parts of the Products and Services, or the services offered by our customer support.

4.2. LIST OF DATA PROCESSING ACTIVITIES.

A) USE OF PRODUCTS AND SERVICES

1. Purchase and delivery of your Age Impulse products and services via our website

  • DATA PROCESSED: Company name / Email address / Identification of the product purchased 
  • LEGAL BASIS: Performance of the contract (acceptance of the General Terms and Conditions of Sale)
  • RETENTION PERIOD: Age Impulse is required to retain billing data for 10 years for legal reasons. When you sign up for an Age Impulse subscription, your banking information may be stored with a partner to facilitate the renewal of your subscription.

2. Creating an Age Impulse / Gaitwin Account

  • DATA PROCESSED: Username / Email Address / Date of Birth / Height / Weight
  • LEGAL BASIS: Performance of the contract (acceptance of the Terms of Use).
  • RETENTION PERIOD: The data is retained until your Age Impulse / Gaitwin account is deleted.

3. Graphical presentation of your data via Age Impulse / Gaitwin

  • DATA PROCESSED: Physiological and technical data collected when you use our Products and Services.
  • LEGAL BASIS: Performance of the contract (acceptance of the Terms and Conditions of Use).
  • RETENTION PERIOD: The data is retained until you delete your Age Impulse / Gaitwin account. You also have the option to delete certain data via the app you are registered with.

4. Displaying the route taken during an activity via the Age Impulse app

  • DATA PROCESSED: Location data collected during physical activity
  • LEGAL BASIS: Consent
  • RETENTION PERIOD: The data is retained until the user account is deleted.

B) COMMUNICATION AND SUPPORT

1. Marketing Communications

  • DATA PROCESSED: Email address
  • LEGAL BASIS: Specific consent provided when you created your account
  • RETENTION PERIOD: The data is retained as long as your account is active or until you no longer wish to receive notifications

2. Improving Navigation on the Site

  • DATA PROCESSED: Login data (See Cookie Policy)
  • LEGAL BASIS: Consent obtained via the cookie banner
  • RETENTION PERIOD: 3 months

3. Customer Support – Requests submitted via our Help Center on the Age Impulse app

  • DATA PROCESSED: Email address / Last name / First name / Content of the request.
  • LEGAL BASIS: Necessary for the performance of the contract (acceptance of the Terms and Conditions of Sale/Terms of Use)
  • RETENTION PERIOD: Data associated with the support ticket is retained for 10 years or until the user account is deleted.

4. Customer Support – Requests submitted via Age Impulse’s official social media accounts

  • DATA PROCESSED: Last Name / First Name / Content of the request / Username.
  • LEGAL BASIS: Legitimate interest
  • RETENTION PERIOD: Data associated with the support ticket is retained for 10 years or until the user account is deleted.

5. Customer Support Satisfaction Feedback

  • DATA PROCESSED: Email address
  • LEGAL BASIS: Legitimate interest
  • RETENTION PERIOD: Data associated with the support ticket is retained for a maximum of 5 years.

C) SECURITY AND EXERCISING YOUR RIGHTS

1. Prevention and Combating of Computer Fraud and Cyberattacks

  • DATA PROCESSED: Pseudonymized data regarding the various actions performed by the user
  • LEGAL BASIS: Legitimate interest
  • RETENTION PERIOD: 1 year from the date the action was recorded.

D) RESEARCH AND DEVELOPMENT 

1. Sending out “Research” questionnaires and analyzing the responses received

  • DATA PROCESSED: User ID / The content of the questionnaire varies depending on the issues addressed
  • LEGAL BASIS: Consent of the person completing the questionnaire
  • RETENTION PERIOD: Pseudonymized data is retained until the account is deleted.

2. Anonymization of data for research purposes

  • DATA PROCESSED: Personal data relevant to the study
  • LEGAL BASIS: Consent of the individual

3. Improvement of Products and Services (including improving algorithm performance and compiling statistics)

  • DATA PROCESSED: Relevant data related to the performance of these processing activities. This consists exclusively of pseudonymized data
  • LEGAL BASIS: Legitimate interest
  • RETENTION PERIOD: Personal data is retained until the user account is deleted

4.3. DATA SHARING. We share this data only under the circumstances described below:

a. Your Control Over the Data. You may ask us to disclose information to others, such as when you use our community features, including programs that require sharing with third parties. You may change your preferences at any time by adjusting your account settings or by visiting our Help Center.

b. Internal and Legitimate Sharing. Personal Data may be processed by employees of Age Impulse SAS, within the scope of their respective responsibilities and solely for the purposes described in this Policy.

c. Use of Our Service Providers. We share certain Data with service providers who are experts in their field to enable the provision of Products and Services. Our service providers are required to comply with GDPR regulations and process the shared data solely for the intended purpose. We will use service providers to help us ensure the quality of certain services and products.

d. Legal Reasons. We may share your personal data when required by law, upon a court order, in connection with legal proceedings, or if we believe in good faith that disclosure is reasonably necessary to (a) investigate, prevent, or take action regarding suspected or actual illegal activities, or to assist public authorities; (b) investigate and defend against any claims or allegations by third parties; (c) protect the security or integrity of our services. We will notify you of any legal proceedings seeking access to your Data, unless we are prohibited by law from doing so. In cases where a court order specifies a period during which the request must not be disclosed to the individuals concerned, we will send you a delayed notification after the non-disclosure period has expired.

V. DATA RETENTION

5.1. RETENTION PERIOD. The retention period specified in the list of processing activities depends on the type of data, the purpose of the processing, and our legal obligations. If you request it, Age Impulse will delete your personal data from its servers and instruct its data processors involved in the processing to do the same. We use data processors to manage backup data. This data will be used in the event of an operational issue to ensure the continuity of our services and products. Please note that, for security reasons, we are unable to apply data deletions or modifications to backups that have already been made, in order to protect the integrity of the backup data.

5.2. INACTIVE ACCOUNTS. Your Age Impulse/Gaitwin account will be considered inactive if, for a period of 3 years, (i) you have not used the mobile or web app, (ii) you have not taken any measurements using the Age Impulse/Gaitwin products associated with the account, and (iii) you have not clicked on any links contained in an email sent by Age Impulse. You will receive an email notification 90 days before your account is deemed inactive, giving you the opportunity to continue your Age Impulse experience. If you do not take any action, your account and the associated data will be deleted in accordance with this Privacy Policy.

5.3. ANONYMIZED DATA. Age Impulse may anonymize your data in accordance with applicable security standards and regulations. Once anonymized, the data can no longer be used to identify you and is no longer considered Personal Data. Age Impulse uses the data in this form to participate in research projects.

5.4. DATA SHARED WITH THIRD PARTIES. If you have chosen to share your data from Age Impulse Products and Services with third parties, we cannot guarantee the deletion or anonymization of that data. We encourage you to contact the third party for more information.

VI. DATA HOSTING, TRANSFER, AND SECURITY

Your Personal Data is hosted in France. Age Impulse will take several measures in the event of a data breach.

VII. EXERCISING YOUR RIGHTS

You may exercise your rights by contacting us at privacy@age-impulse.com.

7.1. YOUR RIGHTS. You may exercise the following rights on your own or with our assistance.

a. Right of Access. You may access the Personal Data concerning you that is processed, collected, or stored by Age Impulse. You can obtain this information through customer support.

b. Right to Rectification. If you find that the data concerning you is inaccurate, you have the right to request that it be corrected. Certain personal data can be modified directly from your Age Impulse/Gaitwin account. 

c. Right to restriction of processing and right to object. If you find that data about you is inaccurate, you may ask us to stop processing that data until the situation is corrected. You may also ask us to stop processing your Personal Data.

d. Right to erasure. You may request the deletion of your Personal Data. We will assist you in deleting your Personal Data through your account or customer support.

e. Right to data portability. You may ask us to provide you with your Personal Data so that you can transfer it to another company. Instructions on how to exercise your right to data portability are available by contacting our Help Center.

7.2. ASSISTANCE IN EXERCISING YOUR RIGHTS.

You may exercise your rights at any time by writing to privacy@age-impulse.com. You may be asked to provide proof of identity if we have no other way to verify that you are the account holder to whom the data pertains. Age Impulse processes all requests that are not excessive within the timeframes set forth by the GDPR.

7.3. ASSISTANCE FROM THE CNIL.

In the event of a dispute, you have the right to file a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL), whose headquarters are located at 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 7.

GaiTwin – Consent Form – Participation in the Functional Mobility Assessment

Age_Impulse_Informed_Consent_Form_EN_Professional

Consent Form Participation in the Functional Mobility Assessment – Download