privacy policy

last updated: 18. Sep 2021

Table of contents

Identity and contact details of the data controller
Contact details of the data protection officer
General information on data processing
Rights of the data subject
Provision of website and creation of log files
Use of cookies
Newsletter
Contact via Email
Contact form
Corporate web profiles on social networks
Use of corporate profiles in professionally oriented networks
Hosting
Geotargeting
Registration
Usage of Plugin

Identity and contact details of the data controller

The data controller responsible in accordance with the purposes of the UK General Data Protection Regulation (UK GDPR) and other data protection regulations is:

sofi health ltd
201 Haverstock Hill Second Floor C/O Fkgb
London, NW3 4QG
UK
+44 79 00 000 456
hello@sofi.health
join.sofi.health

Contact details of the data protection officer

The designated data protection officer is:

DataCo International UK Limited

c/o One Peak Partners, 41 Great Pulteney Street 2nd floor

London W1F 9NZ

United Kingdom

+44 20 3318 17 18

www.dataguard.co.uk

General information on data processing

1. Scope of processing personal data

In general, we only process the personal data of our users to the extent necessary to provide a functioning website with our content and services. The regular processing of personal data only takes place with the consent of the user. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.

2. Legal basis for data processing

Where consent is appropriate for processing personal data, Art. 6 (1) (1) (a) UK GDPR serves as the legal basis to obtain the consent of the data subject for the processing of their data.

As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (1) (b) UK GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.

When it is necessary to process personal data in order to fulfil a legal obligation to which our company is subject, Art. 6 (1) (1) (c) UK GDPR serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (1) (d) UK GDPR serves as the legal basis.

If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (1) (f) UK GDPR will serve as the legal basis for the processing of data.

3. Data removal and storage duration

The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if this is provided for by international regulations, laws, or other relevant regulations to which the data controller is subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfiling the respective contract.

Rights of the data subject

When your personal data is processed, you are a data subject within the meaning of the UK GDPR and have the following rights:

1. Right to information

You may request the data controller to confirm whether your personal data is processed by them.

If such processing occurs, you can request the following information from the data controller:

The purpose for which the personal data is processed.
The categories of personal data being processed.
The recipients or categories of recipients to whom the personal data have been or will be disclosed.
The planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage.
The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing.
The existence of the right to lodge a complaint with a supervisory authority.
Where personal data are not collected from you any available information as to their source.
The existence of automated decision-making including profiling under Article 22 (1) and Article 22 (4) UK GDPR and, in certain cases, meaningful information about the data processing system involved, and the scope and intended result of such processing on the data subject.

You have the right to request information on whether your personal data will be transmitted to a third country or an international organization. In this context, you can then request for the appropriate guarantees in accordance with Art. 46 UK GDPR in connection with the transfer.

Your right to information may be limited where it is likely that such restriction will render impossible or seriously impede the achievement of scientific or statistical purposes and that such limitation is necessary for the achievement of scientific or statistical purposes.

2. Right to rectification

You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay

Your right to rectification may be limited to the extent that it is likely to render impossible or seriously impair the achievement of the purposes of the research or statistical work and the limitation is necessary for the achievement of the purposes of the research or statistical work.

3. Right to the restriction of processing

You may request the restriction of the processing of your personal data under the following conditions:

If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
If you have objected to the processing pursuant to Art. 21 (1) UK GDPR and it is not yet certain whether the legitimate interests of the data controller override your interests.

If the processing of personal data concerning you has been restricted, this data may – with the exception of data storage – only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the processing has been restricted according to the aforementioned conditions, you will be informed by the data controller before the restriction is lifted.

Your right to restrict the processing may be limited where it is likely that such restriction will render impossible or seriously impede the achievement of scientific or statistical purposes and that such limitation is necessary for the achievement of scientific or statistical purposes.

4. Right to erasure

a) Obligation to erase

If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:

Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
You withdraw your consent on which the processing is based pursuant to Art. 6 (1) (1) (a) and Art. 9 (2) (a) UK GDPR and where there is no other legal basis for processing the data.
According to Art. 21 (1) UK GDPR you object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) UK GDPR.
Your personal data has been processed unlawfully.
The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject.
Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) UK GDPR.

b) Information to third parties

If the data controller has made your personal data public and must delete the data pursuant to Art. 17 (1) UK GDPR, they shall take appropriate measures, including technical means, to inform data processors who process the personal data, that a request has been made to delete all links to such personal data or copies or replications of the personal data, taking into account available technology and implementation costs to execute the process.

c) Exceptions

The right to deletion does not exist if the processing is necessary

to exercise the right to freedom of speech and information.
to fulfil a legal obligation required by the law of the Union or Member States to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative.
for reasons of public interest in the field of public health pursuant to Art. 9 (2) (h) and Art. 9 (2) (i) and Art. 9 (3) UK GDPR.
for archival purposes of public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) UK GDPR, to the extent that the law referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or
to enforce, exercise or defend legal claims.

5. Right to information

If you have the right of rectification, erasure or restriction of processing over the data controller, they are obliged to notify all recipients to whom your personal data have been disclosed of the correction or erasure of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.

You reserve the right to be informed about the recipients of your data by the data controller.

6. Right to data portability

You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:

the processing is based on consent in accordance with Art. 6 (1) (1) (a) UK GDPR or Art. 9 (2) (a) UK GDPR or performance of a contract in accordance with Art. 6 (1) (1) (b) UK GDPR and
the processing is done by automated means.

In exercising this right, you also have the right to transmit your personal data directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the data controller.

7. Right to object

For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (1) (e) or 6 (1) (1) (f) UK GDPR; this also applies to profiling based on these provisions.

The data controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, exercising or defending legal claims.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Regardless of Directive 2002/58/EG, you have the option, in the context of the use of information society services, to exercise your right to object to automated decisions that use technical specifications.

You also have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out for scientific or historical research purposes or for statistical purposes pursuant to Article 89 (1) of the UK GDPR.

Your right to objection may be limited where it is likely that such restriction will render impossible or seriously impede the achievement of scientific or statistical purposes and that such limitation is necessary for the achievement of scientific or statistical purposes.

8. Right to withdraw the data protection consent declaration

You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.

9. Automated decisions on a case-by-case basis, including profiling

You have the right to not be subject to a decision based solely on automated processing – including profiling – that will have a legal effect or substantially affect you in a similar manner. This does not apply if the decision:

is required for the conclusion or execution of a contract between you and the data controller,
is permitted by the Union or Member State legislation to which the data controller is subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or
is based on your eplicit consent.

However, these decisions must not be based on special categories of personal data under Art. 9 (1) UK GDPR, unless Art. 9 (2) (a) or Art. 9 (2) (b) UK GDPR applies and reasonable measures have been taken to protect your rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in (1) and (3), the data controller shall take appropriate measures to uphold your rights and freedoms as well as your legitimate interests, including the right to obtain assistance from the data controller or his representative, to express your opinion on the matter, and to contest the decision.

10. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in the Member State of your residence, or your place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you violates the UK GDPR. If you are located in the United Kingdrom, you shall have the right to complain to the ICO if you are unhappy with how we have used you data and/or believe that the processing of the personal data concerning you violates the applicable law. The ICO´s address: Information Commissioner´s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk

The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 UK GDPR.

Provision of website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device.

The following data is collected:

Browser type and version used
The user’s operating system
The IP address of the user
Date and time of access
Web pages from which the user’s system accessed our website
Web pages accessed by the user’s system through our website

This data is stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Purpose of data processing

The temporary storage of the IP address by the system is necessary for the delivery of the website to the computer of the user. For this purpose, the user’s IP address must be kept for the duration of the session.

The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimize the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.

For the aforementioned purposes, our legitimate interest lies in the processing of data in compliance with Art. 6 (1) 1 (f) UK GDPR.

3. Legal basis for data processing

The legal basis for the temporary storage of data and logfiles is Art. 6 (1) (1) (f) UK GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the website is accomplished.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is not possible.

5. Objection and removal

The collection of data for the provision of the website as well as the storage of data in log files are essential for the operation of the website. Therefore, the user may not object to the aforementioned processes.

Use of cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the internet browser or the internet browser on the user’s computer system. If a user calls up a website, a cookie can be stored on the user’s operating system. These cookies contain a string of characters that allows the browser to be uniquely identified when the website is reopened.

We use cookies to make our website more user-friendly. Some elements of our website require the calling browser to be identified even after a page break.

The following data is stored and transmitted in the cookies:

Language settings
Log-in information
Entered search queries
Frequency of page views
Use of website functionalities

The user data collected in this manner is pseudonymised by technical measures. It is therefore not possible to assign the data to the user accessing the site. The data is not stored together with other personal data of the users.

2. Purpose of data processing

The purpose of using technical cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. These require that the browser is recognized even after a page change.

We need cookies for the following purposes:

Applying language settings
Storage of search terms

The user data collected by technical cookies are not used to create user profiles.

3. Legal basis for data processing

The legal basis for the processing of personal data using technical cookies is Art. 6 (1) (1) (f) UK GDPR, legitimate interests.

4. Duration of storage and possibility of objection and removal

Cookies are stored on the user’s device and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it is possible that not all functions of the website can be used to their full extent.

The transmission of Flash cookies cannot be prevented via the browser settings, but by changing the settings of the Flash Player.

If you use the Safari browser version 12.1 or higher, cookies will be automatically deleted after seven days. This also applies to opt-out cookies, which are used to prevent the use of tracking mechanisms.

1. Description and scope of data processing

You can subscribe to a newsletter on our website free of charge. When subscribing for the newsletter, the data from the input mask is transmitted to us.

Email address
Last name
First name
Pseudonym
IP address of the user’s device
Date and time of registration

No data will be passed on to third parties in connection with data processing for the dispatch of newsletters. The data will be used exclusively for sending the newsletter.

2. Purpose of data processing

The user’s email address is collected to deliver the newsletter to the recipient.

Additional personal data as part of the registration process is collected to prevent misuse of the services or email address.

3. Legal basis for data processing

The legal basis for the processing of data provided by the user after registration for the newsletter is Art. 6 (1) (1) (a) UK GDPR if the user has given his consent.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The user’s email address will therefore be stored as long as the newsletter subscription is active.

The other personal data collected during the registration process is generally deleted after a period of seven days.

5. Objection and removal

The subscription for the newsletter can be cancelled by the data subject at any time. For this purpose, every newsletter contains an opt-out link.

Through this, it is also possible to withdraw the consent to the storage of personal data collected during the registration process.

Contact via Email

1. Description and scope of data processing

You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored.

The data will be used exclusively for the processing of the conversation.

2. Purpose of data processing

If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

3. Legal basis for data processing

If the user has given consent, the legal basis for processing the data is Art. 6 (1)(a) UK GDPR.

The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (1) (f) UK GDPR. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) UK GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Objection and removal

The user has the possibility to withdraw consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time.

All Pioneers and sofi customers can revoke consent by writing to us at hello@sofi.health.

In this case, all personal data stored while establishing contact will be deleted.

Contact form

1. Description and scope of data processing

A Contact form is available on our website, which can be used for electronic contact. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored.

When sending the message the following data will also be stored:

Email address
Last name
First name
IP address of the user’s device
Date and time of contact

As part of the sending process, your consent will be obtained for the processing of your data and reference will be made to this privacy policy.

Alternatively, you can contact us via the email address provided. In this case the personal data of the user transmitted with the email will be stored.

The data will be used exclusively for the processing of the conversation.

2. Purpose of data processing

The processing of the personal data from the input mask serves us exclusively for the purpose of establishing contact. If you contact us by email, this also constitutes our necessary legitimate interest in the processing of the data.

The other personal data processed during the sending process serve to prevent misuse of the Contact form and to ensure the security of our information technology systems.

3. Legal basis for data processing

The legal basis for the processing of the data is Art. 6 (1) (1) (a) UK GDPR if the user has given his consent.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the Contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be inferred from the circumstances that the facts in question have been conclusively clarified.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Objection and removal

The user has the possibility to withdraw the consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time.

All Pioneers and sofi customers can revoke consent by writing to us at hello@sofi.health.

In this case, all personal data stored while establishing contact will be deleted.

Corporate web profiles on social networks

Use of corporate profiles on social networks

Instagram:

Instagram, Part of Facebook Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2 Ireland

On our company profile we provide information and offer Instagram users the possibility of communication. If you carry out an action on our Instagram company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Instagram, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:

to explain the sofi platform, demonstrate the range of formulations and plants available, disseminate research and core findings, and provide a community we call the “treehouse” where Pioneers and sofi customers can engage.

Publications on the company profile can contain the following content:

Information about products
Information about services
Customer contact
Online community | “the treehouse”

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (1) (a) UK GDPR.

We store your activities and personal data published on our Instagram corporate profile until you withdraw your consent. Furthermore, we comply with the statutory retention periods.
We process data from our corporate web profile in our own systems as well. The data is stored there for the following period: Indefinitely unless requested otherwise by a Pioneer or sofi customer.
You can object at any time to the processing of your personal data that we collect within the framework of your use of our Instagram corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to hello@sofi.health. For further information on the processing of your personal data by Instagram and the corresponding objection options, please click here:

Instagram: https://help.instagram.com/519522125107875

Pinterest:

Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:

Publications on the company profile can contain the following content:

Information about products
Information about services
Customer contact
Online community | “the treehouse”

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (1) (a) UK GDPR.

We store your activities and personal data published on our Pinterest corporate profile until you withdraw your consent. Furthermore, we comply with the statutory retention periods.
We process data from our corporate web profile in our own systems as well. The data is stored there for the following period: Indefinitely unless requested otherwise by a Pioneer or sofi customer.
You can object at any time to the processing of your personal data that we collect within the framework of your use of our Pinterest corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to hello@sofi.health. For further information on the processing of your personal data by Pinterest and the corresponding objection options, please click here:

Pinterest: https://policy.pinterest.com/de/privacy-policy

Twitter:

Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:

Publications on the company profile can contain the following content:

Information about products
Information about services
Customer contact
Online community | “the treehouse”

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (1) (a) UK GDPR.

We store your activities and personal data published on our Twitter corporate profile until you withdraw your consent. Furthermore, we comply with the statutory retention periods.
We process data from our corporate web profile in our own systems as well. The data is stored there for the following period: Indefinitely unless requested otherwise by a Pioneer or sofi customer.
You can object at any time to the processing of your personal data that we collect within the framework of your use of our Twitter corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to hello@sofi.health. For further information on the processing of your personal data by Twitter and the corresponding objection options, please click here:

Twitter: https://twitter.com/de/privacy

YouTube:

YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company’s profile for:

Publications on the company profile can contain the following content:

Information about products
Information about services
Customer contact
Online community | “the treehouse”

Every user is free to publish personal data.

The legal basis for data processing is Art. 6 (1) (1) (a) UK GDPR.

We store your activities and personal data published on our YouTube corporate profile until you withdraw your consent. Furthermore, we comply with the statutory retention periods.
We process data from our corporate web profile in our own systems as well. The data is stored there for the following period: Indefinitely unless requested otherwise by a Pioneer or sofi customer.
You can object at any time to the processing of your personal data that we collect within the framework of your use of our YouTube corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to hello@sofi.health. For further information on the processing of your personal data by YouTube and the corresponding objection options, please click here:

YouTube: https://policies.google.com/privacy?gl=DE&hl=en

Use of corporate profiles in professionally oriented networks

1. Scope of data processing

We use corporate profiles on professionally oriented networks. We maintain a corporate presence on the following professionally oriented networks:

LinkedIn:

LinkedIn, Unlimited Company Wilton Place, Dublin 2, Ireland

On our site we provide information and offer users the possibility of communication.

The corporate profile is used for job applications, information, public relations, and active sourcing.

We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate profile. Further information can be found in the privacy policy of:

LinkedIn:

https://www.linkedin.com/legal/privacy-policy

If you carry out an action on our company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public.

2. Legal basis for data processing

The legal basis for the processing of your data in connection with the use of our corporate web profile is Art. 6 (1) (1) (f) UK GDPR.

3. Purpose of the data processing

Our corporate web profile serves to inform users about our services. Every user is free to publish personal data.

4. Duration of storage

We store your activities and personal data published via our corporate web profile until you withdraw your consent. In addition, we comply with the statutory retention periods.

5. Objection and removal

You can object at any time to the processing of your personal data which we collect within the scope of your use of our corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to the email address stated in this privacy policy.

You can find further information on objection and removal options here:

LinkedIn:

https://www.linkedin.com/legal/privacy-policy

Hosting

The website is hosted on servers of a service provider commissioned by us.

Our service provider is:

wpengine.com

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:

Browser type and version
Used operating system
Referrer URL
Hostname of the accessing computer
Time and date of the server request
IP address of the user’s device

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (1) (f) UK GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – and server log files are therefore recorded.

The server of the website is geographically located in the European Union (EU) or the European Economic Area (EEA).

Geotargeting

We use the IP address and other information provided by the user (e.g. the postal code used for registration or ordering) to approach regional target groups (so-called “geotargeting”).

The regional target group approach is used, for example, to automatically display regional offers or advertisements that often are more relevant to users. The legal basis for the use of the IP address and any other information provided by the user (e.g. postal code) is Art. 6 (1) (1) (f) UK GDPR, based on our legitimate interest in ensuring a more precise target group approach and thus providing offers and advertising with greater relevance for our users.

Part of the IP address and the additional information provided by the user (e.g. postal code) are merely processed and not stored separately.

You can prevent geotargeting by, for example, using a VPN or proxy server that prevents accurate localisation. In addition, depending on the browser you are using, you can also deactivate a location localisation in the corresponding browser settings (as far as this is supported by the respective browser).

We use geotargeting on our website for the following purposes:

Geoblocking
Customer approach
Advertising purposes

Registration

1. Description and scope of data processing

We offer users the opportunity to register by providing personal data. The data is entered into an input mask and transmitted to us and stored. The data will not be passed on to third parties. The following data is collected as part of the registration process:

Email address
Last name
First name
Address
Telephone / mobile phone number
IP address of the user’s device
Date and time of registration
Survey questions

As part of the registration process, the user’s consent to the processing of this data is obtained.

2. Purpose of data processing

A registration of the user is necessary for the fulfilment of a contract with the user or for the execution of pre-contractual measures.

We maintain details to authenticate Pioneers and sofi customers.

3. Legal basis for data processing

The legal basis for the processing of the data is Art. 6 (1) (1) (a) UK GDPR if the user has given his consent.

If the registration serves the fulfilment of a contract to which the user is a party or the execution of pre-contractual measures, the additional legal basis for the processing of the data is Art. 6 (1) (1) (b) UK GDPR.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected.

This is the case for the data collected during the registration process for the execution of a contract or for the implementation of pre-contractual measures if the data is no longer required for the execution of the contract. Even after the conclusion of the contract, it may be necessary to store personal data of the contractual partner in order to comply with contractual or legal obligations.

5. Objection and removal

As a user you have the possibility to cancel the registration at any time. You can request a change to the data stored about you at any time.

We ask all Pioneers and sofi customers to write directly to us requesting a removal of their data by emailing hello@sofi.health.

If the data is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures, a premature deletion of the data is only possible insofar as contractual or legal obligations do not stand in the way of a deletion.

Usage of Plugins

We use plugins for various purposes. The plugins used are listed below:

Use of Google AdWords

1. Scope of processing of personal data

We use Google AdWords of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). With this service we place advertisements. Google places a cookie on your computer. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and operating system), data about the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data from advertising partners (in particular pseudonymised user IDs).
Further information on the collection and storage of data by Google can be found here:
https://policies.google.com/privacy?hl=en-GB

2. Purpose of data processing

We only obtain knowledge of the total number of users who have responded to our advertisement. We will not share any information that could be used to identify you. The use does not serve the traceability.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (1) (a) UK GDPR.

4. Duration of storage

Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.

5. Possibility of revocation of consent and removal

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You can prevent the collection and processing of your personal data by Google by preventing the storage of cookies from third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by using a script blocker such as a browser browser browser.B. Install NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.
With the following link you can deactivate the use of your personal data by Google:
https://adssettings.google.com
Further information on objection and removal options against Google can be found at:\https://policies.google.com/privacy?gln=EN&hl=en

Use of Google Analytics

1. Scope of processing of personal data

We use Google Analytics, a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). Google Analytics examines, among other things, the origin of visitors, their length of stay on individual pages and the use of search engines, thus allowing better monitoring of the success of advertising campaigns. Google places a cookie on your computer. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and the operating system), data on the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data on advertising partners (in particular pseudonymised user IDs). The information generated by the cookie about your use of this website will be transmitted to and stored by Google on servers in the United States. However, if IP anonymization is enabled on this online presence, Google will previously truncate your IP address within member states of the European Union or other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
On behalf of the operator of this online presence, Google will use this information to evaluate your use of the online presence, to compile reports on the activities of the online presence and to provide further services associated with the use of the online presence and the Internet use to the operator of the online presence. The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website.\Further information on the collection and storage of data by Google can be found here:
https://policies.google.com/privacy?hl=en-GB

2. Purpose of data processing

The purpose of processing personal data is to specifically address a target group that has already expressed an initial interest by visiting the site.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (1) (a) UK GDPR.

4. Duration of storage

Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law. Advertising data in server logs is anonymized by Google’s own statements to delete parts of the IP address and cookie information after 9 and 18 months respectively.

5. Possibility of revocation of consent and removal

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You may prevent the collection and processing of your personal data by Google by preventing the storage of cookies by third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. your IP address) to Google and to prevent the processing of this data by Google by downloading and installing the browser plug-in available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en
With the following link you can deactivate the use of your personal data by Google:
https://adssettings.google.com\Further information on objection and removal options against Google can be found at:
https://policies.google.com/privacy?gl=EN&hl=en

Use of Instagram Plugin

1. Scope of processing of personal data

We use plugins of the Instagram service of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA and their representatives in the Union Facebook Ireland Ltd. 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Hereinafter referred to as Facebook). The integrated Instagram buttons are used by us to link to our Instagram profile. Also included is a widget that allows us to display certain photos and videos from our Instagram profile on our online presence. When you visit one of our pages that contains such a plug-in, your browser connects directly to a Facebook server. The contents of the plug-ins are transmitted directly to your browser and integrated into the online presence. Data is automatically transferred to Instagram and stored on its servers. This transmitted data includes connection data (such as your IP address, date and time, the URL accessed) as well as the browser and operating system used.
Your visit to our site can be tracked by Instagram even if you are not actively using the plug-in features.
If you are logged into your Instagram account, you can click the Instagram button to link the contents of our site to your Instagram profile. This allows Instagram to assign the visit to our pages to your user account. If you want to prevent this direct assignment, you must log out of Instagram before visiting our online presence. \For more information, see Instagram’s privacy policy:
https://help.instagram.com/519522125107875

2. Purpose of data processing

The use of the Instagram Plug-In serves to improve the public image of our company.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (1) (a) UK GDPR.

5. Possibility of revocation of consent and removal

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You can prevent Instagram from collecting and processing your personal information by preventing third party cookies from being placed on your computer, by using the “Do Not Track” feature of a supporting browser, by disabling script code execution in your browser, or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.\For more information about objection and removal options for Instagram, visit:
https://help.instagram.com/519522125107875

Use of LinkedIn

1. Scope of processing of personal data

We use functions of the network LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland (Hereafter referred to as LinkedIn). Each time you access one of our pages that contains LinkedIn functions, a connection is established to LinkedIn servers. LinkedIn will be informed that you have visited our website with your IP address. If you click the LinkedIn “Recommend” button and are logged into your LinkedIn account, LinkedIn will be able to associate your visit to our website with you and your user account. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on) and device and browser information (in particular the IP address and the operating system).
We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by LinkedIn. For more information on LinkedIn’s collection and storage of data, please visit:
https://www.linkedin.com/legal/privacy-policy

2. Purpose of data processing

The use of the LinkedIn Plugin serves the usability of our online presence.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (1) (a) UK GDPR.

5. Possibility of revocation of consent and removal

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You can prevent LinkedIn from collecting and processing your personal data by preventing the storage of third-party cookies on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. Furthermore, the transmission may be prevented by logging out of your LinkedIn account before accessing our website.
The following links will allow you to deactivate the use of your personal data by LinkedIn:
https://www.linkedin.com/psettings/guest-controlsy
For further information on the possibilities of objection to and removal from LinkedIn, please visit:
https://www.linkedin.com/legal/privacy-policy

Use of Adobe Fonts

1. Scope of processing of personal data

We use fonts using Adobe Fonts from Adobe Systems Software Ireland Limited, 6 Riverwalk, Naas Road 24, Dublin, Ireland (Hereinafter referred to as Adobe). The fonts are transferred to the browser’s cache when the page is called up in order to be able to use them for the visually improved display of various information. If the browser does not support Adobe Fonts or prevents access, the text is displayed in a standard font. When the page is accessed, no cookies are stored for the online presence visitor. Data transmitted in connection with the page view is sent to resource-specific domains such as use.typekit.net or use.typekit.com. The following data will be processed:
– Provided Fonts
– ID of the WEBPROJECT
– JavaScript version of the WEBPROJECT (String)
– Type of WEBPROJECT (String “configurable” or “dynamic”)
– Embedding type (whether you use the JavaScript or CSS embedding code)
– Account ID (identifies the customer from whom the WEBPROJECT originated)
– Service that provides the fonts (e.g. B. Adobe Fonts or Edge Web Fonts)
– Application that requests the fonts (e.g., Adobe Muse)
– Server that provides the fonts (e.g., Adobe Muse)
– Server that provides the fonts). B. Adobe Fonts or Company CDN)
– Host name of the page on which the fonts are loaded
– The time it takes for the web browser to download the fonts
– The time it takes for the web browser to download the fonts and apply the fonts
– Whether an ad blocker is installed to determine if the ad blocker interferes with the correct tracking of page views
– IP address of the website visitor, operating system, and browser version
For more information about Adobe’s collection and retention of data, please visit:
https://www.adobe.com/privacy/policies/adobe-fonts.html and
https://www.adobe.com/privacy/policy.html

2. Purpose of data processing

The use of Adobe Fonts serves an appealing representation of our texts. If your browser does not support this feature, a standard font will be used by your computer to display it.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (1) (a) UK GDPR.

4. Duration of storage

Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law.

5. Possibility of revocation of consent and removal

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You can prevent the collection and processing of your personal data by Adobe by preventing the storage of third-party cookies on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser, or by using a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.
With the following link you can deactivate the use of your personal data by Adobe:
https://www.adobe.com/de/privacy/opt-out.html
For more information on opposition and removal options against Adobe, please visit:
https://www.adobe.com/privacy/policies/adobe-fonts.html and https://www.adobe.com/privacy/policy.html

Use of DocuSign

1. Scope of processing of personal data

We use functionalities of the DocuSign e-signature platform of Docusign, Inc. 221 Main Street, Suite 1000, San Francisco, CA 94105, USA and their representatives in the Union DocuSign, Inc., Broadgate Quarter, 9 Appold Street, 2nd Floor, London, EC2A 2AP, UK (Hereinafter referred to as DocuSign). DocuSign allows us to forward offers, contracts or other agreements to customers and partners and to have them electronically or digitally signed by them. The following personal data in particular will be processed by DocuSign as part of this process:
– Name
– Email Address
– Postal Address
– Phone Number
– Billing Data or Electronic Signature
– IP Address
– Geographical Location, that you have allowed to be captured by our apps (usually via your mobile device)
– Unique identifiers (UDI) of your device and its characteristics such as operating system and browser type
– Web log data
– References and end pages
– Reference and End URLs
– Platform Type
– Number of Calls
– Domain Names
– Destination Pages
– Viewed Pages and Content and the Order of Call of these Pages
– Time Spent on Individual Pages
– Date and Time
– Frequency, in which you have used DocuSign services
– error logs and similar data
– names and email addresses of parties to an envelope
– subject matter of an envelope
– history of actions taken by individuals with respect to an envelope (e.g., error logs and similar data
)B . Verification, Signing)
-Authentication Methods

DocuSign uses cookies, web beacons, locally released objects and tracking pixels. Your settings and user name are stored in the cookies; they are also used to align advertising with your interests. All e-document data that DocuSign processes within the scope of using the DocuSign service is automatically encrypted with an AES 256-bit or comparable key. The data will be transferred to third countries, in particular the USA. DocuSign has adopted Binding Corporate Rules (BCR) to enable the transfer of personal data from the EEA to DocuSign locations outside the EEA. You can find DocuSign’s Binding Corporate Rules at https://trust.docusign.com/en-us/trust-certifications/GDPR/bcr-p-processor-privacy-code and https://trust.docusign.com/en-us/trust-certifications/GDPR/bcr-c-csb-privacy-code.\Further information on the collection and storage of data by DocuSign can be found here:
https://www.docusign.co.uk/company/privacy-policy

2. Purpose of data processing

The use of DocuSign enables us to carry out electronic or digital signatures of offers, contracts or other agreements and the proof of effectiveness through the documentation of the transaction.

3. Legal basis for the processing of personal data

The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (1) (a) UK GDPR.

4. Duration of storage

DocuSign shall not retain your personal data for longer than is necessary for the purposes of processing them. The duration for which DocuSign keeps data depends on the purpose for which the data was collected and used and / or corresponds to the period required by applicable law. In the event of technical limitations that prevent deletion or anonymization, DocuSign protects personal data and restricts its active use.

5. Possibility of revocation of consent and removal

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You can prevent the collection and processing of your personal data by DocuSign by preventing the storage of cookies from third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. You can exercise your right of revocation at any time by sending an email to us or to privacy@docusign.com.\Further information on objections and remedies against DocuSign can be found here:
https://www.docusign.co.uk/company/privacy-policy

Integration of plugins via external service providers

1. Description and scope of data processing

We integrate certain plugins on our website via external service providers in the form of content delivery networks. When you access our website, a connection is established to the servers of the providers used by us to retrieve content and store it in the cache of the user’s browser. This allows personal data to be stored and evaluated in server log files, in particular device and browser information (e.g. IP address and operating system). We use the following services:

Discourse, Klaviyo, Typeform

2. Purpose of data processing

The use of the functions of these services serves the delivery and acceleration of online applications and content.

3. Legal basis for data processing

This data is collected on the basis of Art. 6 (1) (1) (f) UK GDPR. The website operator has a justified interest in the technically correct presentation and optimization of the website.

4. Duration of storage

Your personal information will be retained for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law.

5. Objection and removal

Contact Us
If you have any questions about this Privacy Policy, You can contact us by email at hello@sofi.health

Thank you.