GERO
PRIVACY POLICY

Unless the context otherwise requires or as otherwise noted, references in this Terms and Conditions to the "company," "Gero", "we," "us" and "our" refer to Gero LLC, Address: 22-3, Boytsovaya str., Moscow, Russian Federation 107150

Gero is committed to protecting your privacy and handling your data in an open and transparent manner. The personal data we collect and process depends on the product or service requested and agreed in each case.

In this privacy statement, your data is sometimes called "personal data" or "personal information". We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data or any such action as "processing" such personal data.

For the purposes of this statement, personal data shall mean any information relating to you which identifies or may identify you and which includes, for example, your name, address, identification number.

Process, Processed, Processing shall mean any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means. Operations performed may include collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, analysis, calculations based on Data, publication of results of calculations and analysis, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Consent shall mean any freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

Data Controller - the entity that determines the purposes, conditions and means of the processing of personal data

Data Processor - the entity that processes data on behalf of the Data Controller

Data Subject - a natural person whose personal data is processed by a controller or processor

Product or Gero app - Gero mobile device application

Any other definitions not expressly defined here are used in the meaning as it set in Gero application (Product) Terms and Conditions, or if is not set there in general meaning.

What information do we collect and how do we use it?

To use Product you will have the choice to login either via Facebook either by submitting your e-mail; Depending on how you log in we will capture different volume of information, in more details specified in Annex 1. Some of the data we process is likely to constitute sensitive personal data: health-related data. This information allows us to process and fulfil your order successfully. It also helps us in maintaining your account. A more detailed explanation is found in Annex 1 hereto forming an integral part of this policy.

The purpose of the Product is to provide you with a tool for informational purpose only and to provide Gero with data for the purposes described in Terms and Conditions and this Privacy Policy. We may study a specific group or population, identify potential areas or targets for therapeutics development, conduct or support the development of drugs, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on similar research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve health care, wellness, entertainment, insurance, advertising, marketing, banking and other fields wherein it can be useful and legally applicable. We can develop and commercialize commercial product based on the model built using Health Data collected by the Product, create an intellectual property, publish Data, including but not limited to Health Data and the results of analysis of Data, including but not limited to Health Data. We may also disclose your Health Data (not the Personal Data) to our subcontractors and transfer your Health Data to the third party researchers in order to improve general knowledge on health, medical and fitness management and for the purposes of various medical researches and non-profit or commercial products and services development and validation. We can develop and commercialize commercial product based on the model built using Health Data collected by the Product, create an intellectual property, publish Data, including but not limited to Health Data and the results of analysis of Data, including but not limited to Health Data. We will not disclose or anyhow transfer your Personal Data to any third party, unless required by law or we have your express consent to do so to :

  • The US Department of Health and Human Services (HHS), the Office for Human Research Protection (OHRP), the Food and Drug Administration (FDA), and other agencies for review of our research procedures.
  • Interregional Independent Ethical Committee associated with Autonomous Non-Profit Organization "Clinical Pharmacology Institute" and other ethical organisations.
  • Others, if the law requires.
Upon your written consent and approval, we may use and disclose your Health Information for computing your Healthspan and Biological Age

Whether you have an obligation to provide us with your personal data

During a client's registration, client provides information such as name, email address, other relevant data stipulated in more detail in the Annex 1. This information is used by Gero if the client consents to do so, to identify you, make calculations of Healthspan and Biological Age and provide you with support services, mailings, sales and marketing actions, billing and to meet contractual obligations we have with you. Kindly note that if you do not provide us with the required data, then we will not be allowed to commence or continue our research and business relationship either to you as an individual or as the authorized representative/agent or beneficial owner of a legal entity.

Why we process your personal data and on what legal basis

  1. For the performance of a contract
  2. For compliance with a legal obligation
  3. For the purposes of safeguarding legitimate interests
Provided that you have given us your specific consent for processing then the lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.

We process information by users using the Product.

The app is a prototype and at the moment we would like to limit for users the use of this free prototype by entertainment purposes, at the same time working on refining our healthspan, biological age, health risks and mortality risks predictive models and using it for marketing, research and development purposes. In more details the purposes are stipulated in the Annex 1.

Who receives your personal data?

In the course of the performance of our contractual and statutory obligations your personal data may be provided to various departments within Gero. Various service providers and suppliers may also receive your personal data so that we may perform our obligations. Such service providers and suppliers enter into contractual agreements with Gero by which they observe confidentiality and data protection according to the data protection law and GDPR. Gero may disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if you have given your consent. All data processors appointed by us to process personal data on our behalf are bound by contract to comply with the GDPR provisions.

Under the circumstances referred to above, recipients of personal data may be, for example:

  • External legal consultants
  • Financial and business advisors
  • Auditors and accountants
  • Marketing companies and market research companies
  • Card Payment processing companies
Transfer of your personal data to a third country or to an international organisation

Your personal data may be transferred to third countries [i.e. countries outside of the European Economic Area] in such cases as e.g. to execute your payment orders or you have given us your consent to do so. Processors in third countries are obligated to comply with the European data protection standards and to provide appropriate safeguards in relation to the transfer of your data in accordance with GDPR Article 46.

Automated decision-making

Gero will only engage in Profiling and automated decision-making where it is necessary to enter into, or to perform, a contract with the Data Subject or where it is authorised by law.

Where Gero utilises Profiling and automated decision-making, this will be disclosed to the relevant Data Subjects. In such cases the Data Subject will be given the opportunity to:

  • Express their point of view.
  • Obtain an explanation for the automated decision.
  • Review the logic used by the automated system.
  • Supplement the automated system with additional data.
  • Have a human carry out a review of the automated decision.
  • Contest the automated decision.
  • Object to the automated decision-making being carried out.
Each Gero entity must also ensure that all Profiling and automated decision-making relating to a Data Subject is based on accurate data.

How we treat your personal information

Gero uses the information that it collects to operate and maintain Product and Gero"s sites and send you results of calculations, questions, informational and marketing communications, respond to your questions and concerns and to help its partners improve their online offerings.

Gero uses the information it has to help verify accounts and activity, and to promote safety and security on and off of Gero's services, such as by investigating suspicious activity or violations of Gero's terms or policies. Gero works hard to protect customer's account using teams of engineers, automated systems, and advanced technology such as encryption.

Gero can only use your personal data to promote our products and services to you if we have your explicit consent to do so or, in certain cases, if we consider that it is in our legitimate interest to do so.

You have the right to object at any time to the processing of your personal data for marketing purposes.

How long we keep your personal information for

Gero will retain personal data it processes on behalf of you for as long as needed to provide its services and research. Gero will retain this personal information as necessary to comply with its legal obligations, resolve disputes and enforce its agreements.

Severability

The provisions of our agreements shall be deemed severable and the invalidity or enforceability of any provisions shall not affect the validity and enforceability of the other provisions. If any provision of our agreements are unenforceable for any reason whatsoever, such provision shall be appropriately limited and given effect to the extent that it may be enforceable.

Your data protection rights

You have the following rights in terms of your personal data we hold about you.

  • The right to access
You have the right to confirmation as to whether or not Gero process your personal data and, where Gero does, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, Gero will supply to you a copy of your personal data.

  • The right to rectification
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

  • The right to erasure
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

  • The right to object to processing
Where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms. You also have the right to object where we are processing your personal data, for direct marketing purposes. This also includes profiling in as much is related to direct marketing.

If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.

  • The right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; Gero no longer needs the personal data for the purposes of Gero processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, Gero may continue to store your personal data. However, Gero will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

  • The right to data portability
You have the right to request to receive a copy of your personal data in a format that Is structured and commonly used and transmit such data to other organisations. You also have the right to have your personal data transmitted directly by Gero to other organisations you will name.

  • The right to complain to a supervisory authority
If you have exercised any or all of your data protection rights and still feel that its concerns about how the Gero uses your personal data have not been adequately addressed by the Gero, you have the right to complain.

  • The right to withdraw consent.
You have right to withdraw the consent that you have given to the Gero with regard to the processing of your personal data at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing based on consent before it was withdrawn or revoked by you.

We endeavour to address all of your requests promptly.

Cookies:

Stored cookies allow Gero website to be more user-friendly and efficient for Clients by allowing the Gero to learn what information is more valued by Clients versus what isn"t.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies, we need your permission. This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

Appointed EU representative.

If you are the resident of the EU and you have any questions about this Privacy Policy or the Service, please contact us through the email [email protected] or get in touch with our EU representative below:

DPOEU LTD

Address: Office 902, Oval, Krinou 3, Ayios Athanasios,

4103, Limassol, Cyprus

Email: [email protected]

Anex 1

The information that shall be collected by Product ("Data") includes :

Source: Apple Health app
We collect your: date of birth; biological sex; steps logs; heart rate; heart rate variability.
How we use it: Your steps data, biological sex and age are used to calculate Healthspan and Biological Age. Your heart rate and heart rate variability are used for research how it can improve Healthspan calculation and can be used in a model for Healthspan calculation in future.

Source: Apple Health app (HealthKit)
We collect your: Data sources list (list of your devices such as iPhone, Apple Watch, fitness trackers etc.) without device names assigned by user (just vendor, model, device id, OS version and other technical info such as hash code of device's name)
How we use it: to detect steps/heart rate source device technical parameters needed for adjustments of calculations of Healthspan and Biological Age

Source: Facebook
We collect your: id, email of user for registration, gender, profile picture, timezone, birthday and/or age range, last name, first name, links to your profile and its picture, language and timezone, tagged places, is your profile verified or not
How we use it: All mentioned parameters are used to preset your GERO profile and user preferences on our Sites and applications. We need biological sex for our calculation while Facebook has gender information. We take it, if your biological sex is not provided from Apple Health App. You can change this information in Product. Additionally, biological sex, age and tagged places could be used in our models to calculate Healthspan and Biological Age.

Source: Your input (manually)
We collect your: date of birth; biological sex; email
How we use it: Your biological sex and age are used to calculate Healthspan and Biological Age. Email is used for registration process.

Source: Your input (manually)
We collect your: Answer to the question "Had you ever been diagnosed with the disease or condition from the list: Congestive Heart Failure (CHF), Myocardial Infarction (MI), Chronic Obstructive Pulmonary Disease (COPD), stroke, dementia, diabetes, cancer?"
How we use it: Answer is used for research how it can improve calculation of Healthspan and Biological Age and can be used in a model for Healthspan Biological Age and other alike calculations in future.

Source: Your input (manually)
We collect your: Answer to the question "Do you smoke?"
How we use it: Answer is used for research how it can improve calculation of Healthspan and Biological Age and can be used in a model for Healthspan Biological Age and other alike calculations in future.

Source: Your input (manually)
We collect your: Results of periodic questionnaires (surveys)
How we use it: We can periodically ask you to answer some questions about yourself, your lifestyle, medical history, and your current health and symptoms for a purpose of further prediction model improvement, research on relations of lifestyle with health or in order to try to track changes. Your answers can be used in a model for Healthspan and Biological Age calculation in future. You may skip any questions that you do not want to answer.

Gero may collect your Data every time you enter the Product information from Product and within 30 days of obtaining the Data it will inform you that it has done so and the purpose for why it keeps your personal data in its system.

Personal Data - your personal information including name, last name, personal account details such as full name, nickname, member since, country, avatar, timezone, Facebook account information when using Product as in more details specified in Data definition.

De-identified health Data ("Health Data") as follows: steps data, survey responses, date of birth, biological sex, heart rate, heart rate variability, calculated Healthspan, calculated Biological Age

We respect your privacy. We will never sell, rent, or lease your contact information. We will not disclose your Personal information unless the law requires us to do so.