LEGAL NOTICE OF PUBLICATION

Owner:

ELLCIE HEALTHY Marina Buro 1752 RN7 06270 Villeneuve-Loubet France

SIRET : 82012934400025

Code APE : 6201Z

SAS with a capital of €127,500

RCS Antibes – APE 6201Z

Publication manager: Philippe Peyrard

Hosting

GANDI SAS, a simplified joint stock company with a capital of 800.000€ with its head office at 63-65 boulevard Masséna Paris (75013) FRANCE

Data Protection Officer

Mr. Muela Thierry

vosdroits@ellcie-healthy.com

Pictures and visuals of the site

Non-contractual pictures

ELLCIE HEALTHY PRIVACY POLICY

The protection of your personal data is at the heart of our attention at Ellcie Healthy. Our team is committed to protecting the confidentiality of your information, security and accuracy of the information provided in accordance with the legislation.

This Privacy Policy addresses the guiding principles for protecting the personal information of the individuals who are our customers, providers, suppliers and prospects.

By providing personal information to Ellcie Healthy, you agree that we may collect, use or disclose such personal information in accordance with this Privacy Policy.

You may refuse or withdraw your consent to certain of the identified purposes at any time by contacting us directly. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you for some of the services necessary for the operation of the Ellcie Healthy Device.

Created in 2016, Ellcie-Healthy is a start-up company founded under the impetus of Philippe PEYRARD that develops intelligent and connected eyewear. Today, more than twenty people work every day to develop these innovative frames.

The PRUDENSEE system includes the prevention of drowsiness while driving, as well as accompanying the user to ensure his safety once a drowsiness alert is detected.

European legislation on the protection of personal data defines personal information as information about an “identifiable individual” or information that identifies an individual. The types of personal information we may collect are different depending on the need.

On the Ellcie Healthy Web Site via the CONTACT form :

– Your first and last name

– Email address

– Phone

 

On the Application Driver by Ellcie Healthy :

– Your first and last name

– Email address

– Phone

– Gender

– Country / Address / Postal Code

In addition, in order to ensure the functioning of our Ellcie Healthy device, the prevention of drowsiness thanks to the smart connected glasses and the support of the users in case of a sleep alert, we need to collect physical, physiological and environmental data (ex: accelerometric measurement of head movement such as lateral and vertical movements, frequency and duration of blinking, geolocalization through the Smartphone, ambient temperature).

We collect your personal information in order to :

(1) Provide the connected eyewear device to help prevent drowsiness while driving (Sleepiness prevention + assistance)

If you have subscribed to the Ellcie Healthy device, we use your personal information (above) to be able to provide you with our offer in a personalized manner, or to respond to any other requests regarding problems with the device’s understanding, operation or bugs.

(2) To process all information requests

Whether you are a client or prospect, professional or consumer, we use your personal information to ensure a personalized answer in adequacy with your needs.

(3) Providing you information

It is also possible that we may provide you various information concerning possible changes to our system.

(4) Other purposes

Also, as needed, we may use your personal information for the following purposes:

– To detect errors, fraud, theft and other illegal activities, and to verify compliance with Ellcie Healthy’s policies and contractual obligations.

– Understand your needs and preferences, including how to communicate with you

– Obtain audited statements regarding the number of customers by products and services ;

– Any other purpose that we may indicate to you

We may disclose your personal information to the following third parties in the circumstances set out below:

(1) Communications to our service provider

We may communicate your personal information to the company Europ Assistance France, a subsidiary of Generali, which provides assistance services for the Ellcie Healthy device.

We will only provide this company with the information it needs to provide the driver assistance service and it is contractually prohibited from using this information for any other purpose.

(2) Communication to our business units

We may share your personal information with any of Ellcie Healthy’s business units in order to best satisfy your requests and ensure the best possible quality of service.

(3) Law Enforcement and Statutory Disclosure

Ellcie Healthy may share your personal information with a government agency that has asserted its lawful authority to obtain the information or to comply with a subpoena, warrant or order made by a court, person or body with jurisdiction requiring the submission of the information, or to comply with a court order for the submission of information records.

Ellcie Healthy wants you to be able to maintain control over how we use your personal information.

You always have the choice to ask us not to use your name, address, e-mail address, etc.

However, we may not be able to provide you access to our device if you withdraw your consent to our use of your personal information.

Your personal information are stored in secure locations on servers controlled by FireBase.inc. that comply with GDRP* standards. To consult your personal information, please communicate your request to our data protection officer via the contact information provided in the last part of this document.

*Certifications and audits: ISO 27001 (Information Security Management) / ISO 27017 (Security in the Cloud) / ISO 27018 (Protection of Personal Data in the Cloud) / SOC 1 / SOC 2 / SOC 3 / Privacy Shield

Upon written request, subject to some exceptions, Ellcie Healthy will inform you of the existence, use and disclosure of your personal data and allow you to access it. You should send your request for access to our data protection officer using the contact information provided in the last part of this document.

We make every effort to prevent the loss, misuse and alteration of personal information under our control. Our security policies are monitored and enhanced as necessary by our departments under the responsibility of the Data Protection Officer.

Only authorized employees and suppliers have access to your personal information. When personal information is sent to a third party for processing (Europ Assistance for the Help Desk), we ensure, on a contractual basis with the third party, that your personal information remains secure. We retain your personal information for the period of time we provide you with our device. We will permanently delete it upon direct request.

We operate secure data networks protected by firewall systems (software that secures data according to defined standards) and password protection.

When an individual accesses Ellcie Healthy websites, we use a browser feature called a “cookie” to collect information such as the type of Internet browser and operating system the visitor uses, the domain name of the websites from which the visitor came, the date and length of the visit, the number of visits, the average time spent on our websites, the pages viewed and the number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor’s browser (but does not necessarily identify the visitor). Unless the visitor specifically informs us (ex: by providing us with information through the CONTACT form), we will not know the identities of visitors. We may use this information from our website and share it with other organizations with whom we have a business relationship to measure the use of our websites and to improve the content of our websites.

Browser Information: You can reset your browser to notify you as soon as you receive a cookie, thereby potentially rejecting it. However, when a visitor refuses cookies, he may not be able to use some of the features offered on our Website.

Ellcie Healthy reserves the right to modify or add to this Privacy Policy at any time. If we make changes to this Privacy Policy, we will post those changes on our websites and the updated policy will be available upon written request to Ellcie Healthy’s Privacy Officer.

Ellcie Healthy has designated a Privacy Officer who is responsible for monitoring and implementing the measures necessary to ensure that this Privacy Policy complies with privacy laws.

Here is the contact information to enforce your rights:

Data Protection Officer

MUELA Thierry

Ellcie Healthy

1752 RN7

Marina Buro

06270 Villeneuve-Loubet

vosdroits@ellcie-healthy.com : To enforce your rights of portability, retraction, modification, deletion