Privacy Policy tVNS Patient App

A. Information on the processing of your data in accordance with Art. 12 ff. GDPR

I. Scope:
This privacy policy applies to the tVNS® Patient app, which is used to accompany the treatment of tVNS nextGen neurostimulators from tVNS Technologies GmbH.

II. Responsibility:
The person responsible for processing personal data is:

tVNS Technologies GmbH,
represented by the managing directors Prof. Dr. Armin Bolz and Tobias Jeglorz
Henkestr. 91
91052 Erlangen
Email: info@tech.t-vns.com
Internet: www.t-vns.com

Registered at:
District court Fürth – HRB 17082
VAT ID No. DE 246259527

III. Data protection officer:
You can contact our data protection officer at datenschutz@tech.t-vns.com

IV. Our handling of your data when using the t-VNS® app
1) Information that is processed automatically
When using the t-VNS® app, we automatically collect certain data that is required for using the app. These include, among others, the IP address, device data, date and time of the retrieval, notifications on the retrieval status, operating system and browser software. The purpose of processing this data is to provide the service and the associated functions and to prevent and eliminate misuse and malfunctions.

The legal basis for this data processing is our legitimate interest in accordance with. Art. 6 Para-graph 1 lit. f DS-GVO ensure the functionality and error-free operation of the app, which out-weighs your rights and interests in the protection of your personal data.
2) Processing of user data
We also process the information you provide about gender, age, height, weight and illnesses as well as your diary entries. In addition, the app collects and saves all the technical data of your stimulation device (stimulation parameters, duration of use, currents, error states, etc.) as well as measurement results from internal sensors (movement, current, EKG, etc.). All data is regular-ly anonymized. Upon your request, you can access this data via a patient access code. You can also optionally share your data with your attending physician so that they can get an impression of your therapy progress.

We evaluate your information and measurement results as well as device data to improve the measurement devices, for quality assurance and for research purposes. To this end, we occa-sionally – with the provision of anonymized data – also use the support of universities and exter-nal experts who deal with transcutaneous vagus nerve stimulation and its improvement as part of their research. It is not possible for universities and external experts to assign the data to you personally.

The legal basis for the processing of your user data (including information about your health) for the purposes mentioned above is your consent (Art. 6 Paragraph 1 lit. a, 9 Paragraph 2 lit. a GDPR).
3) Duration of storage
We process and store your data only for the period necessary to achieve the purpose of the processing or if we are obliged to continue processing by legal regulations.
V. Your rights:
As a user of our app offering, you have various rights under the GDPR, which arise in particular from Articles 15 to 18, 20 and 21 GDPR:

1) Right to information:
You can request information according to Art. 15 GDPR about your personal data processed by us. In your request for information, we ask you to specify your request in order to make it easier for us to compile the necessary data.
2) Right to rectification:
If the information concerning you is (no longer) correct, you can request a rectification accord-ing to Art. 16 GDPR. If your data is incomplete, you can request it to be completed.
3) Right to erasure:
You can request the deletion of your personal data under the conditions of Art. 17 GDPR.
4) Right to restriction of processing:
If the requirements of Art. 18 GDPR are met, you have the right to request that the processing of your data be restricted.
5) Right to data portability
If the requirements of Art. 20 GDPR are met, you have the right to request the personal data concerning you that you have provided to us in a structured, common and machine-readable format and to transmit this data to another person responsible without hindrance from us; if applicable, you also have the right to request that we transfer the personal data directly to an-other person responsible, insofar as this is technically feasible.
6) Right to object:
According to Art. 21 GDPR, you have the right to object to data processing that is based on a legitimate interest, unless we can prove that compelling legitimate reasons outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defense of legal claims; you can object to processing for the purpose of direct advertising at any time.
7) Right to complain:
If you are of the opinion that we have not complied with data protection regulations when processing your data, you can submit a complaint to the

Bavarian State Office for Data Protection Supervision (BayLDA)
Promenade 18
91522 Ansbach
Phone: +49 (0) 981 180093-0
E-Mail: poststelle@lda.bayern.de

B. Consent
In knowledge of the statements under Section A, I consent to my personal data being processed, in particular the information about my health, for the purposes described above and, if necessary, transferred in anonymized form to universities and external experts who deal with transcutaneous vagus nerve stimulation and with their improvement. I am aware that I can re-voke this consent at any time without giving a reason with effect for the future. For this pur-pose, an email to info@t-vns.com is sufficient. The legality of the processing carried out on the basis of the consent up to the point of revocation is not affected by the revocation.