Privacy Novio Hand

In accordance with the requirements of Articles 13, 14 and 21 of the General Data Protection Regulation (GDPR), LIME hereby informs you about the processing of personal data collected about you while using Novio Hand as well as your data protection rights in this respect. To ensure that you are fully informed about the processing of your personal data when using Novio Hand, please take note of the information below.

1. responsible person/ contact/ management

LIME medical GmbH

Address
Hauptstraße 17-19
Building 6306
D-55120 Mainz

Contact details
E-mail: [email protected]
Phone: +49 6131 2501053

Management
PascalLindemann

2. data protection officer

For all questions regarding the protection of your personal data, you can contact LIME's data protection officer, who is also available for requests for information as well as suggestions and complaints:

Data protection officer: Daniel Sieg

E-mail: [email protected]
Phone: +49 6131 2501053

3. terms

All data protection terms have the same meaning as defined in Regulation (EU) 2016/679 of the European Parliament and of the Council ("GDPR").

4. purposes of processing and legal bases

We use your personal data exclusively for the following purposes:

1. 1. Intended use of Novio Hand (legal basis: consent, Art. 6 (1) lit. a) and Art. 9 (2) lit. a) of the GDPR)(further information in 6.).
   2. Additional processing purposes required by law, such as the fulfillment of obligations under medical product law, etc., but also, for example, the defense of legal claims (legal bases: legal obligation, Art. 6 (1) lit. c) of the GDPR in conjunction with the respective special legal provision, Art. 6 (1) lit. d) and e) of the GDPR and Art. 9 (2) lit. c), lit. f) to lit. j) of the GDPR, as applicable)(further information in 7.).
   3. Permanent guarantee of technical functionality, user-friendliness and further development of the application (legal basis: consent, Art. 6 (1) lit. a) and Art. 9 (2) lit. a) of the DSGVO)(further information in 8.).

5. categories of data processed within the scope of the intended use

• Personal data
  • E-mail
  • Nickname
  • Year of birth
• Training data
  • Start and end time, as well as duration of the training
  • Type and number of exercises planned and carried out
  • Progress within a game
  • Optional: Hand position data and its evaluation in the context of the respective exercise.
  • Optional: Time of the measurement

• Health data
  • present indication
  • which hand and which finger(s) are trained
  • daily pain check
  • medical questionnaire

6. description of the required data processing within the scope of the intended use

1. Processing of inventory data, payment data and data from interfaces of the mobile device
   • LIME processes your inventory data (name, contact data, date of birth, ...), other data (zip code of your treating physician) and data records from the interface of your mobile device for the following purposes:
     • Creation of an account in the app;
     • Provision of the app and the respective functions and content;
     • Respond to contact requests and communicate with users;
     • Answering your support requests;
     • Safety measures.
2. Processing of special categories of personal data (health data)
   • We process your health information for the following purposes:
     • Adaptation of the therapy to the user;
     • Reminding the patient to perform the therapy if the user wants to use this service within the application;
     • Storage and display of therapy progress.

7. description of data processing for billing and for compliance with legal regulations and obligations.

1. In connection with the fulfillment of the statutory obligations to which LIME is subject, LIME processes your data provided in the course of the intended use of the app, including user, application, technical and billing data, such as, in particular, for the fulfillment of obligations under medical device law, such as for the performance of conformity assessment procedures and post-market surveillance of the app.
2. To comply with our legal obligations, we may also share your information with the relevant regulatory authorities, although we generally share your information only in pseudonymous form, so that no information that directly identifies you is shared.

8. description of data processing for further development (optional).

If you give us permission to process your personal data for further development, we will process this data as follows:

1. To improve Novio Hand;

2. to analyze user behavior in the app;

3. for the development and further development of safety measures.

As part of data processing for further development and to ensure technical functionality and user-friendliness, we may evaluate your user behavior in connection with app use. If possible, the evaluation is always based on aggregated data, so that no information that directly identifies you is processed.

8. revocation

Any of your consents can be revoked at any time via the menu in the Novio Hand app. Please note that in case your consent for the intended use of the app is revoked, the features of the app will no longer be available to you.

9. recipients of personal data

1. We may transfer your personal data collected through our App to the following processors in accordance with Article 28 of the GDPR who assist us in operating the App and providing the Service:

Name	Seat	Function	Categories of personal data
OVH SAS	2 rue Kellermann, 59100 Roubaix, France	Cloud Platform as a Service - provision of server and database resources for the operation of the Novio Hand App.	Inventory data, contact data, health data, billing data, product improvement data.
Flowmailer BV	Van Nelleweg 1, 3044BC Rotterdam, Netherlands	Email automation	Automation of e-mails such as notification of password changes

(2) Contracts pursuant to Article 28 of the GDPR or the standard contractual clauses pursuant to Chapter V of the GDPR have been concluded between LIME and all processors, which in particular stipulate that the data processing will be carried out exclusively in accordance with LIME's instructions and that all employees who are in contact with LIME's personal data have been bound by data protection secrecy.
3. in addition, LIME may disclose your personal data to the following categories of recipients for the processing purposes described above: Accountants, Legal Advisors, Tax Advisors, Supervisory Authorities, Regulatory Authorities, etc.
4. Please note that as part of offering the Application, LIME also works with other partners who are not Processors and who collect any Personal Data from Customers directly, without any transfer via LIME. Such third party providers are not "recipients" of LIME in the sense of Art. 13 (1) lit. e) of the GDPR. They collect the customer's data independently. LIME points out that your contractual relationship with third party providers is independent from your contractual relationship with LIME.

10. international data transfer

The processing of personal data by LIME itself as well as in case of processing of personal data on behalf will only take place in the domestic market, in a member state of the EU or the EEA, Switzerland or, if an adequacy decision pursuant to Art. 45 of the GDPR is available, in a third country.

11. storage and deletion concept

1. Your data will only be stored by us for as long as is necessary to achieve the purposes for which the data was collected or until you revoke your consent (see point 9). If there are additional legal retention periods (e.g. according to the German Commercial Code, the German Fiscal Code or for regulatory reasons), your data will be stored for the duration of this legally prescribed retention period.
2. You can stop using Novio Hand in the app at any time and have all personal data deleted. You can do this via the "Settings" menu.
3. We store health-related data physically and logically separate from data required for service billing. During a deletion process, your data that is processed by order processors will also be deleted.

12. your rights

1. • According to the GDPR, you are entitled to the following data protection rights in accordance with the legal requirements:
   • • • Right to information, correction, deletion and restriction: You have the right to request information about your data stored by us at any time (Art. 15 DSGVO). When we process or use your data, we strive to take reasonable steps to ensure that your data is accurate and up-to-date for the purposes for which it was collected. In the event that your data is inaccurate or incomplete, you may request that it be corrected (Art. 16 GDPR). Furthermore, you may have the right to request the deletion (Art. 17 DSGVO) or restriction of processing (Art. 18 DSGVO) of your data if, for example, your data is no longer necessary for the purposes for which it was collected or otherwise processed and legal retention obligations do not require its further storage.

1. 1. • • Right to data portability: You may have the right to receive the data concerning you that you have provided to us in a structured, common and machine-readable format or to transfer this data to another controller (Art. 20 DSGVO).

1. 1. • • Right to revoke your consent: If you have consented to the collection, processing and use of your data, you can revoke your consent at any time with effect for the future (see 8.), but without affecting the lawfulness of the processing carried out on the basis of the consent until revocation (Art. 7 para. 3 DSGVO).

1. 1. • • Right to object: You have the right to object at any time to the processing of your data based on Art. 6 (1) e) or f) DSGVO for reasons arising from your particular situation. LIME will not process your data after an objection, unless LIME can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise or defense of legal claims (Art. 21 (1) DSGVO, so-called "limited right of objection"). In this case, you must provide reasons for the objection that arise from your particular situation. Furthermore, you have the right to object to the processing of your data for the purposes of direct marketing at any time, even without stating reasons (Art. 21 (2) DSGVO).

1. 1. • • Automated decision-making (including profiling): You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you (Art. 22(1) DSGVO). Please note that LIME does not use such automated decision-making or profiling in the sense of Art. 22 DSGVO in connection with Novio Hand.
      • To exercise your right of access and your right of data portability, go to the "Settings" menu item in the Novio Hand app. There you can export your data in a human readable format as well as in a machine readable format.
      • To correct your data, you can find some options directly in the settings of the app. If you want to correct any other data, you can always contact our customer support via email ([email protected]), who will make the correction for you.
      • To restrict the processing or to object to the processing of personal data, you can also find options in the settings of the app under the menu item "Settings". If you would like to restrict further processing, please contact our customer support via email ([email protected]).
      • You also have the right to complain to the competent supervisory authority at any time if you believe that the processing of your data is not lawful.

Contact
The State Commissioner for Data Protection and Freedom of Information of Rhineland-Palatinate
Prof. Dr. Dieter Kugelmann
Hintere Bleiche 34
55116 Mainz
Phone: +49 6131 8920-0
E-mail: [email protected]

13. changes to the privacy policy

LIME reserves the right to update the Novio Hand privacy policy, in particular to incorporate feedback from users and to respond to changes in legislation or standing case law.

14. wording of your declaration of consent

• • I consent to the use of my personal data (incl. health data) for the purpose of using the Novio Hand App as well as the required verification to my health insurance company and billing-related service providers.

• • I consent to the use of my personal data (including health data) for the purpose of improving and further developing the Novio Hand App, including the evaluation of my user behavior and anonymization to create aggregated data and statistics.