Privacy Policy
Valid from December 26, 2018



1   The scope of the Privacy Policy

The following describes how Empowered Applications AB (“Healo“), 559093-0722, with address Stora gråbrödersgatan 13, 222 22 Lund, (“Healo“, the “Service” or “Services”, “us“ or “we“), processes your Personal Data as a user of the apps named Healo, and when you visit our website www.healo.app (the “Website“).

Your privacy is important to us and we take it seriously. We protect your Personal Data and assure you that our handling and processing of your data is done in a correct and legal manner.

In this privacy policy we explain what types of Personal Data and data we may manage and for what purpose we manage them. We also describe our processing of Personal Data and what rights you have in relation to the processing. Please read this policy carefully and become acquainted with its contents.

Please note that this Personal Data policy only concerns the processing of Personal Data for which Healo is the data controller. This means data for which we are responsible for the handling and processing of. It also means that it is to us you shall turn with your questions or comments, or if you want to enforce any of the rights you have in relation to our managing of your Personal Data.

If you have been prescribed our Services by a healthcare provider, who offers you care through Healo, your Personal Data is also managed by the healthcare provider. For the healthcare provider's processing of Personal Data the healthcare provider is responsible for Personal Data. For more information about your healthcare provider's processing of your Personal Data, we refer you to your healthcare provider.

If you have been referred by your insurance company to a doctor or physiotherapist who offers you care through Healo, your Personal Data related to the insurance case is also managed by your insurance company. For more information about your insurance company's processing of your Personal Data, we refer you to your insurance company.


2   Personal Data processed

Personal Data refers to data that can be attributed to you as a user of Healo. We may process the following Personal Data that can be attributed to you:

  • contact information (name and email address),

  • your health information,

  • your health information as related to the therapies and progress in Healo,

  • the token for authenticating your account at HEALO.

Please note that your providing us your Personal Data is a prerequisite for entering into agreements with us about Healo Service.


3   Purposes of treatment and legal basis

We process your contact information to handle our communication with you as a user of Healo.

We process your health information to, through analysis of results and behavior based on our treatments, conduct research on how the treatments can be improved and made more efficient.

We process your token for authentication in order to ensure that only authorized users can log in to Healo.

As Healo is a healthcare service, all Personal Data is related to your health. This means that your Personal Data is considered sensitive and is therefore processed only with your prior consent.

You have the right to withdraw your consent for our processing of your Personal Data at any time. You can also withdraw your consent for a certain part of our processing. Note, however, that your full consent is a prerequisite for us to be able to offer you the Healo service.


4   Access to your Personal Data

Your Personal Data will only be processed by Healo and our Personal Data Processors and Controllers. Subcontractors Personal Data Controllers are always bound by written Personal Data Processing Agreements that impose on them the same obligations in the processing of Personal Data as the obligations that apply under this policy.

Healo will never forward, sell, or exchange your Personal Data to third parties.

Healo only transfers Personal Data to countries outside the EU / EEA if the country concerned has a sufficient level of protection according to the EU or the EU Commission, or if this is specifically stated in connection with you providing your Personal Data to us.

Healo will not use your email address for unsolicited mailing. Email sent by Healo will be entirely in accordance with the terms of this policy.

In case of suspected violation of law or our general terms and conditions, we may disclose your Personal Data to law enforcement authorities, as well as to our legal advisors.

Notwithstanding the above, Healo may transfer your Personal Data:

  • To the healthcare provider who offers you care through Healo or the insurance company that referred you to us,

  • to your Caregiver if you request it or agree to the Caregiver's inquiry via Healo,

  • to Swedish national quality registers,

  • to regulatory authorities or legal advisors in connection with alleged violation of law or suspected breach of our General Terms and Conditions, or

  • when Healo is obliged to disclose or share your Personal Data in order to fulfill obligations under law.


5   Personal Data storage

Healo stores your Personal Data as long as it is necessary to fulfill the purpose of the treatment, and after that for a period of 12 months.

If you cease to be a user of Healo, we will graft or delete your Personal Data in full within twelve months from the time you ceased to be a user. However, we will continue to store and process your health data but in an anonymous state.

If you withdraw your consent to processing of your data that requires consent, or your Personal Data is no longer necessary to fulfill the purpose of the treatment, or if the treatment is no longer permitted for other reasons, your data is anonymized or deleted.


6   Cookies

Our website uses cookies. Cookies are small text files that are stored on our visitors' computers and make it possible for us to follow what a visitor does on the Website.

We use so-called tracking cookies, which aim to share information between websites to gather information and provide you with customized information.

We use cookies only if you have given your consent. If you do not accept cookies, you can turn off cookies in your browser's security settings. You can also set the browser so that you are asked every time a site tries to place a cookie on your computer. Stored cookies can also be deleted through the browser. See the browser's help pages for more information. Furthermore, you can delete cookies at any time manually.

Please note that if you choose not to accept cookies, functionality may be restricted on certain websites.


7   Your rights

You have the right to receive confirmation of if we process your Personal Data and receive information about our handling of them.

You have the right to obtain the Personal Data you provided to us in an electronic format that is widely used. You have the right to transfer such data to another Data Controller (data portability).

You have the right to receive amendment of incorrect Personal Data without delay. You also have the right to supplement incomplete Personal Data, taking into account the purpose of the treatment.

You have the right to withdraw your consent to our processing of your Personal Data at any time. However, this affects our possibility to offer you our services.

You have the right to object to our processing of your Personal Data for direct marketing.

You have the right to have your Personal Data deleted by us, for example, if the Personal Data is no longer necessary to fulfill the purposes for which they were collected, or if the Personal Data has been managed in an inappropriate manner.

You have the right to demand that we limit the processing of your Personal Data. For example, if you dispute the correctness of the Personal Data, you may require that we limit their processing during the time it takes for us to check whether your data is accurate.

If you have any comments on our processing of your Personal Data, you are welcome to contact us at the contact information at the bottom of this document.


8   Additions and changes

We will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the Services.



Data Protection

For more information or questions about this Privacy Policy, please contact HEALO's Data Protection Officer:

core@healo.app

Empowered Applications
SE559093072201

Stora gråbrödersgatan 13
222 22 Lund
Sweden


Healo is a registered trademark of
Empowered Applications ©2017–19