BIOW APP PRIVACY POLICY

1. Data controller

The data controller for the personal data collected and processed through the BIOW App is BIOW EXPOSOMICS, S.L., with Tax ID No. B33998980 and registered address at Calle Michel Faraday, 75 – Units 9-10, 33211 Gijón, Asturias, Spain. You may contact BIOW for any matter relating to privacy or data protection by email at lopd@biow.net or by postal communication addressed to the address indicated above. For the purposes of this policy, “BIOW” refers to BIOW EXPOSOMICS, S.L. as the controller of the BIOW App, without prejudice to the fact that certain functionalities may link to external services or to other companies of the BIOW Group, as explained in this policy.

2. Scope of application

This Privacy Policy applies to the processing of personal data carried out through the BIOW App, including the following functionalities:
  • Registration, authentication and user account management;
  • Connection of the BIOW device via WiFi and functional control of the equipment;
  • Scheduling, switching on, switching off, technical support and management of incidents linked to the device;
  • The “Measure Yourself” section, including the internal Biowoman and phenotype questionnaires, their results, historical results, progress and comparisons;
  • Internal statistical use, R&D activities and internal studies by the scientific department related to well-being and the use of BIOW;
  • Access via external link to the SofIA AI agent;
  • Security, maintenance, technical diagnosis, technical telemetry and improvement of the App and the BIOW ecosystem.
Where a specific functionality is subject to particular terms or specific information notices, those texts shall supplement this Policy where applicable.

3. Main functionalities of the App

The BIOW App allows users to access three main functional blocks:

3.1. Connect BIOW device.

This allows the BIOW device to be connected via WiFi and operated, including functions such as switching on, switching off, scheduling, configuration, technical support and other technical functionalities available in each version of the App.

3.2. Measure Yourself.

This allows access to questionnaires related to well-being. This section includes:
  • Biowoman survey: a questionnaire integrated into the App itself, focused on aspects of women’s quality of life and well-being. The responses and results will be processed within the BIOW App, associated with the user’s account where necessary to show the result, keep the history or display progress, without prejudice to the specific information provided before starting it.
  • Phenotype questionnaire: an internal App questionnaire whose results are stored in the user’s account so that the user can view progress over time.

3.3. SofIA.

This allows access, via an external link to https://sofiabiow.com/, to an artificial intelligence agent created by BIOW to answer questions about BIOW. This service is provided in an environment external to the App, as explained in section 13.

4. What personal data we process

BIOW will process the following categories of data depending on the actual use made of the App by the user.

4.1. Identification and account data

  • First name and surname, when requested;
  • Email address;
  • Telephone number, when requested;
  • User identifier;
  • Access credentials or authentication mechanisms;
  • Registration date, account status and basic records associated with account management.

4.2. Data relating to the connected BIOW device

  • Serial number or equipment identifier;
  • Device model;
  • Information linking the account and device;
  • Equipment status and technical parameters necessary for its operation;
  • Data necessary for scheduling, switching on, switching off, configuration and functional control of the device.

4.3. Technical data on App use and connectivity

  • IP address;
  • Access logs;
  • Date and time of connection;
  • App version and operating system;
  • Technical identifiers of the device where necessary;
  • Error events, failures, logs and technical traces;
  • Network information necessary for connectivity with the device, including WiFi connectivity where essential for the provision of the service.

4.4. Mobile device location data

The App may require permission to access the location of the mobile device where the device’s operating system requires such permission to allow the detection, connection or initial configuration of a BIOW device. This access will be limited to the technical purpose of connection or configuration and will not be used for continuous tracking, monitoring of movements, advertising, profiling or analysis of personal habits.

4.5. Biowoman and phenotype questionnaire data and well-being results

Where the user voluntarily decides to complete the Biowoman Survey or the phenotype questionnaire, BIOW may process the responses entered, contextual data and the results generated by the App. Among others, data relating to the following may be processed:
  • Responses to the Biowoman questionnaire related to women’s quality of life and well-being;
  • Age;
  • Sex;
  • BPR, where completed by the user;
  • Sleep and rest, including consecutive hours of sleep, night awakenings, snoring, nasal breathing difficulty during sleep and perception of restorative rest;
  • Pain and physical fatigue, including daily fatigue, lack of energy, joint or muscle pain, tiredness upon waking, general discomfort and headaches;
  • Well-being and balance, including swollen or tired feet, frequency of blowing one’s nose, perception of skin aging, weak hair, dark circles under the eyes, fluid retention, swollen or congested face upon waking and weak nails;
  • Overall questionnaire result;
  • Partial results or well-being dimensions, such as Energy, Sleep and Well-being;
  • Date of completion of the questionnaire;
  • Results history, progress over time and comparisons between results.
BIOW considers this information to be well-being data. However, some responses to the Biowoman and phenotype questionnaires may relate to physical, symptom-related, quality-of-life or perceived bodily-condition aspects of the user. For this reason, BIOW will apply a reinforced level of information, minimization, security and access control.

4.6. Data provided in communications, incidents and support

  • Enquiries, requests or incidents submitted by the user;
  • Technical information provided to resolve incidents;
  • Data necessary to manage technical support, faults, returns, repairs or assistance linked to the device;
  • Communications maintained with BIOW through the enabled channels.

4.7. Derived data for statistical analyses, R&D and internal studies

BIOW may use results from the Biowoman and phenotype questionnaires and other App or device usage data to carry out internal statistical analyses, R&D activities and internal studies by the scientific department related to well-being and the use of BIOW. Preferably, these analyses will be carried out using anonymized, aggregated or dissociated data, so that they do not allow specific individuals to be identified. Where it is necessary to process personal or pseudonymized data for a statistical, scientific or R&D purpose, BIOW will apply a valid legal basis, minimization measures, access limitations, pseudonymization where appropriate and, where applicable, the user’s specific consent as indicated in this policy.

5. How we obtain the data

The data may be obtained from the following sources:
  • Directly from the user, when they create an account, configure the App, connect a device, complete the Biowoman or phenotype questionnaires or submit communications and incidents;
  • From the connected BIOW device, where technically necessary for the provision of the service, diagnosis, security, support or maintenance;
  • From the user’s mobile device, with prior authorization of the relevant operating system permissions, where technically necessary for the connection, connectivity or operation of the App;
  • Automatically through use of the App, in relation to events, access logs, errors, technical communications, security or technical telemetry;
  • From providers or third parties legitimately involved in the technical provision of the service or incident management, where there is sufficient legal coverage and the corresponding applicable contract or safeguard.

6. Purposes of processing and legal bases

BIOW will process personal data for the purposes and on the legal bases indicated below.
Purpose Description Legal basis
Registration, authentication and account management To allow registration, access, authentication, administration and maintenance of the user account in the App. Art. 6.1(b) GDPR: performance of the relationship requested by the user.
Connection, configuration and control of the BIOW device To allow connection between the App and the BIOW device, as well as its configuration, scheduling, switching on, switching off, control and operation. Art. 6.1(b) GDPR: provision of the service requested by the user.
WiFi connectivity and technical permissions To enable detection, local connection, network configuration and technical communication with the BIOW device. Art. 6.1(b) GDPR and, where applicable, Art. 6.1(f) GDPR: legitimate interest in ensuring connectivity, security and technical support.
Location for initial connection To allow the detection or initial configuration of the device when the operating system requires location permission. Art. 6.1(b) GDPR. Where applicable, Art. 6.1(f) GDPR for minimum technical traceability and support of the connection process.
Technical support, incidents and technical assistance To handle requests, incidents, faults, technical support, repairs, returns or operational queries. Art. 6.1(b) GDPR and, where applicable, Art. 6.1(f) GDPR.
Technical telemetry, diagnosis and maintenance To process technical records, errors, operating parameters and events strictly necessary for diagnosis, maintenance, service continuity, security and technical improvement. Art. 6.1(b) GDPR and Art. 6.1(f) GDPR: legitimate interest in maintaining a secure, stable and functional service.
Biowoman and phenotype questionnaires, results and history To allow the user to complete the questionnaires in the “Measure Yourself” section, obtain informational well-being or quality-of-life results, store historical results and display progress or comparisons over time. Art. 6.1(a) GDPR: user consent. Where the data could be considered health-related data or especially sensitive information, Art. 9.2(a) GDPR: explicit consent.
Internal statistical, scientific and R&D use To carry out general statistical studies, not individualized by user, internal analyses of well-being, quality of life and R&D related to the use of BIOW. Preferably, anonymized or aggregated data will be used. Anonymized data: GDPR would not apply. If personal or pseudonymized data were processed: Art. 6.1(a) GDPR and, where applicable, Art. 9.2(a) GDPR, unless another specific legal basis applies.
App security, prevention of misuse and system protection To detect improper access, prevent unauthorized use, ensure the security of the App, the device and the technological infrastructure. Art. 6.1(f) GDPR: legitimate interest in security; Art. 6.1(c) GDPR where there is a legal obligation.
Legal compliance and legal defense To comply with legal obligations, authority requests, contractual, regulatory, tax, consumer or legal defense responsibilities. Art. 6.1(c) GDPR and Art. 6.1(f) GDPR.
BIOW will not use data from the Biowoman and phenotype questionnaires for behavioral advertising, commercial segmentation, commercial profiling or automated decisions with legal or similarly significant effects on the user.

7. Specific information on the questionnaires in the “Measure Yourself” section: Biowoman and Phenotype

The “Measure Yourself” section includes voluntary questionnaires related to well-being and quality of life, including the Biowoman Survey and the phenotype questionnaire. The Biowoman Survey is integrated into the BIOW App itself and, therefore, its responses and results will be processed within the App environment, under the responsibility of BIOW EXPOSOMICS, S.L. These questionnaires are for informational purposes and for personal well-being monitoring. They do not constitute a medical diagnosis, do not assess diseases, do not prescribe treatments and do not replace consultation with healthcare professionals. If the user has symptoms, a diagnosed illness, persistent discomfort or doubts about their health status, they should consult a healthcare professional. The questionnaire results will be stored in the App associated with the user’s account in order to allow, where the functionality is available:
  • Viewing the overall result obtained;
  • Consulting partial results or specific dimensions of each questionnaire;
  • Viewing historical results by date;
  • Comparing results from different dates;
  • Graphically displaying the evolution of well-being or indicators associated with the questionnaire over time.
Completion of these questionnaires is voluntary. The user may use other App functionalities even if they decide not to complete them, except those that depend directly on the questionnaire or on the history of results. Before starting each questionnaire, BIOW will provide specific information and request the acceptance or consent required to process the responses, results and history. This acceptance will be separate from the general acceptance of the privacy policy given during registration.

8. Use of results for internal statistical studies, R&D and the scientific department

BIOW may internally analyze the results of the Biowoman and phenotype questionnaires and other data related to use of the App or BIOW device in order to carry out general statistical studies, R&D activities and analyses by the scientific department related to well-being, quality of life and use of BIOW. These analyses will be general in nature and will not be intended to individually evaluate a user, make decisions about them, carry out commercial segmentation or send them personalized commercial communications. BIOW will apply the following criteria:
  • Prioritize the use of anonymized, aggregated or dissociated data;
  • Limit access to authorized personnel;
  • Prevent R&D or scientific department personnel from accessing direct user identifiers where this is not necessary;
  • Apply pseudonymization measures where appropriate;
  • Document the analyses, purposes, data categories and applicable retention periods;
  • Not use the results for marketing, sale of data, commercial disclosure to third parties or commercial profiling.
Where internal analysis is carried out using personal or pseudonymized data, BIOW will do so on a valid legal basis and with the safeguards required by applicable regulations. Where data have been irreversibly anonymized, such data will no longer be considered personal data.

9. Mobile device permissions

The App may require access to certain mobile device functionalities in order to operate correctly. In particular, it may require:
  • Access to network and connectivity, to allow communication with BIOW services and with the BIOW device;
  • Access to local network or WiFi, where essential for connecting, configuring or controlling the device;
  • Access to the location of the mobile device, only where technically necessary for the detection, connection or initial configuration of a new BIOW device and where the operating system requires such permission;
  • Push notifications, if the user wishes to receive operational, technical or informational alerts.
Disabling certain permissions may prevent the use of some App functionalities, especially initial device connection or receipt of operational alerts.

10. Recipients of and access to the data

As a general rule, BIOW will not sell or disclose personal data to third parties for commercial purposes. Data may be processed or disclosed in the following cases:
  • Authorized internal personnel of BIOW EXPOSOMICS, S.L., according to their responsibilities and under a duty of confidentiality;
  • Authorized personnel of the BIOW Group involved in technical, support, R&D or scientific department functions, where necessary and in accordance with the legal role documented in each case;
  • Providers that provide services to BIOW as processors, such as software development and maintenance, hosting, cloud infrastructure, technical support, monitoring, cybersecurity, backups, electronic communications or technical services necessary for the operation of the App;
  • Technical services, technical support teams, carriers or providers necessary to resolve incidents, repairs, returns or device support, where applicable;
  • Public administrations, authorities, courts and tribunals where there is a legal obligation or where necessary for the defense of rights and legitimate interests.
Where other companies of the BIOW Group provide internal services to BIOW EXPOSOMICS, S.L. or participate in R&D, support or scientific department activities, their involvement must be documented through the appropriate legal instrument, including a data processing agreement, joint controllership agreement or equivalent internal authorization, as applicable.

11. International transfers

BIOW will endeavor to ensure that personal data processed through the App are stored and processed within the European Economic Area. If, for the provision of any service, it is necessary to use providers located outside the European Economic Area or that may access data from third countries, BIOW will ensure that such processing is carried out in accordance with the safeguards provided for in Articles 44 et seq. of the GDPR, including, where appropriate, adequacy decisions, standard contractual clauses, binding corporate rules or complementary technical, organizational and contractual measures.

12. Retention periods

BIOW will retain personal data for the time necessary to fulfil the purpose for which they were collected and, subsequently, for the periods required by applicable regulations or necessary for the formulation, exercise or defense of claims. As a general rule, the following criteria will apply:
  • Account data: while the account remains active and, subsequently, for the period necessary to address legal or contractual liabilities;
  • Connected device data: while the device remains associated with the account or is necessary to provide support, maintenance, warranty, technical traceability or defense of claims;
  • Technical data, logs and security: for the time strictly necessary to ensure security, continuity, technical traceability, diagnosis and legal defense;
  • Incident and technical support data: while the incident is being managed and during subsequent liability periods;
  • Location data for initial connection: for the time strictly necessary to complete the connection and, where essential, to manage associated technical incidents or keep a minimum technical trace of the process;
  • Responses and results of the Biowoman and phenotype questionnaires: while the account remains active and the user does not request their deletion, to the extent necessary to show historical progress and comparisons;
  • Data used in statistical studies, R&D or by the scientific department: preferably anonymized or aggregated. If personal or pseudonymized data are retained, they will be kept for the time necessary for the corresponding analysis or study and in accordance with the documented safeguards;
  • Irreversibly anonymized data: may be retained without time limitation, as they do not allow specific individuals to be identified.
When the data are no longer necessary, BIOW will delete, anonymize or block them, as appropriate.

13. Integration of Biowoman and external services: SofIA

13.1. Biowoman Survey integrated into the App

The Biowoman Survey is integrated into the BIOW App itself as an internal questionnaire in the “Measure Yourself” section. Consequently, its responses, results and, where applicable, history or progress will be processed within the BIOW App environment under the responsibility of BIOW EXPOSOMICS, S.L. The App will not redirect the user to an external website to complete the Biowoman Survey, unless expressly indicated in a transitional version or complementary functionality and the applicable policy is provided. The processing of the integrated Biowoman Survey will be governed by this Privacy Policy and by the specific information that, where applicable, is displayed before starting the questionnaire.

13.2. SofIA AI agent

The BIOW App may allow access via an external link to the SofIA AI agent, available at https://sofiabiow.com/. SofIA is a service external to the BIOW App. When accessing it, the user leaves the App environment and enters a website managed under its own privacy policy and, where applicable, cookie policy. The controller for the processing carried out by the SofIA agent is BIOW PREVENTIVE SERVICES, S.L. The BIOW App does not transmit user account data to the SofIA service. The queries or interactions that the user carries out directly in the sofiabiow.com environment will be governed by the privacy policy applicable to that service. Before accessing SofIA, the App must inform the user that an external environment is being opened and that the controller of the processing for that service is BIOW PREVENTIVE SERVICES, S.L.

14. User rights

The user may exercise the following rights, under the terms provided for by applicable regulations:
  • Right of access to their personal data;
  • Right to rectification of inaccurate data;
  • Right to erasure of their data where applicable;
  • Right to object to processing in the legally established cases;
  • Right to restriction of processing;
  • Right to data portability, where the processing is based on consent or on the performance of a contract and is carried out by automated means;
  • Right to withdraw the consent given, without affecting the lawfulness of processing carried out prior to withdrawal.
In particular, the user may request deletion of the historical results of the Biowoman and phenotype questionnaires or of their account, without prejudice to any data that must be retained in blocked form due to legal obligations or for the formulation, exercise or defense of claims. To exercise these rights, the data subject may contact BIOW EXPOSOMICS, S.L. by email at lopd@biow.net or by postal address at Calle Michel Faraday, 75 – Units 9-10, 33211 Gijón, Asturias, Spain. The request must sufficiently identify the applicant and specify the right they wish to exercise. Likewise, if the user considers that their rights have not been properly addressed, they may lodge a complaint with the Spanish Data Protection Agency.

15. Withdrawal of consent

Where processing is based on the user’s consent, the user may withdraw it at any time. Withdrawal of consent will not affect the lawfulness of processing carried out prior to withdrawal. Withdrawal of consent may mean that BIOW can no longer provide certain functionalities associated with the processing, such as the Biowoman and phenotype questionnaires, the retention of historical results or certain internal statistical analyses based on personal data.

16. Minors

The BIOW App is not generally intended for minors, unless a specific functionality expressly provides otherwise and the necessary legal coverage exists. BIOW will not deliberately process minors’ data without complying with the applicable legal requirements. If the unauthorized collection of a minor’s data is detected, such data will be deleted as soon as possible.

17. Automated decisions and profiling

BIOW will not make decisions based solely on automated processing that produce legal effects concerning the user or similarly significantly affect them. The Biowoman and phenotype questionnaires generate informational well-being or quality-of-life results so that the user can view their result and progress, but they are not used to make automated decisions, perform diagnoses, commercially profile the user or individually evaluate the user with legal or similarly significant effects. There may be automated technical or security controls, such as error detection, irregular access detection, technical validations or system integrity checks, without this implying the adoption of automated decisions with the effects indicated above.

18. Security and confidentiality

BIOW applies appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account the nature of the data processed, the functionalities of the App and the state of the art. Among other measures, BIOW may apply access controls, authentication, permission management by profiles, encryption where appropriate, pseudonymization, event logging, backups, security monitoring, segregation of environments, minimization of access to data and confidentiality duties for authorized personnel. Access to the results of the Biowoman and phenotype questionnaires or to data used for R&D and the scientific department will be limited to authorized personnel who need to know such data for the performance of their duties, applying minimization, aggregation, anonymization or pseudonymization measures where appropriate. The user must adequately protect their credentials, mobile device and access, avoiding sharing passwords or allowing unauthorized access to their account.

19. Purpose limitation

The data collected through the BIOW App will be processed exclusively for the purposes described in this Privacy Policy or for other purposes that are compatible or have been adequately communicated with the corresponding legal basis. In particular, BIOW will not use location data, technical device data or results from the Biowoman and phenotype questionnaires for advertising purposes, commercial disclosure to third parties, analysis of personal habits not disclosed, continuous location tracking, commercial profiling or individualized evaluation of the user with legal or similarly significant effects.

20. Changes to the Privacy Policy

BIOW may amend this Privacy Policy to adapt it to regulatory, technical, organizational or functional changes in the App. Where the changes are relevant, BIOW will notify users through the reasonable means available, including, where appropriate, notices within the App itself. The current version will be the one published at any given time in the App or in the channel enabled by BIOW for this purpose.

21. Contact

For any query relating to this Privacy Policy or to the processing of personal data carried out through the BIOW App, you may contact BIOW EXPOSOMICS, S.L. by email at lopd@biow.net or by postal communication addressed to Calle Michel Faraday, 75 – Units 9-10, 33211 Gijón, Asturias, Spain.