Eldie - Virtual Friend of Seniors

PERSONAL DATA PROCESSING POLICY

I. General information

The privacy of your personal data is one of the primary concerns of S.C. SILVERCARE S.R.L., headquartered in Cosâmbești village, Cosâmbești commune, Valea Pezenului Street, no. 4, Ialomița County, Romania, acting as data controller ("Eldie" or "the Controller").

This document ("GDPR Policy") is intended to inform you about how your personal data is processed in the context of using the Eldie mobile application ("the Application").

We note that the processing of your personal data is carried out in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("the General Data Protection Regulation" or "GDPR").

II. Categories of personal data processed

We inform you that the only personal data we process is the data you provide when using Eldie's services. Please note that you are not obligated to provide us with your personal data; however, in that case we will be unable to provide you with our services.

When you become a user of the Application, Eldie will process your personal data, such as first and last name, phone number, email address, billing address, delivery address, data relating to how you use the Application — for example your behaviour/preferences/habits within the Application — as well as any other categories of data you provide directly in the context of creating a user account, in the context of using the services offered through the Application, or in any other way arising from your use of the Application. If you use your Facebook, Google, Apple or similar account to create a user account on the Application, Eldie will process the following public profile data displayed by those applications: username, email address.

The personal data that Eldie processes is the data provided by you both at the time of creating a user account and through the use of the Application and its services, including but not limited to the information you provide during conversations with the artificial intelligence model ("Virtual Friend").

The information you provide through conversations with the Virtual Friend will be summarised after a determined number of interactions with the Virtual Friend and will be saved in Eldie's database.

In particular, Eldie informs you that it may collect and store data regarding your health, should you provide such information through the Virtual Friend, for the sole purpose of improving your experience with the Virtual Friend.

III. Purposes and legal bases of processing

We process your personal data in order to provide a service requested by you, such as the use of the Application, and to be able to identify you as a user and respond to your requests.

We will also process your data on the basis of our legitimate interest, for example to improve our services or to resolve possible disputes.

IV. Duration of data processing

Eldie will process your personal data for as long as is necessary to achieve the processing purposes mentioned above in section 3.

If you are a user, we will process your data for the entire duration of the contractual relationship and, after the termination of that relationship, the data will be processed in accordance with the legal obligations incumbent on Eldie (for example, financial-accounting supporting documents containing your personal data will be retained for the period provided by the regulations in force at the time the obligation to archive those documents arises).

Should you exercise the option to delete your user account by pressing the Delete account button in the My account information section, Eldie will interpret this action as your choice to unsubscribe from receiving commercial communications keeping you updated about the products and services offered through the Application. Accordingly, if you choose to delete your user account, we will no longer send you emails and/or SMS messages of this kind. However, please note that deleting your account will not automatically result in the deletion of your personal data. Should you no longer wish your personal data to be processed, or if you wish to have your data erased, you may exercise the rights detailed in section VIII below. If you request the deletion of your account but there is at least one active order on that account, the account deletion request can only be registered after the products have been delivered and the last active order has been completed.

If you withdraw your consent to the processing of data for marketing purposes, Eldie will cease processing your personal data for that purpose, without affecting the processing carried out by Eldie on the basis of the consent you expressed prior to its withdrawal.

V. Disclosure of personal data

For the purposes of processing, Eldie may disclose your data to partners, to third parties or entities that support Eldie in carrying out its activities through the Application (such as IT service providers, accounting service providers, commercial partners), or to central/local public authorities, in the following exemplary cases:

(i) for the administration of the Application;

(ii) in situations where such communication is necessary for awarding prizes or other benefits to data subjects obtained as a result of their participation in various promotional campaigns organised by Eldie through the Application;

(iii) for maintaining, personalising and improving the Application and the services operated through it;

(iv) for performing data analysis, testing and research, monitoring usage and activity trends, developing safety features and authenticating users;

(v) for sending commercial marketing communications, within the conditions and limits provided by law;

(vi) when the disclosure of personal data is required by law.

In particular, we assure you that in the event we engage a natural or legal person as a data processor for the processing of your personal data, we will ensure that a written agreement exists whereby that person assumes, among other obligations provided for by personal data protection legislation, the obligations (i) to process personal data only in accordance with our written instructions and (ii) to effectively implement measures to protect the confidentiality and ensure the security of personal data. We will also ensure that the written agreement between us and the processor includes at least all other obligations provided by applicable personal data protection legislation and that the protection afforded to you is at least as comprehensive as set out in this document.

VI. Security of your data

We pay particular attention to the personal data you provide to us and we continuously improve our technical and organisational measures in order to guarantee the highest possible standard of personal data security.

In particular, we take care to develop dedicated policies through which we analyse and improve the data processing practices and policies of our customers and other individuals, in order to secure our systems against potential security threats.

We also take care to process minimum data sets, without exceeding the information necessary for our purposes. At the same time, we ensure that only authorised processors and a limited circle of authorised persons can access your data. We also commit to continuously training authorised staff to be attentive to any potential threat to your data.

VII. Transfer of personal data

Personal data provided to Eldie may be transferred outside Romania, but only to states within the European Union or to states outside the European Union in respect of which the European Commission has decided that the third country, a territory or one or more specified sectors within that third country, or the international organisation in question ensures an adequate level of protection, in accordance with the GDPR.

VIII. Your rights as a data subject

Under the conditions provided by personal data processing legislation, as data subjects, you benefit from the following rights:

1. Right of access. You have the right to obtain access to your personal data that we process or to copies thereof; you also have the right to obtain from us information regarding the manner in which we process such data, including the purposes and duration of processing, the recipients or categories of recipients to whom we disclose your data.

2. Right to rectification. You have the right to obtain the rectification of inaccuracies or the completion of your personal data that we process.

3. Right to erasure ("right to be forgotten"). You have the right to request and obtain the erasure of your data if the legal basis for processing it has ceased to exist — for example, in situations where we have no legal obligation or legitimate interest in retaining it. Our responses to your erasure requests will always be reasoned with respect to the limits on the exercising of this right, depending on the categories of data processed in connection with you. It is possible that, following a request for data erasure, Eldie may anonymise such data (thereby removing its personal character) and continue processing it under those conditions for statistical purposes.

4. Right to restriction of processing. You have the right to restrict the processing of your data for a period you specify. Please note that this cannot affect processing carried out on the basis of our legitimate interest.

5. Right to data portability. You have the right to receive directly or to obtain the transfer to another controller of the data you have provided to us directly and which are processed by automated means.

6. Right to object. You have the right to object to the processing of data that we process in connection with you on the basis of our legitimate interest.

7. Right not to be subject to an individual automated decision-making process, including profiling, without your consent.

8. Withdrawal of consent. In situations where we process your data on the basis of consent, you may withdraw your consent at any time, at least as easily as you initially granted it; the withdrawal of consent will not affect the lawfulness of the processing of your data that took place prior to withdrawal.

9. Right to lodge a complaint with the supervisory authority. You have the right to lodge a complaint with the personal data processing supervisory authority regarding the processing of your data by us.

For any additional questions regarding how personal data is processed and to exercise the rights mentioned above, please contact us at the email address: [email protected]. We will endeavour to respond as promptly and thoroughly as possible to all your questions and concerns.

IX. Applicability of this GDPR policy

Our GDPR policy applies in connection with the processing of your personal data by Eldie. Should we modify this policy, as may occasionally happen, we will notify you of the changes made and will request your consent in situations where your level of protection would decrease as a result of the modification. In all cases, our GDPR policy can be consulted at https://eldie.co/gdpr.