The company REVITALIVE s.r.o., Co. Reg. No: 13968297, with registered office at Bulharská 996/20, Vršovice, 101 00 Prague 10, Czech Republic, registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, Insert 358059 (hereinafter referred to as “REVITALIVE“), as the data controller, hereby provides information regarding the processing of personal data carried out in connection with the provision of the service “REVital” to the customer (hereinafter referred to as the “Customer“), which the Customer uses through the mobile application “REConnz” (hereinafter referred to as the “Application“). This document includes information on the rights of data subjects in connection with such processing.

For any questions about privacy protection and the exercise of your rights, please use the following contact:

•   Email: gdpr@revital.live.

1.      For what purpose, on what legal basis, and which personal data do we process?

1.1.  Entering into and performance of the Agreement

REVITALIVE cooperates with Customers on the basis of an agreement concluded with the respective Customer under the terms and procedure set out in the applicable Terms and Conditions of REVITALIVE, the subject of which may be the provision of services with or without Paid Content (hereinafter referred to as the “Agreement“). For the conclusion and execution of the Agreement and its subsequent performance – including enabling the use of the Application, registration and management of the Customer’s user account, and the provision of services involving the transmission, processing, and display of data – REVITALIVE requires the following personal data of the Customer as a natural person:

•   Identification and contact details of the Customer (natural person): name, surname, date of birth, email address;
•   Registration data related to the Customer’s user account: username and password (in encrypted form), and information provided by the Customer during the registration process (such as gender);
•   Technical data: device identifier;
•   Information from any communication with the Customer and other details concerning the course of the contractual relationship with the Customer.

Paid Content is available within the Application, which the Customer may purchase through the Application (hereinafter referred to as “Paid Content“). To enable the purchase and provision of Paid Content, including the fulfillment of related obligations (in particular, sending purchase confirmations to the Customer), REVITALIVE requires the following personal data of the Customer—natural person—in addition to the data listed above:

•   Billing information of the Customer;
•   Data related to the payment for the Paid Content, to the extent required by the selected payment method (e.g., payment identifier, date of payment).

Without the above data, the Agreement cannot be concluded or performed, meaning that the agreed services cannot be provided to the Customer. The legal ground for processing this data is the conclusion and performance of the Agreement at the request of the Customer.

1.2.  Data Subject’s Consent

REVITALIVE enables the Customer to grant consent for the processing of the following personal data – of the Customer as a natural person – for the purpose of enabling full functionality of the Application:

•   Health-related data of the Customer obtained from a third party, which was provided to such party directly by the Customer and/or collected from a supported device (e.g., weight, height, body mass, heart rate, blood pressure, blood glucose levels, user activity, wake and sleep times).

Without the above data, it is not possible to provide the Customer with the full functionality of the Application. The purpose of processing this data within the Platform is to subsequently display and evaluate it by REVITALIVE using the Application, in particular to analyze health-related data, compare it with historical data, and inform the Customer of any differences compared to such data.

Since the above-mentioned personal data constitutes health data, falling under special categories of personal data, the legal basis for processing such data is the data subject’s consent, i.e., the Customer’s consent. The Customer grants consent to the processing of the above data by ticking a checkbox or clicking a button containing the wording: “The user gives explicit consent to the processing of health data under the conditions stated in the Privacy Policy“, as part of a separate declaration displayed during the first launch of the Application, which includes a link to this data processing information.

Consent may be withdrawn at any time via the user account (in the Application) or by contacting the email address provided above.

1.3.  Compliance with legal obligations

REVITALIVE has to process personal data where required by law. For this purpose, REVITALIVE processes, in particular, personal data to the extent required by the relevant legal regulations in connection with REVITALIVE’s obligation to keep accounts and for the performance of related tax obligations, or for the fulfilment of obligations imposed by the Archiving Act.

1.4.  Legitimate interests of REVITALIVE

In justified cases, REVITALIVE may also process personal data on the legal ground that is the protection of its legitimate interests. However, REVITALIVE always thoroughly assesses and ensures that the interest in processing your data for this purpose does not unduly interfere with your privacy.

Proof of Consent to the Terms and Conditions of REVITALIVE: The Customer enters into the Agreement with REVITALIVE via electronic means, by expressing consent to the Terms and Conditions upon the first launch of the Application. Therefore, in order to protect REVITALIVE’s legitimate interests (to retain evidence that a specific Customer has agreed to the Terms and Conditions of REVITALIVE in their specific version), REVITALIVE stores data necessary to identify the Customer as a contractual party, as well as data confirming the Customer’s actions (i.e., conclusion of the Agreement and consent to the Terms and Conditions).

Proof of Consent to the Processing of Health Data: Consent to the processing of health data is granted by the Customer electronically during the first launch of the Application. Accordingly, and for the purpose of protecting REVITALIVE’s legitimate interests (to have proof that a specific Customer granted consent to the processing of such data and to what extent), REVITALIVE retains data necessary to identify the Customer as a contractual party and data confirming the Customer’s actions (i.e., consent to the processing of personal data and the scope of personal data for which consent was granted).

Defense and Enforcement of Legal Claims of REVITALIVE: REVITALIVE also processes personal data for the purpose of protecting a legitimate interest, which is to ensure the possibility of defending REVITALIVE in the context of potential legal disputes, court proceedings or inspections by state authorities or other public authorities. We process this data in order to be able to demonstrate, where necessary, that we have acted in accordance with our contractual obligations and legal regulations.

Analysis and improvement Platform: REVITALIVE also processes data about the Customer’s activity within the Application (Activity Logging) for the purpose of protecting its legitimate interest – the analysis of the use of the Application and its future improvement. For these purposes, REVITALIVE collects and further processes data such as device identifier, date and time of Application access, the use of its functions.

1.5.  Sending commercial communications

In the case of Customers with whom we have concluded an Agreement and in connection with which we have obtained their email address, or in the case of other individuals who have actively and voluntarily subscribed to our newsletters (e.g., via the REVITALIVE website), we process the personal data of these individuals – specifically their email address – for the purpose of sending information and updates about our services and products (commercial communications).

The legal basis for the processing of personal data for the purpose of sending commercial communications, in the case of our Customers, is the legitimate interest of REVITALIVE. The Customer has the option to opt out of receiving further commercial communications at any time and free of charge, either by following the instructions provided in each commercial communication, through their user account (within the Application), or by contacting us at any time via the contact email address provided earlier in this document.

The ground for the processing of personal data for the purpose of sending commercial communications is, in the case of persons who have actively subscribed to the newsletter themselves (regardless of whether they are Customers or not), is their consent, which was granted just by subscribing to commercial communications. If you do not wish to receive these messages from us, you have the option to unsubscribe from them at any time free of charge. The option to do so is always included, among other things, in each such newsletter that is sent, or you may unsubscribe from newsletters at any time through the interface of your user account (in the Application).

2.      Who do we receive personal data from and to whom do we transfer it?

We primarily obtain personal data from the Customers – the data subjects. If, within the Application, you consent to the provision of selected personal data by a provider acting as a third party, that provider will transfer the data to us to the extent of your consent. Registration and login within the Application, as well as payments for Paid Content, are carried out through a third-party service (Stripe, see below). For this purpose, the provider of this service transfers personal data to us with your consent. Unless stated otherwise, we do not collect any additional information about you other than the data you provide to us yourself (or which we obtain from a third party with your consent), or which is generated through your activity within the Application and your user account. You are required to provide us only with accurate information and if your personal data changes, you must update it.

We may transfer personal data under the conditions laid down by law to public authorities where we are required to do so by law, or where the authority so requests within its competence.

We use the following processors for data processing:

•   Stripe, Inc., with registered office at 185 Berry Street Suite 550, San Francisco, CA 94107, USA.

In the case of the above-mentioned processor, a data transfer to a third country – the United States – takes place.  In such a case, the data is transferred under the conditions set out in the EU Commission’s decision that the United States ensures an adequate level of data protection (within the so-called Data Privacy Framework), along with the adoption of additional security measures to safeguard the data.

3.      How is the personal data processed?

We process your personal data electronically by automated means for the purpose of managing user accounts and analyzing and displaying data within the Application. We may also process your personal data manually, in accordance with the relevant purpose, where manual processing is necessary or appropriate, or in the event that you use Paid Content as part of the services provided. In the management of your data, our employees or other individuals working on our behalf may be involved, including for the purposes of data analysis and evaluation, error correction, resolving inaccuracies, and similar activities. However, such persons may process personal data only under the conditions and to the extent specified above and are bound by the obligation to remain confidential about the personal data and security measures, the disclosure of which would compromise the security of personal data.

We always process personal data in accordance with the relevant legal regulations and ensure proper care and protection of such data. We take care that you do not suffer harm to your rights, especially the right to human dignity and to your private and personal life.

4.      How long is your personal data processed?

4.1.  Agreement with the Customer, Customer’s Consent

We process personal data processed for the purpose of entering into and performing the Agreement for the period of entering into and performing the given Agreement (i.e. for the period necessary to fulfil the obligations arising from it). Personal data processed on the basis of the data subject’s (Customer’s) consent is processed until the Customer withdraws their consent, but no longer than for the duration of the performance of the Agreement.

Afterwards, we may also process personal data for the following purposes:

4.2.  Compliance with legal obligations

We process personal data processed on the ground of our legal obligations within the time limits set by those laws.

We need to process the personal data required by the legislation regulating the tax and accounting obligations of REVITALIVE (typically, billing data and information about the provided performance) for accounting purposes and tax compliance. The data retention period is 5 years from the end of the accounting period. We archive relevant personal data in accordance with the requirements of the Archiving Act for the period specified therein.

4.3.  Legitimate interests

We continue to process personal data even after the termination of the Agreement for the protection of our legitimate interests (i.e., for the purpose of defending against potential claims by Customers or third parties, including in court proceedings, for record-keeping purposes, to demonstrate consent to the Terms and Conditions, and to identify individuals acting on behalf of the Customer with REVITALIVE) for the duration of the applicable limitation periods, which in the Czech Republic may last up to 15 years from the occurrence of the relevant event. If a relevant claim is not applied, this period is typically five (5) years from the termination of the Agreement.

4.4.  Sending commercial communications

We send commercial communications as outlined above until you opt out.  The option to opt out is provided in each communication sent and is free of charge. You may also opt out at any time via the user account (in the Application) or contact e-mail mentioned above.

4.5.  Longer processing

Personal data may be processed even longer than stated above in the case where a relevant reason for further processing arises, typically where administrative or judicial proceedings are initiated for which the personal data is relevant.

5.      What are your rights?

First of all, you have the right to request access to your personal data, including making a copy of all your personal data. You may do this using the e-mail address stated in the header of this document.

Withdrawal of consent to the processing: If we process your personal data based on your consent, you may freely and at any time withdraw your consent to such processing, free of charge, through your user account (in the Application), via the contact e-mail address provided above, or in another manner as specified elsewhere in this document. In this case, we no longer process your personal data based on consent.

For personal data not processed based on a consent, it is not possible to withdraw consent to the processing. However, based on your request, we always assess whether it is still necessary to process your personal data for any of the above purposes.

Your other rights:

We will always inform you about:

•   the purpose of processing personal data,
•   the personal data, or the categories of personal data subject to processing, including any available information as to its source;
•   the nature of automated decision-making, including profiling, and information about the logic involved, as well as the significance and envisaged consequences of such decision-making for the data subject;
•   the recipients or categories of recipients to which the personal data has been or will be transferred and, in the event of a transfer to a third country, appropriate safeguards relating to the transfer to ensure the security of the personal data;
•   where possible, the envisaged period for which the personal data will be stored, or, if such period cannot be determined, the criteria used to set that period;
•   where the personal data is not collected from you, any available information as to its source.

Your other rights include:

•   ask us for explanation,
•   require us to remedy the situation, in particular it may be blocking, correction, completion, restriction of processing or destruction of personal data (right to be forgotten),
•   request a copy of the personal data processed or request personal data concerning you in a structured, commonly used and machine-readable format, and transfer such data to another controller without us preventing such transfer in any manner.
•   file a question or complaint with the Office for Personal Data Protection,
•   object to the processing of personal data concerning you.

6.      How we protect your personal data

Your personal data is protected. In particular, the following means of security are used for this purpose: implementation and enforcement of internal personal data protection regulations, antivirus protection, firewalls, encryption, control of access to personal data, authorization data, backing up, physical means of protection and more.

This version of the Personal Data Processing Information is effective as from 14.04.2025 .