WE TAKE PRIVACY SERIOUSLY

Elevating Privacy to a Treasured Artform: Wearatec’s Uncompromising Commitment to Safeguarding Your Personal Data

PRIVACY POLICY
Date: Jan 01, 2024
Wearatec designs, develops, and produces connected accessories for luxury watches which all connect to ONE OS, a Wearatec brand. Our heath sensing devices observe users’ health via heart rate, HRV, and SpO2. Additionally, we gather motion sensor data such as steps, sleep, activity, and gestures. All of this data is transmitted into ONE OS, where the application’s algorithms evaluate and analyze it, providing users with health insights.

1. OUR COMMITMENT TO YOUR PRIVACY
1.1 Our Privacy Policy tells you what personally identifiable information Wearatec Inc. and ONE OS a brand of Wearatec (“ONE OS”, “we”, “our”) collect, how we use it, and how we may disclose it, as well as certain of your rights. This privacy policy describes the privacy practices for our devices, applications, website, products and services with respect to the digital health (“Services”). We will only use your personal information in accordance with this policy unless otherwise required by applicable law.
1.2 Personal Information means any information, recorded in any form, about an identifiable individual or an individual whose identity may be inferred or determined, directly or indirectly, from such information, and includes personal health information, such as information concerning physical or mental health.
1.3 Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use ONE OS Services. By accessing or using ONE OS Services, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy).

2. CONSENT
2.1 To register for an account with us, you must provide your express consent to our collection, use, transfer and disclosure of your personal information as described in this Policy. When you provide us with your express consent and use our Services, or otherwise interact with us, you consent to the collection, use and disclosure of your personal information by ONE OS in accordance with the terms of and for the purposes set out in this Policy.
2.2 We only collect, use or disclose your personal information with your consent.
2.3 Please note that it is always your choice whether you provide us with your personal information, however, in some circumstances, if the personal information requested is necessary in order for us to provide a product or service to you, we may be unable to provide that product or service to you without your personal information.
2.4 We will ask for your consent if we wish to use your personal information for purposes other than those listed in this Privacy Policy or if we are required to request your express consent under applicable law, unless an exception to consent applies (e.g. in the event of a lawful government demand for information).
2.5 You may withdraw your consent for us to collect, use and disclose your personal information at any time, by contacting us at the email/address provided at the end of this Policy. It is important to realize, however, that withdrawal of your consent will not operate retroactively and may impact your ability to use our services.

3. INFORMATION WE COLLECT AND HOW WE COLLECT INFORMATION ABOUT YOU
3.1 When you use our Services, we collect the following information you provide ONE OS
(a) Account Information:
To establish an account on our Services, you must provide certain information, including your name, email address, password, date of birth, gender, height, and weight, activity level, your goals (calories, steps, sleep).
You may opt to offer other information, such as a profile photo, email, displays, photographs, and other information, material and information you submit, post, publish, display, or transmit to and via the ONE OS Service.
(b) Additional information
To enhance your experience or enable certain elements of the ONE OS Services, you may opt to give additional information to us, such as your weight, sleep, activity level, your goals (calories, steps, sleep) and your fitness data from EVB (heart rate).

3.2 Information About The Device
(a) Data about your activity on and use of our Services. Your device collects data in order to estimate a range of metrics, including the number of steps you take, the distance you travel, the calories you burn, your weight, your heart rate, your sleep phases and your active minutes,. The type of data gathered varies according on the device being used. When you sync your device with our applications or software, the data stored on your device is sent to our servers.
3.3 Information About Geolocation
(a) ONE OS Services incorporate capabilities that make use of accurate geolocation data, such as GPS signals, device sensors, Wi-Fi access points, and cell tower identification. If you enable access to your location, we will gather this sort of data. You may always disable our access through the settings on your ONE OS enabled device or mobile device. Additionally, we may determine your approximate location based on your IP address. We also collect location information for Android devices only.
3.4 Usage Information
(a) We obtain certain use or network activity information when you access or utilize our Services. This includes information regarding your interactions with the Services, such as when you browse or search for content, install programs or software, create or log into an account, link your ONE OS device with your account, or access or engage with an application on your ONE OS device.

4. Cookies
4.1 ONE OS may use cookies, web beacons, behavioral advertising or similar technology to track your use of its app.
(a) Our app places cookies, which are small data files, on your computer or handheld device. Cookies are essential for helping us deliver a high quality app and online experience for our users, and some collect information about browsing behavior.
(b) A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular app. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
(c) ONE OS uses traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our app in order to tailor it to customer needs. ONE OS only uses this information for statistical analysis purposes and then the data is removed from the system.
(d) The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve ONE OS Services and to deliver a better and more personalized service, including by enabling us to:
1) Estimate our audience size and usage patterns;
2) Store information about your preferences, allowing us to customize ONE OS Content and ONE OS Services according to your individual interests;
3) Speed up your searches;
4) Recognize you when you return to our website or app.
(e) Google Analytics and the Facebook Pixel are used on our website. Please visit these third-party sites to review their privacy policies and manage their cookies, and for information on how to opt-out of some of these practices:
(i) Google Analytics is a web analytics service that provides statistics and analytical tools for search engine optimization and marketing purposes. We use Google Analytics which allows us to see information on user website activities including, but not limited to, page views, source and time spent on our website and to provide advertisements to you on other websites. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. We use Google Analytics on our website to analyze how users use the website, Google Analytics may collect information such as user location as inferred from IP address, the amount of time a visitor spends on our website, which pages are more frequently accessed, how the website is accessed (either directly, a search engine, or from a link), what sort of software is used (e.g. operating system, browser type, etc.), as well as demographics. For more information on how Google Analytics collects and processes information, please visit: www.google.com/policies/privacy/partners/.
For information about how to opt out of having your information used by Google Analytics, visit: https://tools.google.com/dlpage/gaoptout/.
(ii) Google AdWords: We use Google AdWords Remarketing to advertise ONE OS across the Internet and to advertise on third party websites (including Google) to previous visitors to our website. AdWords remarketing will display ads to you based on what parts of the ONE OS website you have viewed by placing a cookie on your web browser. It could mean that we advertise to previous visitors who have not completed a task on our site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our website, so that they may show you ads relating to that page. If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google’s Ads Preferences Manager.
(iii) We work with Facebook and Instagram to collect data that helps us track conversions from Facebook or Instagram ads, optimize ads, build targeted audiences and remarket users. For more information on Facebook’s and Instagram’s advertising tools and your options to opt-out, please visit:
Facebook: https://www.facebook.com/policies/cookies
(iv) Some of our advertising services providers are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies.

4.2 Other Automatically-Gathered Information
(a) ONE OS may automatically record information when you visit its app, including the URL, IP address, browser type and language, and the date and time of your visit. ONE OS uses this information to analyze trends among its users to help improve its app or customize communications and information that you receive from us. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our app.

5. HOW INFORMATION IS USED
5.1 When ONE OS uses or processes personal data about you, it does so only as necessary to provide the Services you use or otherwise with your consent, to communicate with you, or to comply with applicable law as described in this Policy. Through our app, you will be provided with the choice of which types of communications you will receive with us, and the ability to change those choices whenever you want. We use information that we collect about you or that you provide to us, including any personal information:
(a) To provide you with information, products, or services that you request from us. For example we use your information to create and maintain your account.
(b) To provide you with heath insights based on your use of the Services.
(c) To respond to communication, reach out to you about your account or Services, market our products and services, provide other relevant information.
(d) To improve our Website, products or services, marketing, or customer relationships and experiences.
(e) To allow you to participate in interactive features or similar features on our Website and Services.
(f) To protect individuals, employees, and ONE OS and for loss prevention and to prevent fraud.
(g) To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
(h) In any other way we may describe when you provide the information.
We store personal information on our servers located in North Virginia, United States of America

6. HOW WE SHARE YOUR PERSONAL INFORMATION
6.1 We may share your personal information that we collect or you provide as described in this privacy policy:
(a) To our third-party service providers to fulfill the purpose for which it has been collected or as set out in the Privacy Policy, for example to assist us in continuously improving the application’s functionality and data analysis for the user.
(b) In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ONE OS’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ONE OS about our customers and users is among the assets transferred.
(c) To fulfill the purpose for which you provide it.
(d) For any other purpose disclosed by us when you provide the information.
(e) With your consent.

6.2 ONE OS may also disclose your personally identifiable information, if such disclosure is:
(a) required by law, or other legal process or to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law;
(b) necessary to investigate violations of or otherwise enforce our Terms which can be found here: https://oneos.com/terms-conditions/
(c) necessary to protect us from legal action or claims from third parties including you; and
(d) necessary to protect the legal rights, personal/real property, or personal safety of our company, clients, third party partners, employees, and affiliates.

6.3 We may disclose aggregated information about our users, and information that cannot reasonably be used, directly or indirectly, to identify any individual. For example we share your aggregate and de-identified information with exercise analytics contractor. The contactor is an exercise intelligence company combining expertise in physiology, precision health and data science with a deep understanding in technology, molecular profiling, and practical sports performance. ONE OS uses health analytics algorithms developed by contractor to provide our customers industry leading health insights.

7. TRANSFERRING YOUR PERSONAL INFORMATION
7.1 We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
7.2 We may process, store, and transfer your personal information in and to a foreign country including Canada, United States, United Kingdom and Sweden, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
7.3 By submitting your personal information or engaging with ONE OS Services or ONE OS Content, you consent to this transfer, storage, or processing.

8. ACCESS AND CONTROLLING YOUR INFORMATION
8.1 We provide you with privacy preference in account setting to allow you to control your information. By login into your account, you may access a wealth of personal information, including your dashboard, which contains information on your daily exercise and activities. Additionally, you may download information in a regularly used file format via your account settings, including data on your activities, physique, meals, and sleep.
(a) You may edit and remove your personal information by login into your account and accessing your account settings. For example, you may change or delete the information you offer in your profile and, if desired, deactivate your account.
(b) If you want to deactivate your account, please keep in mind that while the majority of your information will be erased within 30 days, certain information, such as data collected by your ONE OS device and other data held in our backup systems, may take up to 90 days to delete completely. This is because of the magnitude and complexity of the data storage systems we utilize. Additionally, we may retain data for legal reasons or to avert harm.
(c) You can limit how your information is visible to other users of the Services via your privacy settings; you can also limit the number of notifications you receive from us via your notification settings; and you can revoke access to third-party applications previously connected to your ONE OS account via your application settings. Additionally, you may unpair your device from your account at any moment using the ONE OS program.

8.2 In addition to the privacy preference and account options set out above, you may exercise any of the rights described in this section by sending an email to us at the contact information below. Please note that we will ask you to verify your identity before taking further action on your request to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

9. DATA RETENTION.
9.1 Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

10. SECURITY OF DATA
10.1 We will use reasonable security measures to help protect your personal information against unauthorized access such as physical, technical, administrative, and physical restrictions. However, no mode of data transmission or storage is fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any personal information. Please contact Customer Support if you have a security-related concern.

11. PROTECTING YOUR CHILD’S PRIVACY
11.1 ONE OS understands the special importance of protecting the privacy of children. We do not knowingly permit children under the age of 16 to become registered members of our app and to use our services, without proven parental consent. ONE OS does not knowingly collect or solicit Personal Information about children under 16, except with their parent or guardian’s express consent

12. USER CHOICES ABOUT RECEIVING MAIL
12.1 You may receive e-mails regarding their account and products or services. You may also receive e-mails with information and/or special offers about products and services that may be of interest to customers, unless you indicate you do not want to receive them. ONE OS complies with Canada’s Anti-Spam Legislation with respect to such communications.
12.2 We give you an opportunity to let us know your preference in terms of receiving promotional e-mail when you register for a service, provide us with their Personal Information, or when we send uses e-mails. If you choose not to accept promotional e-mail, you may not receive special offers that may be of value. This option applies to promotional e-mail only, as we may find it necessary to send you e-mail relating to your account or services. Promotional e-mail that you receive from ONE OS will tell you how to decline receiving future promotional e-mail.

13. LINKS TO OTHER WEBSITES
13.1 This Privacy Policy only addresses the use and disclosure of information by ONE OS. Other websites that may be accessible through this website and have their own privacy policies and data collection, use and disclosure practices. Once you have used these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide while visiting such sites and such sites are not governed by this privacy statement. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

14. CHANGES TO OUR PRIVACY POLICY
14.1 ONE OS reserves the right to change this privacy policy at any time. If we decide to change this Privacy Policy, we will post those changes on the app so our users are always aware of what information we collect, use, and disclose. In all cases, your continued use of our app after any change to this Privacy Policy will constitute your acceptance of such change.

15. HOW TO GET IN TOUCH WITH US
15.1 If you have any concerns regarding this policy or want assistance in exercising your privacy rights, please contact our CEO by writing to one of the following address: team@wearatec.com; Visit www.wearatec.com or www.oneos.com for more ways to get in touch with us.
This Privacy Policy was last updated on Jan 1, 2024.

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