Sanitas Active App – Data privacy policy

Edition August 2020 / Version 2020

 

Purpose and basis

 

Data privacy and data security are a top priority for Sanitas. We therefore place great emphasis on the protection of personal details in all Sanitas business processes.

The data privacy policy therefore specifies which data Sanitas collects in conjunction with use of the Sanitas Active app and associated services and how it processes this data.

This privacy policy ensures you are fully informed about how your data is handled in conjunction with the Sanitas Active app. This way, you decide whether or not to give us access to your data.

The privacy policy of the Sanitas Active app applies to all services offered in conjunction with the Sanitas Active app. If other provisions are stated in the terms of use for other services, these take precedence or supplement the terms of use for the Sanitas Active app.

 

Privacy agreement

 

1. Who is the owner of the data collection?

The owner of the data collection is

Sanitas Privatversicherungen AG

Jägergasse 3

8004 Zurich.

 

2. What are your rights with regard to your data?

You are entitled at all times to assert your right to data privacy and to demand information on any of your data that Sanitas has stored and processed. You also have the right to amend or add to your data, to object to the processing of your data or to request that your data be deleted. Excluded from the right of deletion is any photographic material provided for the food service, which may be used anonymously. See point 10 below for information on how to contact us. To assert your right to data privacy (information, correction/supplement, objection, deletion), you must make your request in writing, sign an original copy, and send it to us along with a copy of your passport or ID card. You also have the option of permanently deleting your account and exercise data at the touch of a button directly in the app.

 

3. When do we collect data?

We collect your data whenever we are in contact with you in conjunction with the Sanitas Active app. We collect data that you make available to us, data that is generated when you use the Sanitas Active app, and data that is recorded automatically or manually during any contact with us. For example, your data will be collected when you:

• register to use the Sanitas Active app
• use the Sanitas Active app as a registered user
• subscribe to a newsletter or other forms of advertising via the Sanitas Active app
• enter competitions or prize draws
• take part in one of our market research campaigns or surveys
• receive a credit when reaching a step target
• open the Food Scanner to take a photo of a meal

 

4. What data do we collect?

We collect a range of data in conjunction with the Sanitas Active app, including for example:

Personal data

• Surname and first name
• Date of birth and age
• Sex
• Height
• Weight
• Level of fitness
• Calories
• Pulse
• Sleep
• Diet and nutrition
• Address
• Nationality
• Habits of use
• Language preferences
• Telephone number(s)
• Email address(es)
• ID numbers of your technical devices
• Customer number
• Information on subscribed newsletters or information and advertising received
• Consent to the receipt of advertising
• Consent to profile generation
• Consent to the receipt of notifications
• User account information (including the date you open the account)

Exercise data

(from registration onwards)

• Number of steps
• Distance covered on foot
• Minutes cycled
• Minutes swum

Data on customer activities

• Session data with reference to visits to the Sanitas Active app (including duration and frequency of visits, language and country settings, information on the browser and computer operating system, internet protocol addresses, search terms and search results, evaluations submitted).
• Data on usage of the Sanitas Active app (including data on information viewed).
• Communication with us by telephone, email, voice messaging, text messaging (mobile, push notifications, etc.), picture messaging (MMS), video messaging or instant messaging.

Sports Check-in

Users have to allow access to the location data in their device’s settings in order to use the Sports check-in function in the Active app. The Active app (without the Sports check-in function) can still be used if access to the location data is denied.

Data retrieval, data update

On registering for the Sanitas Active app, you expressly agree that, when you log in for the first time, the above data collected from other applications (e.g. Apple Health, Google Fit, Fitbit, Garmin) in the last 7 days may be recorded in the Sanitas Active app.

On registering for the Sanitas Active app, you expressly agree that the above data, collected from the time you register for the Sanitas Active app, may be combined with data from other applications (e.g. Apple Health, Google Fit, Fitbit, Garmin). This consent to the collation of your data applies until you delete your exercise data using the Delete account function.

Data from your Sanitas Active app can only be synchronised with data from other applications (e.g. Apple Health, Google Fit, Fitbit, Garmin) that has been recorded over the last 7 days.

 

5. Why do we process data?

We process your data for different purposes. These purposes can be summarised in various groups. Specifically, we can process all or part of your data for one or more of the following purposes:

Processing purposes in conjunction with the Sanitas Active app

• Provision of the Sanitas Active app
• Calculation of credit on reaching step targets

Processing purposes in conjunction with customer communication

• Provision, administration and execution of customer communication by electronic means of communication.
• Business-related communication by telephone, email, voice messaging, text messaging (mobile, push notifications, etc.), picture messaging (MMS), video messaging or instant messaging.
• Evaluation of the usage of our offers by telephone, fax, email, voice messaging, text messaging (mobile, push notifications, etc.), picture messaging (MMS) or instant messaging, such as: type of use, frequency and duration of use, and exact location of use.

Processing purposes in conjunction with analysis of user behaviour

• Optimisation of the Sanitas Active app by means of individualised and personal/anonymous and group-related recording and evaluation of past and current user behaviour and exercise habits.
• Individualised and personal/anonymous and group-related identification, classification and analysis of current and potential user requirements and user interests.
• Individualised and personal/anonymous and group-related classification and analysis of user potential and exercise habits.
• Statistical evaluation of customer behaviour based on anonymous user data and exercise data.
• Combination and enhancement of the personal data collected by us with personal and non-personal data that is publicly accessible or acquired from third parties for the purpose of improving our database and analysing user behaviour. Enriching of profiles using data from third parties including, for example, data from the Swiss Federal Statistical Office, calendar data, socio-demographic data, publicly accessible data or data from social networks.
• Calculation of the activity score.
• The user's weight and height are used to calculate calories burned. If this information is not provided, average values will be used to calculate calories burned, and the information displayed may be very inaccurate.
• Sanitas is authorised to anonymise your data and subsequently use it for scientific and statistical purposes.

Processing purposes in conjunction with direct marketing

• Simplification of processes and utilisation of findings from the analysis of user behaviour for the continued improvement of the Sanitas Active app.
• Avoidance of unnecessary advertising by using the findings from the analysis of user behaviour for customised and personalised direct marketing.
• Distribution of customised and personalised advertising by post, telephone, fax, email, voice messaging, text messaging (mobile, push notifications, etc.), picture messaging (MMS), video messaging or instant messaging.
• Customisation and personalisation of the Sanitas Active app and advertising through our channels on multimedia portals and social networks.

We also reserve the right to supplement or have supplemented your collected data with additional information (e.g. number of times you've moved house) that has already been collected by the Sanitas Group or made available by professional address brokers.

 

6. Who do we pass your data on to?

For the purposes set out in these privacy rules we can pass on your data to other companies within the Sanitas Group or third parties that process data for Sanitas within the framework of a contractual relationship. The other companies in the Sanitas Group can use your data in their own interests for the same purposes as outlined here. In particular, the companies of the Sanitas Group can process your data in their own interests for customised and personalised analysis of user behaviour and for direct marketing activities. Within the Sanitas Group, employees can only access your data to the extent required for the fulfilment of their tasks. Arrangements are in place to ensure that contracted companies do not use your data independently, outside the scope of the contract, or pass it on to third parties.

If we consider it necessary in order to protect and defend our rights or property, we can also pass on your personal details and exercise data in order to comply with the applicable laws and regulations, in case of legal proceedings, at the request of relevant courts and authorities or due to other legal obligations.

 

7. What rules apply with regard to links to third-party websites?

Our Sanitas Active app and any associated communication (e.g. emails) can contain links to third-party websites. We do not have any influence on the information and services on third-party websites. Nor do we have any influence on how third parties handle the data collected on their websites. We are therefore not responsible for complying with data privacy and other applicable laws with regard to third-party links in the Sanitas Active app or any associated communication. If you have any questions on this matter, please contact the third-party providers directly.

 

8. How do we protect your data?

We have all the requisite technical and organisational precautions in place to protect your data against unauthorised access and processing. These precautions are checked regularly and adjusted in line with advances in technology.

 

9. Can this privacy policy be changed?

We reserve the right to amend or change this data privacy policy at any time. We will inform you of any changes or amendments by email and via the Sanitas Active app. If you do not object to these changes or amendments within 30 calendar days, the new privacy policy will be deemed to have been accepted.

 

10. How can you contact us?

If you wish to assert your rights with regard to your data or if you have any questions or concerns regarding the processing of your data, you can contact us as follows:

By post

Sanitas Privatversicherungen AG, Datenschutzbeauftragter, Jägergasse 3, Postfach, 8021 Zürich

By email

active@sanitas.com

 

11. Final provisions

Sanitas accepts no responsibility for the fact that information, software and/or documentation on the Sanitas Active app may be viewed or downloaded at locations outside of Switzerland. If users access the Sanitas Active app from outside Switzerland, they are exclusively responsible for compliance with all applicable local laws. Access to information, software and/or documentation on the Sanitas Active app from countries where such access is unlawful is prohibited. In this case and where users seek to do business with Sanitas, they should contact a Sanitas representative in Switzerland.

Sanitas reserves the right to make changes to the Sanitas Active app at any time and without prior notice. Likewise, Sanitas reserves the right to change these terms at any time. Changes will be indicated appropriately and the consent of users sought.

Users may deactivate/delete the Sanitas Active app free of charge at any time.

All questions and disputes in connection with the Sanitas Active app are subject exclusively to Swiss law with the express exclusion of any conflict-of-law provisions. Mandatory provisions concerning conflict-of-law rules remain unaffected. Sole jurisdiction is Zurich; compulsory places of jurisdiction remain reserved.

In case of doubt and/or conflict between the German, French, Italian and English versions of these terms, the German text takes precedence.

 

Sanitas, Zurich 17.08.2020