This Privacy Policy (hereinafter “Policy”) sets out how your personal data (hereinafter “Personal Data”) may be handled by ReMark International B.V., its parent company and its affiliates (hereinafter “ReMark”, also referred to as “us”, or “we”, or “our”) in relation to the Biological Age Model BAM application (hereinafter “App”).

To the extent required by law, we will obtain your express consent for certain processing of your personal data. We will use your Personal Data to provide you with the products and/or services available through the App. You understand that your use of the App is voluntary. You do not have to participate in any of the features in the App, and you can stop using the App and delete your account and all accompanying data at any time.

We process, handle and protect your Personal Data with the utmost care. While collecting, processing, using and internationally transmitting Personal Data, we comply with applicable laws and regulations.

The App may contain hyperlinks to third-party websites. ReMark is not responsible for the content or privacy practices of any third-party. We recommend that you carefully review and consider the terms of use and privacy policy of all third-party websites prior to use.

ReMark (Netherland Trade Registration Number: 34122876) is a private limited company established and existing under the laws of The Netherlands with its registered office at Jollemanhof 14a, 1019GW Amsterdam. Questions about this Policy can be submitted via security@remarkgroup.com.

Subject to applicable laws, you may also contact us, as described above, to inquire about your Personal Data held by us, withdraw consent to continued collection, processing, use or disclosure of your Personal Data where your consent has been obtained by ReMark as expressly required by law, to request access to or supplementation or correction of your Personal Data held by us, or to request a copy of your Personal Data and/or the most up-to-date version of this Policy.

ReMark may collect and process the following Personal Data:

• Name / Screen name
• E-mail address
• Date of Birth
• Gender
• Reward points
• Insurance policy information : policy status
• App data (including but not limited to avatar, steps, height, weight, biological age, body mass index, resting heart rate, hours of sleep, active calories burnt, stress and oxygen saturation (SPo2)) provided or uploaded by you either manually or generated by the App or through a third party wearable platforms such as (but not limited to) Garmin Connect or Apple HealthKit.
• Profile picture if you affirmatively choose to upload your picture in the App. Uploading a profile picture is not required for use of the App.
• Information about your performance, achievements and activity data (including time of the last activity) on the Friends section (including the Activity Dashboard, Friends Leaderboard and tasks, challenges and competitions) if you affirmatively choose to opt-in to these social features. Participation in the social features is not required in order to use the App.

Additionally, ReMark may also process certain data, such as your URL, your IP address and language preferences, and the date and time when you use the App.

ReMark collects your Personal Data when you provide your Personal Data to ReMark directly, when you use the App, and, if you choose to link your third-party wearable device such as Garmin Connect or Apple HealthKit to the App, when you use that third-party’s wearable platform. You understand that this Policy does not apply to the collection and processing of your Personal Data by any such third party’s wearable platform, which privacy policy may substantially differ from this Policy. We recommend that you carefully review and consider the terms of use and privacy policy of all third-party wearable platforms prior to use.

ReMark may collect and process your Personal Data for the following purposes:

• To establish your identity, set up your account and communicate with you concerning your account, including responding to any enquiries you may submit as well as sending emails to facilitate and verify your account creation.
• To provide the products and/or services to you, and information about those products and/or services. This includes fulfilling or meeting the reason for which the information is provided. For example, if you earn reward points under the App, we will use your Personal Data to provide reward points to you. We will also use your Personal Data for the purposes of calculating your biological age and helping you set and track your fitness goals. Where you use other optional features of the App such as “Heads Up”, we will also use your Personal Data for the purposes of providing you with such features.
• To allow you to participate in the social features such as the 3D “Gameworld”, Activity Dashboard, Friends Leaderboard, Coach and competitions, should you affirmatively elect to participate in such activities.
• To execute marketing and related activities and to the extent that certain marketing activities require your consent under the relevant laws, we will seek your consent.
• To send you (electronic) commercial messages (newsletters) with information about the products and/or services or request your feedback on use of the App through surveys and to the extent these require your consent under the relevant laws, we will seek your consent.
• To review, analyze, monitor, maintain, secure and optimize the App and associated technologies.
• To comply with relevant laws and regulations.
• For testing, research, analysis and product and service development.
• Other country-specific uses detailed in Exhibits A and B of this Policy
• As otherwise permitted by applicable laws

ReMark respects the privacy of all its App users and ensures that the confidential nature of the Personal Data you provide us will be maintained. ReMark may transfer your Personal Data to the following persons:

• ReMark’s parent company and affiliates (including but not limited to SCOR SE), for the purposes of providing the products and/or services to you.
• Google Cloud (ReMark’s cloud provider) shall process Personal Data, such as date of birth, policy information, gender, number of steps, active calorie count, resting heart rate, sleep hours (if available), weight and height.

These third parties may be located outside of the country in which you are located, including in the Netherlands.

In addition, your Personal Data may be shared with other App users if you opt-in to the Activity Dashboard, Friends Leaderboard, competitions and other social features, which are further described in Article 8 below.

ReMark will not make your Personal Data available to other persons, unless it is required to do so by virtue of mandatory rules, a binding decision from a government agency or an order to do so by a competent court.

In accordance with the applicable laws and regulations, ReMark has taken adequate technical and organizational measures to safeguard the security of your Personal Data. ReMark stores Personal Data on a secure database that is protected by technical access controls and periodically reviews the information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to our systems.

We cannot guarantee use of the App is 100% secure. We encourage you to use caution when using the Internet and the App.

Our App is not intended to be used by minors under 20 years old. You represent and warrant that you are at least 20 years of age. If you are under age 20, you may not use the App.

Reward points. In addition to the collection and use of Personal Data as described in Article 4 of this Policy, reward points or “bolts” may be available to you based upon the Activity Dashboard, Friends Leaderboard, competitions, referrals and other features offered under the App. Eligibility for App competitions, referrals and reward points will be communicated to you. Your Personal Data may be used by the persons listed in Article 5 for purposes of administering competitions and referrals and distributing resulting reward points that you may earn.

App Profile. If you do not wish to select an avatar that is available in the App, you may personalize your profile by including a picture of your choosing, provided that the picture does not infringe upon the rights of others. You may remove your picture at any time in the App settings.

Friends Section. You may elect to join the Friends section of the App, where you will be able to add others who are also using the Friends section, individually connect and share your profile and daily achievements with your Friends with a 3D “Gameworld”. You will also be able to see how you compare with your Friends on the Activity Dashboard and Leaderboard. The Activity Dashboard has a total of 4 rankings: (a) biological age; (b) steps; (c) active calories burnt; and (d) the combination of (a), (b) and (c). In the Activity Dashboard and the Leaderboard, your Friends can see your name/username, avatar/profile picture, biological age, steps, active calories burnt, rankings and the last time the App was synchronized. If you want to stop sharing this data with your Friends and stop participating in the Activity Dashboard and/or Friends Leaderboard, you can revoke your access at any time in the App settings.

Friends Competitions. You can also create and participate in competitions with others who are using the Friends section. The Friends competition has the same 4 rankings: (a) biological age; (b) steps; (c) active calories burnt; and (d) the combination of (a), (b) and (c). You may elect to participate in each competition by accepting the invite to that competition. If you do not wish to participate, you are able to decline the invite when prompted in the App. Once you participate, your name, avatar, biological age, steps, active calories burnt, respective rankings and the last time your App was synchronized will be visible to all participants in the competitions. If you want to stop participating in the Friends competitions, you can terminate participation at any time in the App settings.

Coach. Where you choose to participate in the “Coach” feature your personal data may be used to provide you with guidance and support to complete your tasks and challenges. If you want to stop participating in the Coach feature, you can terminate your participation at any time in the App settings.

Heads Up. Where you use other optional features of the App such as “Heads Up”, we will also use your Personal Data for the purposes of providing you with such features. If you want to stop participating in these features, you can terminate your participation at any time in the App settings.

ReMark keeps your Personal Data or other data that you provide to us, whether or not provided via the App, for as long as necessary for the purposes indicated above, or to comply with our legal obligations such as (statutory) retention periods. After expiry of such a retention period, ReMark will destroy all copies containing Personal Data or anonymize such data.

ReMark reviews this Privacy Policy on a regular basis and may change it at any time. Your continued use of the App will indicate that you have read and understood any updates of this Policy.