Data protection and data management policy of WIWE
Objective of the Policy
The protection of your data is a priority for myWIWE Diagnostics Ltd. and its partners. The present guideline determines the data protection and data management applied by myWIWE Diagnostics Ltd.
The collection and processing of the data of personal character suitable for identification that are necessary in the course of using the WIWE website, webshop, the WIWE device and WIWE device are in compliance with the Hungarian data protection regulations inforce (Act CXII of 2011).
It is also the purpose of this Policy to ensure that right and fundamental freedoms, particularly the right to provate life are respected in all areas of the services provided by us, for all entities -regardless of their ethnicity or place of residence – in the course of the automated processing of their personal data (data protection).
Using the website, webshop, the WIWE device and the WIWE application you agree to the terms and conditions of this data protection policy, and grant permission to us to use your data as specified herein.
in compliance with Act CXII of 2011 on the right of informational self-determination and on freedom on information (hereinafter referred to as Privacy Act) the definition of the terms used in this policy are as follows:
Personal data: shall mean specific data relating to the any natural person (hereinafter referred to as data subject), in particular by reference to the name and identification number of the data subject or one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity as well as conclusions drawn from the data in regard to the data subject. The personal data shall be treated as personal as long as its relation to the data subject remains recoverable;
Data management:shall mean any operation or the totality of operations performed on the data, irrespective of the procedure applied; in particular, collecting, recording, registering, classifying, storing, modifying, using, querying, transferring, disclosing, synchronising or connecting, blocking, deleting and destructing the data, as well as preventing their further use;
Consent:shall mean any freely and expressly given specific and informed indication of the will of the data subject by which he signifies his agreement to personal data relating to him/her being processed fully or to the extent of specific operations.
Objection:shall mean a declaration made by the data subject objecting to the processing of their personal data and requesting the termination of data processing, as well as the deletion of the data processed;
Data controller: myWIWE Diagnostics Ltd. (registered seat: H-3300 Eger Faiskola út 5.);
Data processing: shall mean performing technical tasks in connection with data processing operations, irrespective of the method and means used for executing the operations, as well as the place of execution, provided that the technical task is performed on the data;
Data destruction: shall mean complete physical destruction of the data carrier recording the data;
Data transfer: shall mean ensuring access to data for a third party;
Disclosure: shall mean ensuring open access to the Personal data;
Data processor: shall mean any natural or legal person or organisation without legal personality processing the personal data on the grounds upon the assignment of the data controller;
Data deletion: shall mean making the data unrecognisable in a way that it can never again be restored;
Automatic processing: shall include the following operations when carried out party or entirely by automated devices: data storage, the logic and arithmetic operations carried out with the data, data modification, data deletion, retrieval and dissemination of data;
User: the natural person who uses the services on the website and in the webshop (www.mywiwe.com) of myWIWE Diagnostics Ltd.
Scope of managed data
Our services do not require registration of any kind, which allows you to visit our website, webshop and use the WIWE device and the related application without revealing your identity.
However, in case of making a purchase in the webshop providing some data (name, delivery address, etc.) are essential to smooth delivery. The personal data provided voluntarily allow the use of the webshop.
myWIWE Diagnostics Ltd. uses the personal data that are inevitably necessary based on the consent of the buyer, and exclusively for the purpose of the purchase.
myWIWE Diagnostics Ltd. undertakes to manage the personal data acquired by it in compliance with the provisions of the Privacy Act and the data protection principles specified in this policy, and not to transfer the personal data to any third party.
In terms of data transfer, exception to the provision of this article are the use of the data in a statistically consolidated form, as well as the consolidated data collected on the activity of users, which shall not include in any form the name of the user concerned, or any other data suitable to identify the user.
In using the webshop and the website
Data that may be provided upon the decision of user:
- surname, first name, tekephone number e-mail, password,
- the description of the product/products bought by user upon ordering,
- the company name, delivery and invoicing address provided by user,
- the delivery and payment method used by user ,
- the sum of the purchases of user..
Technical data recorded in the course of operating the system:
- those data of the user’s computer logging in that are generated in course of using the service and which are the system of myWIWE Diagnostics Ltd. records as the automatic result of technical processes.
Upon log-in and log-out the system automatically logs automatically recorded data without the specific statement or act of user. These data cannot be connected with other user data – except if made compulsory by law. The data can be accessed by Sanatmetal Kft. exclusively.
We do not use any other tracking cookies which would allow us to track whether you had visited other websites within our network.
You may read about allowing, blocking and deleting cookies in detail in the help function of your browser.
Google placed cookie on the website, which is part of the “Analytics” service offered by them. We use this service to track how visitors use our website. Google may provide the related information to third parties in order to comply with legislative obligations, or may provide it to third parties that process such data on behalf of Google. The information collected by Google are managed so that they cannot be identified by persons. Your IP address will not be provided! The information are transferred to the United States and are saved on hosts located in the United States. Google indicated that it complies with the Safe Harbour principles, as well as joined the Safe Harbour program of the Department of Commerce of the United States of America, and thus Google executes the data protection standard on the management of personal data that also complies with EU legislature.
For the sake of user experience and satisfaction we are constantly developing our products. We provide inform on new developments in newsletters. You may ask for our newsletter by an e-mail address provided in the course of the registration. WIWE rejects the practice of “spamming” and does not send unwanted e-mails.
The WIWE device and the WIWE telephone application
The optimal operation of the WIWE cardiac diagnostic device may be achieved through a mobile application. The mobile application can be downloaded from the the webshops.
The WIWE mobile application can be downloaded from the Apple store (AppStore) and the Google playwebshop. Although in the course of the download the user data used to identified the user are recorded, these are not accessible to the service provider and cannot be matched with the data stored on the WIWE device.
Users can select in-app purchases to access some additional features of the WIWE application.
HRV age, stress level measurement and HRV (heart rate variability) trend analysis
Auto renewable subscription
Free trial period: 30 days
Period (in months)
Monthly HRV trend subscription
3 months HRV trend subscription
Half year HRV trend subscription
Annual HRV trend subscription
Management of the data necessary for the use of WIWE
using the WIWE application does not require separate registration, however, the optimal use of certain functions may require your personal data. You may provide these data at your own discretion when using WIWE. Sanatmetal Kft. does not acquire, collect or store user data in the use of WIWE (device, application).
The personal data stored on the WIWE device or in the WIWE application are available only to the user, through the mobile phone of the user.
The user data of personal nature provided in the course of using the WIWE mobile application (gender, age, weight, height, diagnosed illnesses, lifestyle customs, etc.) are stored exclusively in the mobile phone of the user, and their sole purpose is self-checking, those are not stored and not managed in any way by the developer and operator of the application. The personal data may remain stored in the device or in the mobile phone until the self-checking purpose is fulfilled.
The WIWE data stored in the mobile phone by the user are subject to the same level of data protection as the other personal data of the user and the access authorization to the data is determined solely by the user.
The information derived from the WIWE device are stored solely on the WIWE device and mobile device, these are not available to Sanatmetal Kft. or any third party, however, consequently when the application is deleted, the personal data are also deleted.
The services available in the WIWE application may differ subject to the software version f the application. The services provided by the application may change without notice according to the software versions.
The information derived from the WIWE device may be transferred with the help of the application solely upon the intention of the authorized user and the user’s express consent. The purpose of the data sharing option is that health parameters could be shared with the physician of the user or any person the user considers worthy of sharing with.
The application does not send any data related to the user automatically. However, the user has the opportunity to send the data measured by his/her WIWE device through his/her smartphone with the help of the WIWE application to any e-mail address the user specified. The device arranges the ECG graph acquired through the measuring carried out by the WIWE device and the numerical evaluation related to the ECG, as well as the findings indicated by WIWE in a predetermined format. This document can be forwarded by one touch to the persons chosen by the user.
Duration of the Data Management
myWIWE Diagnostics Ltd. manages only those data that are essential to the sale, in the form and for the duration prescribed by law.
The user has the right to access and update his/her personal data provided during the registration, as well as to request the deletion of his/her personal data, and – except for ongoing order – may modify the data any time following log-in to the www.mywiwe.com homepage, in the menu item “Profile”, or via the e-mail address firstname.lastname@example.org.
In case of using unlawful, misrepresenting personal data or in case of criminal offense committed by the user, or in case of attack against the system myWIWE Diagnostics Ltd. is entitled to immediately delete the user’s data simultaneously with the termination of the user’s registration, however, in case of suspicion of the criminal offense or civil law liability myWIWE Diagnostics Ltd. is also entitled to keep such data or the duration of the procedure to be carried out.
The data automatically, technically recorded in the course of the operation of the system are stored in the system from the date they were generated until the duration justified by ensuring the operation of the system. myWIWE Diagnostics Ltd. ensures that these automatically recorded data cannot be matched with other user personal data – except in case made compulsory by law.
If the user withdraws its consent granted for the management of the user’s data or unsubscribes from the newsletter, then following such act the person of the user will not be identifiable based on the technical data.
The user may unsubscribe from sending newsletters by clicking on the link provided in the newsletters.
If myWIWE Diagnostics Ltd. fails to execute the user’s request for correction or deletion, myWIWE Diagnostics Ltd. shall notify the user within 30 days of receiving the request in writing on the material and legal reasons of rejecting the user’s request for correction or deletion, and of the fact that the user may turn to the court or the Hungarian National Authority for Data Protection and Freedom of Information against the decision of myWIWE Diagnostics Ltd.
The above provisions do not affect the performance of the obligations to keep the data prescribed by law (e.g. accounting laws).
The data subject, as well as anybody to whom personal data have been forwarded for the purpose of data management shall be notified of the correction, blocking, marking and deletion of the data of the subject. myWIWE Diagnostics Ltd. may omit the notification if – in consideration of the purpose of the data management - it does not violate the legitimate interest of the user.
Following the fulfilment of request for deletion or modification of personal data, the data former (deleted) data can no longer be restored.
The scope of entities accessing the data, data transfer, data processing
myWIWE Diagnostics Ltd. does not employ external data processor. The data managed by myWIWE Diagnostics Ltd. are processed by itself.
We treat your data confidentially and do not transfer those to third parties, except if its essential to the performance of the contract (eg. post, delivery service). Our co-workers, partners have confidentiality obligations to us.
The third parties essential to the performance of the contract may work with different data protection policies, however, myWIWE Diagnostics Ltd. stipulates in contract that that third parties shall ensure the same level of security as myWIWE Diagnostics Ltd. and shall process the data transferred expressly only according to those purposes approved by myWIWE Diagnostics Ltd.
We use those data that your send to our customer service only for solving the problem, and otherwise those are also subject to the data protection obligation.
Sanatmetal Kft. keeps your data only until it is strictly necessary for the purpose concerned, and until it complies with any applicable legal or ethical, report and document keeping obligation. The purpose of the data management is ensuring the webshop and newsletter services available on the website. myWIWE Diagnostics Ltd. stores the data provided by the client to myWIWE Diagnostics Ltd. with purpose limitation, exclusively in the interest of subsequently proving the order, on the sites of Sanatmetal Kft. In all cases where myWIWE Diagnostics Ltd. wishes to use the data for purpose other than the purpose of the original data provision, then myWIWE Diagnostics Ltd. shall notify the user thereof, obtain the user’s express consent, as well as shall ensure opportunity to user to prohibit the use.
myWIWE Diagnostics Ltd. is entitled and obliged to transfer all data available to and lawfully stored by myWIWE Diagnostics Ltd. to the competent authorities, to which data transfer myWIWE Diagnostics Ltd. is obliged by law or final administrative imposition. For such data transfer, and for the consequences arising therefrom myWIWE Diagnostics Ltd. cannot be made liable.
If the client provided a third person’s data in the course of the registration, or caused damage in any other way when using the website, then Sanatmetal Kft. shall be entitled to enforce compensation against the user. In such case myWIWE Diagnostics Ltd. provides all reasonable help to the proceeding authorities in order to establish the identity of the violating person.
If myWIWE Diagnostics Ltd. transfers the operation or use of the content services to be found on the site a www.mywiwe.com in whole or in part to any third person, then myWIWE Diagnostics Ltd. shall be entitled to transfer these personal data to this third party completely without requesting separate consent thereto. This data transfer shall serve the purpose of continuity of the registration of already registered users exclusively, however myWIWE Diagnostics Ltd. shall not cause the user to be subject to data management and data protection terms and conditions that are disadvantageous compared to those of the present policy.
In order to check the lawfulness of the data transfer and for the purpose of notifying the data subject myWIWE Diagnostics Ltd. maintains a data transfer register, which includes the date of transfer, the legal ground and addressee of the data transfer, specification of the transferred personal data as well as other data specified in the law regulating data management.
Security and confidentiality
myWIWE Diagnostics Ltd. assumes obligation to ensure the security of the data, and takes those technical measures that ensure that the recorded, stored and managed data are protected, as well as makes all efforts to prevent the destruction, unauthorized use and unauthorized modification of the data. For this purpose myWIWE Diagnostics Ltd. uses data networks the protection of which are ensured – among others – by standard firewall and password protection. exclusively those employees have access to the personal data who have the qualification necessary for such data management and observe the strict rules on confidentiality.
In addition, myWIWE Diagnostics Ltd. assumes obligation to request any third party myWIWE Diagnostics Ltd. may transfer or provide the data to fulfil their relevant obligations.
Modification of the Data Management Policy
myWIWE Diagnostics Ltd. reserves the right to change the present data management policy by its unilateral decision at any time. Following the modification of the data management policy the user shall be appropriately (via newsletter, pop-up window upon log-in) notified thereof. By continuing to use the service the users acknowledge the modified data management rules, their further approval is not required.
Client rights and remedies
The user may request information any time from myWIWE Diagnostics Ltd. regarding the personal data relevant to the client. Upon request of the client myWIWE Diagnostics Ltd. provides information on the data related to the client and managed by myWIWE Diagnostics Ltd., on the purpose, legal ground and duration of the data management, as well as who and for what purpose receive or had received the client’s data. myWIWE Diagnostics Ltd. considers any information request sent by e-mail authentic if such request was sent from the registered e-mail address of the user. Following the receipt of the relevant request, myWIWE Diagnostics Ltd. shall provide information with regards to the data management question as soon as possible – but no later than within 30 days – in writing. In case of e-mail the date of receipt shall be the first working day following the sending.
We attempt to settle all diputes arising against WIWE amicably, according to the governing complaint-handling principles. if the issues cannot be resolved amicably, then the Hungarian law shall be applied to resolving the dispute, both in terms of substantive and procedural law.
The data subject may exercise his/her rights through the following contacts:
Mailing address: myWIWE Diagnostics Ltd. Limited Liability Company, H-3300 Eger, Faiskola út 5.
The Client may turn any time to the colleagues of myWIWE Diagnostics Ltd. with any question or comment related to data management through the above contact details.
In case of any objection the client may seek legal remedy from or make a complaint to the following authority:
Name: Hungarian National Authority for Data Protection and Freedom of Information (Nemzeti Adatvédelmi és Információszabadság Hatóság)
Registered seat: H-1024 Budapest, Szilágyi Erzsébet fasor 22/C.
Postal address: 1530 Budapest, Pf.: 5.
In force: 21st September 2015