Mobile App - Privacy Policy

1. Introduction

Allurion Technologies, Inc (“us”, “we”, or “our”) operates the Allurion Scale mobile application (hereinafter referred to as the “App”). The protection and security of your personal data are important to us. Personal data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession) (“Personal Data”). This Privacy Policy tells you how we collect, use, share and protect your Personal Data which is collected through the App.

The App has been developed and is operated by Allurion Technologies, Inc based at 11 Huron Drive, Natick, MA 01760 USA. Allurion Technologies, Inc is the controller of your Personal Data via the App.

 

2.Personal Data Collection and Use

 

We will process your Personal Data when you submit it in the following ways:

• App Account Registration and Profile Details: when you create an App account, the following information will be stored: your name , gender, date of birth, your language preference, phone number, email address, password, authentication details and other registration information including your password for the App account. The App allows you to monitor your weight, body fat %, body water %, bone mass, muscle mass, body mass index, basal metabolic rate and visceral fat by connecting with your Bluetooth Allurion Scale. By connecting with your Bluetooth Allurion Scale, the App will collect and store this Personal Data.
• Customer Services: if you contact us about the App or for any other reason relating to customer services, we will keep a record of that contact. You may provide us with Personal Data when sending us your request. We will hold your email address in order to consider your request and to respond to you.
• Usage Data: when you access the App with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data (“Usage Data”).

 

3. The Reasons for Using Your Personal Data

 

We process your Personal data to enable us to (i) perform the contract we are about to enter into, (ii) to comply with your legal obligations, (iii) as necessary for our legitimate business interests, (iv) as necessary for reasons of public interest in the area of public health and (v) with your permission, including:

• To provide and maintain the service which is provided through the App;
• To notify you about changes to the App;
• To allow you to participate in interactive features of the App, including sharing your App data with your family, friends and health care providers when you have chosen to do so;
• To provide customer support when it is requested by you;
• To gather analysis and/or valuable information so that we can continue to develop, test and improve the App to offer new functionality and features;
• To better understand how you interact with the App, including its functionality and features, as well as ensure the content is presented in the most effective manner;
• If you qualify for discounts on further purchases of our products, we will process your Personal Data to issue you with vouchers and/or discount codes;
• To help us fix any issue with the App, including where we respond to your questions or respond to your request for support, maintenance, troubleshooting, or other performance issues;
• To conduct data analysis, testing and research, including for statistical purposes;
• To develop and implement security tools and mechanisms as part of our efforts to keep the App safe and secure;
• To detect, prevent and address technical issues.

 

4. Retention of Personal Data

We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. In some cases, when you give us Personal Data for a feature of the App, we delete the Personal Data after it is no longer needed for the feature.

We keep other information, like the Personal data we obtain when you connect with your Bluetooth Allurion Scale, until you use your account settings or tools to delete the data or your account because we use this data to provide you with your personal statistics and other aspects of the App. We also keep information about you and your use of the App for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the “Reasons for Using Your Personal Data” and “How we Share your Personal Data” sections. To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

5. Storage of your Personal Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Allurion Technologies, Inc will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

For individuals based in the European Economic Area (“EEA”): If you are based in the EEA please be aware that when you use the App, your Personal Data will be transferred and stored by our Service Providers (as defined below) in locations outside the EEA, such as to the United States and India. Where we transfer your Personal Data outside of the EEA we will take steps to ensure that your Personal Data receives an adequate level of protection where it is processed and your rights continue to be protected (such as, where required to do so, by implementing the European Commission approved standard contractual clauses or ensuring our Service Providers are certified to the EU-U.S. Privacy Shield Framework). If you require more information please contact us using the details in the “Contact Us” section below.

 

6. How we Share your Personal Data

Business Transaction

If Allurion Technologies, Inc is involved in a merger, acquisition or asset sale, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your Personal Data may be transferred including as part of any due diligence process. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Allurion Technologies, Inc may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Disclosure for Service Providers

We may employ third party companies and individuals to facilitate the App (“Service Providers”), provide the services through the App on our behalf, perform App-related services or assist us in analyzing how the App is used.

These Service Providers have access to your Personal Data only to perform these tasks on our behalf and are obligated to keep such Personal Data confidential, not to disclose or use it for any other purpose.

Legal Requirements

Allurion Technologies, Inc may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation;
• To protect and defend the rights or property of Allurion Technologies, Inc;
• To prevent or investigate possible wrongdoing in connection with the Service;
• To protect the personal safety of users of the Service or the public; or
• To protect against legal liability.

 

7. Security of Personal Data

We have implemented appropriate administrative, technical and physical safeguards to protect the confidentiality, integrity and availability of your Personal Data. We will use strict procedures and security features and take all steps reasonably necessary to ensure your Personal Data is processed securely and in accordance with this Privacy Policy.

You are responsible for protecting against unauthorized access to the App. You should use strong password security, by using a mix of letters, numbers and symbols and a different password than you use for any other accounts that you may have. You must keep your account password confidential and not share it with anyone.

We are not responsible for any lost, stolen or compromised passwords or for any access to your account from unauthorized users where caused by you. If you think your account has been compromised, please contact us as soon as possible, using the contact details in the “Contact Us” section below.

 

8. Exercising Your Rights

If you need to update your Personal Data you can do this through the App. If you are unable to access that information for any reason, you can notify us of any changes to (or errors in) your Personal Data.

For individuals based in the EEA: If you are based in the EEA, you may have the right to: (a) access the Personal Data we hold about you; (b) request we correct any inaccurate Personal Data we hold about you; (c) request we delete any Personal Data we hold about you; (d) restrict the processing of Personal Data we hold about you; (e) object to the processing of Personal Data we hold about you; and/or (f) receive any Personal Data we hold about you in a structured and commonly used machine readable format or have such Personal Data transmitted to another company.

Please note that we may ask you to verify your identity before responding to such requests.

Where you have been asked to consent to the processing of your Personal Data, you can withdraw consent, such as by contacting us using our contacts details below. Any withdrawal of consent will not affect the lawfulness of the processing based on your consent before the withdrawal. Please also note that where you withdraw consent, we will only stop processing your Personal Data that relates to the withdrawal of consent.

To exercise any of your rights in connection with your Personal Data, please contact us using the contact information in the “Contact Us” section below. If you are located in the EEA, you have the right to complain to a Data Protection Authority in your country about our collection and use of your Personal Data.

 

9. Links to Other Sites

The App may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

10. Children’s Privacy

 

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect Personal Data from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

 

11. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

12. Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By email: app@allurion.com