Privacy Policy

Respect for the privacy of Personal Information about you is very important to us. We use and share Personal Information that you provide only in ways that we tell you about, and we secure Personal Information that you provide to prevent it from being used and shared for other purposes.

This is the Privacy Policy of Tento Applied Sciences Limited, trading as Tento HealthTM. We are committed to collecting, maintaining, and securing Personal Information about you in accordance with this Privacy Policy, as well as applicable law.

In this Privacy Policy, “we”, “our”, or “us” refers to Tento HealthTM.   “User”, “you” or “your” refers to users of our websites, products, services, software, platforms, applications or programs (each of the foregoing referred to individually, and all of the foregoing referred to collectively, as the “Site”).

INTRODUCTION

We provide our Site to help individuals collect, process and control Personal Information (defined below) using the Site’s features and functionalities.  This Privacy Policy informs you about how information that relates to an identifiable natural person, including Users who are identifiable natural persons (“Personal Information”) and information that does not, directly or indirectly, identify any natural person (“Non-Personal Information”) is collected through the Site. In the context of this Privacy Policy, “process” means collect, store, transfer, use or otherwise perform any operation on Personal Information or Non-Personal Information.

We are committed to providing you with the means to protect the privacy and the confidentiality of Personal Information as described in this Privacy Policy.   Please be advised, however, that except as specifically noted in this Privacy Policy, we do not control your Personal Information or how it is processed; rather, we provide the Site as a mechanism by which you may control your own Personal Information or Personal Information of others which you are legally authorized to control. To the extent that you access or use our Site in any manner, this Privacy Policy will apply to you, so please read it carefully.  If you do not agree to any term within this Privacy Policy, please do not access or use our Site.

1      Collection of Personal Information and Non-Personal Information

How Personal Information is Collected in your Digital Health Wallet (“Tento Wallet”): You control whether Personal Information is collected from you.  For example, Personal Information is collected from you with your prior consent if you choose to upload it to your Tento Wallet (please see description of Tento Wallet below) and share it with our site using the QR code functionality or if you include Personal Information in a question or inquiry to us via the “Contact Us” page of our website.

Kinds of Personal Information that are Collected: Different kinds of Personal Information may be collected about you through your use of the Site. The kinds of Personal Information which may be collected through the usage of your Tento Wallet, are as follows:

  • Basic identifiers such as first name, last name, title, date of birth, contact information such as your email address and telephone number, and other identifiers that you may include within or upload to your own Site app profile (hereinafter, your Tento Wallet) or that you otherwise choose to make available through your use of the Site; Basic identifiers are kept in your Tento Wallet on a permanent basis and can be removed by uninstalling the application from your device. Any identifier shared by QR code is retained for a period no longer than ten (10) minutes, so as to be made available to the organisation that you selected to share your QR code with.
  • Additional Profile information that you may choose to include in your Tento Wallet, such as your preferences, feedback and survey responses; and
  • Sensitive Personal Information that you choose to include in your Tento Wallet, which may include information about race and ethnicity and health information, such as diagnostic test results and medical records.

 

How Non-Personal Information is Collected:

  • When using your Tento Wallet, Non-Personal information is only shared with our operations team when contacting us via the “Contact Us” page of your application.
  • When using or navigating the site, you control whether Non-Personal Information is collected from you. For example, when you use or navigate the Site, information about your browser type may be collected if you set your browser settings to enable collection of such information.

 

Kinds of Non-Personal Information that are Collected:

  • Technical data shared by your Tento Wallet, include: OS version, device model, device operating system, system version, Tento Wallet application version.
  • When using or navigating the site, technical data collected include: your internet protocol (IP) address, browser type and version, device type, time zone setting and location, browser plug-in types and versions, crash reports, operating system and platform and other technology on the devices you use to access the Site

2      Uses and Disclosures of Personal Information and Non-Personal Information; Purposes of Using and Disclosing Personal Information and Non-Personal Information

Uses and Disclosures of Personal Information; Purposes of Using and Disclosing Personal Information.  You control uses and disclosures of Personal Information on the Site as follows:

  • If you have a Tento Wallet, you decide how you wish to use Personal Information in the Tento Wallet utilizing its functions and capabilities. The purpose of your use of Personal Information in this way is so that you may utilize and take advantage of the Tento Wallet that we offer;
  • You decide how Personal Information is disclosed and to whom it is disclosed. For example, if you contact us with a question, you may choose to disclose certain Personal Information about yourself to us so that we can identify and respond to you.  You may disclose Personal Information in this way for the purpose of allowing us to communicate with you; and
  • If you have a Tento Wallet, you choose with whom you share your Personal Information. As an example, you may choose to share Personal Information in your Tento Wallet with your employer or with a business you choose.  You may share Personal Information in this way as part of utilizing and taking advantage of the Tento Wallet and its features.

In limited instances, we may use and disclose Personal Information as follows:

  • Through your Tento Wallet
    • If you contact us with a question or concern about the Site, we may use the Personal Information you chose to share with us for the purpose of communicating with you about your question or concern;
    • We may use Personal Information we’ve collected on the Site if we’re required to do so by applicable law or regulation or to comply with a legal obligation to which we are subject. We may also disclose such Personal Information to those authorized to receive it, as required by applicable law;
  • Through our site
    • We may use Personal Information you provide to us, such as your email address or other basic identifiers, to send you our newsletters, updates about us or our services or marketing materials if you have opted in to receive such communications from us; and
    • We may disclose Personal Information we’ve collected on the Site to third-party service providers that we engage. We disclose Personal Information to such third-party service providers so that they may assist us in providing, managing and operating our Site.

Uses of Non-Personal Information; Purposes of Using Non-Personal Information.

You also control uses of Non-Personal Information as follows:

  • You may set and adjust browser, operating system and device settings to allow or disable use of technical data such as location information and cookies. If you allow use of this information, it will serve the purpose of tracking certain interactions you’ve had with our Site (see “Cookies” section below for more details).

In limited instances, we may use and disclose Non-Personal Information as follows:

  • We may use Non-Personal Information, which may consist of technical data (as described above), for web analytics purposes. For example, we may use such technical data for analyzing our website traffic and other metrics for purposes of evaluating the performance of our website.
  • We may disclose Non-Personal Information, which may consist of technical data (as described above), to third-party service providers that we engage to assist us with the web analytics functions noted above.

3      Processing of Information with your consent

When you browse our website or contact us with questions, you provide your consent for us to process information that may include Personal Information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.  Your explicit consent is also obtained for the processing of Personal Information in connection with your use of a Tento Wallet.  If you use a Tento Wallet for processing of another individual’s Personal Information, you represent and warrant that you are legally authorized to consent on such individual’s behalf to the processing of that individual’s Personal Information and to engage in such Processing.

4      Revoking Your Consent

In situations where you have provided explicit consent for the processing of Personal Information, you may revoke your consent at any time by contacting us at dpo@tentohealth.com. However, please be aware that if you revoke your consent, you may not be able to use our website or our other Site features which depend on processing of Personal Information.

5      Data Minimization

Our Site, including the Tento Wallet, is designed to request access to and use Personal Information and Non-Personal Information only to the extent needed so that you can use the particular Site feature made available to you.  As explained in this Privacy Policy, you are in control of how much information you use and share on the Site, but we do not intend that the Site itself function so as to process more Personal Information or Non-Personal Information than is needed for the Site to operate properly.

6      Information Security

We use commercially reasonable administrative, technical, physical and organizational security measures to maintain the security and integrity of our Site and Personal Information and Non-Personal Information that is processed through the Site.  We implement measures to protect against loss, misuse, or improper access to information through generally accepted industry standard technologies and procedures.  For example, we use authentication, anonymization and encryption technology to protect Personal Information in a User’s Tento Wallet.  Please note that there are inherent risks in transmission of information over the Internet, and we cannot guarantee that unauthorized access or use of information will never occur.  Please also note that features of our Site, such as a Tento Wallet, are designed to be interoperable with and allow for secure exchange of information with various other systems, but we cannot guarantee such interoperability with all systems and make no representation or warranty that unauthorized access to or use of information will never occur in connection with such exchange of information.

7      Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely or until you delete them from your web browser.

Your web browser should allow you to delete any cookies you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

  • to track how you use our website;
  • to record whether you have seen specific messages we display on our website;
  • to keep you signed in to our website;
  • to record your answers to surveys and questionnaires on our site while you complete them; and
  • to record the conversation thread during a live chat with our support team.

8      Third-Party Content

Our Site may include links to third-party content, including without limitation, links to third-party websites.  We do not endorse or recommend such third-party content and we are not responsible for the privacy practices of the operators or publishers of such content.  Please be aware that when you access links to a third party’s content via our Site, you are bound by the privacy policies and practices of that third party. We urge you to be aware of and read the privacy policies governing your use of any third-party content.

9      Location of Information Processing

In instances where you process Personal Information from your local device, processing of this Personal Information occurs where you or your device are located. In other situations where you control the disclosure of your Personal Information, once you disclose such Personal Information to a recipient (such as a clinic or lab that you choose), it may be further processed by those recipients wherever they are located. In situations where we process Personal Information or Non-Personal Information, processing of such information may occur in the United Kingdom (UK) where our cloud-based servers are located or at the locations of our offices, offices of our affiliates or at processing locations of our third-party data management contractors.

Depending on how you use the Site, your use of the Site may involve transfer of your Personal Information across borders from the country in which you are located to other countries around the world.  To the extent we process your Personal Information, we may also transfer such Personal Information internationally.  Accordingly, with respect to an international data transfer, your Personal Information may be subject to different protections depending on the laws and regulations of the country to which your Personal Information is transferred.  In all cases in which we control your Personal Information, we will seek to apply reasonable safeguards for the protection of such Personal Information that is transferred internationally.

10  Third-Party Service Providers

As noted above in this Privacy Policy, in some situations we disclose Personal Information or Non-Personal Information to our third-party service providers so that they may use such information to assist us with various functions, such as web analytics or managing our Site.  Although we do not control these third-party service providers, we make commercially reasonable efforts to engage only with third parties that comply with applicable laws and implement information privacy and security measures to protect information that we share with them.

11  Access to your personal information

At any time, you may access Personal Information which you control on the Site.  For example, if you maintain Personal Information in your Tento Wallet, you may access such Personal Information in the Tento Wallet at any time.

In the limited cases in which we control and maintain your Personal Information, you may contact us to request access to such Personal Information at: dpo@tentohealth.com.  After receiving the request, we may take steps to verify your identity and once verified we will respond to your access request within a reasonable timeframe.

12  Deletion of your Personal Information

At any time, you may delete Personal Information which you control on the Site.  For example, if you maintain Personal Information in your Tento Wallet, you may delete such Personal Information in the Tento Wallet at any time.  Please be aware that certain parts of the Site, such as the Tento Wallet, may include functions that allow you to backup your Personal Information using your own operating system or device, and in case you have backed up your Personal Information in this way, the backup copy will remain even if you have deleted Personal Information on the Site.  In the limited cases in which we control and maintain your Personal Information, you may contact us to request deletion of such Personal Information at: dpo@tentohealth.com.   After receiving the request, we may take steps to verify your identity and once verified we will respond to your deletion request within a reasonable timeframe.  Please be aware that if we delete Personal Information, it may limit your ability to fully utilize the Site and related service we can provide to you.

13  Use of Site by children

Our Site is not directed to or intended to be used by anyone under the age of 16 and we do not knowingly collect or permit collection via our Site of Personal Information from anyone under 16.  If you become aware that Personal Information has been collected on our Site from anyone under the age of 16, we ask that you contact us (see our contact information at the end of this Privacy Policy) and we will seek to delete such Personal Information as soon as possible.

14  Retention of Personal Information

As noted in this Privacy Policy, in most circumstances you are in control of your Personal Information on the Site.  Accordingly, in such circumstances you have sole discretion in determining how long to retain your Personal Information.  In the limited cases where we control the processing of your Personal Information, we retain your Personal Information for as long as reasonably required for fulfilling the purposes of processing such Personal Information described in this Privacy Policy, in each case as permitted under applicable laws and regulations.  For example, if you have shared your Personal Information with us when submitting a question to us, we would retain such Personal Information for only as long as needed to respond to your question. Individuals in the EU and UK

In addition to all of the foregoing terms of this Privacy Policy, the following terms apply to individuals located in the European Union (EU) and United Kingdom (UK) in situations where we act as a “controller” (see paragraph below for further details):

In the limited cases, as described in this Privacy Policy, where we control processing of Personal Information on the Site, we are a “controller” (entity that determines the purposes and means of processing Personal Information) with regard to such Personal Information.

For individuals in the EU:  Ian Sherrington has been appointed as our representative in the EU for data protection matters, pursuant to Article 27 of the EU’s General Data Protection Regulation.  Ian Sherrington can be contacted in addition to or instead of us on matters related to the processing of Personal Information.  You may contact Ian Sherrington at the following address: Catharina van Rennesstraat 280, 2551 GV Den Haag, Netherlands.  You may also contact Ian Sherrington by phone at +31 621 861158 or by email at GDPR@tentohealth.com.

To the extent we collect your Personal Information on the Site and use, share and otherwise process it for the purposes described in this Privacy Policy, our processing has various legal bases, depending on the particular circumstances, which may include (a) our legitimate interests in operating our Site and providing you with Site functions, features and services; (b) for compliance with a legal obligation to which we are subject; (c) for performance of a contract to which you are subject or to take certain pre-contractual measures at your request; (d) your consent; (e) processing is necessary for the establishment, exercise or defense of legal claims; or (f) processing is necessary for reasons of public interest in the area of public health.

As a data subject, you have the right to request from us access to, rectification of, erasure of, portability of and/or restriction of processing of your Personal Information.  You also have the right to object to further processing of your Personal Information. To exercise any of these rights, please contact us at dpo@tentohealth.com.  We will respond to your request in accordance with applicable law.

In the event we process your Personal Information based on your consent, you may withdraw your consent at any time (provided, however, such withdrawal will not affect the lawfulness of processing of your Personal Information that occurred before our receipt of your withdrawal).  To withdraw consent for processing of your Personal Information, please contact us at dpo@tentohealth.com.

We may transfer Personal Information from the EU and/or UK to other countries and jurisdictions around the world.  Please be aware that the European Commission determined that only certain countries/jurisdictions provide an adequate legal framework for the protection of Personal Information.  For more information on the countries/jurisdictions that the European Commission has determined provide an adequate legal framework for protection of Personal Information, please visit:  https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en.  To the extent Personal Information is transferred from the EU or UK to countries/jurisdictions that have not been deemed by the European Commission to provide an adequate legal framework for the protection of Personal Information,  such Personal Information may be at greater risk once it is transferred to such countries/jurisdictions due to the absence of this adequacy determination by the European Commission.  Nonetheless, we commit to protect Personal Information under our control by applying reasonable safeguards to Personal Information transferred to such countries/jurisdictions.

Please note that you are not required to provide us with your Personal Information; provided, however, if you choose not to provide your Personal Information, this means that you will not be able to receive the Site features and services which depend on our processing of your Personal Information as described in this Privacy Policy.

If you have a concern with the handling of your Personal Information, you may lodge a complaint with the applicable data protection authority (also known as “Supervisory Authority”) in the country in which you reside.  For a list of Supervisory Authorities and their contact information, please visit: https://edpb.europa.eu/about-edpb/board/members_en.  If you are located in the UK, you may contact the Information Commissioner’s Office (ICO) (ICO website: https://ico.org.uk/).  If you have a concern, you may also contact us at dpo@tentohealth.com.

15  Changes to this privacy policy

We may update this Privacy Policy from time to time as we deem necessary or appropriate.  On each updated version of this Privacy Policy, we will indicate the effective date of such version of the Privacy Policy. The terms that apply to you are those which are currently effective when you use our Site. We advise you to print a copy of the currently effective Privacy Policy and each updated version of the Privacy Policy for your records.

16  Questions; Concerns

If you have any questions or concerns about this Privacy Policy or our privacy practices, please feel free to contact us at support@tentohealth.com and we will attempt to respond as soon as possible.

This policy was updated 10th April 2021.