T-SHAPED APPS LTD (hereinafter, “Welmi” or the “Provider”), with registered office in Griva Digeni, 51, ATHINEON COURT, Flat/Office 202, 8047 Paphos, Cyprus, operates the website www.welmi.ai (hereinafter, the “Website”) as well as the Welmi app, a digital calorie and health tracker (hereinafter, the “App” or the “Product”) for Android and iOS.
The following Data Protection Policy informs you about the types of personal data of Welmi users that are processed, the purposes for which they are processed, and the scope of processing. The Data Protection Policy applies to all processing of personal data performed by Welmi, both in connection with service provision and, in particular, on the Website and in the Welmi App, which users can install on their mobile end device, as well as within external online presences, such as Welmi’s social media profiles (hereinafter, collectively referred to as the “Online Offer”).
The controller within the meaning of the General Data Protection Regulation (GDPR)—i.e., the entity responsible for collecting, processing and using personal user data—is
T-SHAPED APPS LTD
Griva Digeni, 51
ATHINEON COURT,
Flat/Office 202
8047, Paphos, Cyprus
support@welmi.ai
All incoming and outgoing data—both in the communication with the Apps and in third-party provider communication—are transmitted in encrypted form. The encrypted connection when using the Welmi Website can be seen, for instance, via the address bar of the browser being used, which begins with “https://”, and via the encryption symbol found there. Because of encryption, the transmitted data cannot be read by third parties.
“Personal data” for the purposes of the GDPR means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;Personal data (e.g., e-mail address, nutritional data in the App) will be processed by the Provider only pursuant to the provisions of applicable data protection law. The following provisions inform you about the nature, scope and purpose of the collection, processing and use of personal data.
When visiting the Website www.welmi.ai, the web server, on the basis of Welmi’s legitimate interests under Article 6(1)(f) GDPR, automatically records log files, which cannot be attributed to any specific person, if this is necessary for the App’s functionality and is not outweighed by the interest in protecting the user's personal data. These data include, e.g., the browser type and version, the operating system used, referrer URL (the previously visited site), IP address of the requesting computer, access date and time of server request, and the file requested by the client (file name and URL). These data are collected only for the purpose of statistical analysis and for security reasons (e.g., to investigate acts of misuse or fraud) and are stored for seven days and then erased. If it should be necessary to retain the data for a longer period of time for evidentiary purposes, they are exempt from erasure until final resolution of the respective event.
3.2.1. Use of cookies
In order to make the Website more user friendly and more effective overall, Welmi itself or third parties engaged by Welmi for this purpose store cookies on the user’s hard drive, provided the user has consented to this in accordance with Article 6(1)(a) GDPR.A cookie is a small text file that is used, inter alia, to record information with respect to use of a website. These cookies cannot execute programs or transmit viruses to the user’s computer. They do not contain any personal data, cannot be attributed to specific persons, and, unless described otherwise, will be automatically deleted after one year, at the latest. These data are not combined with other data sources.It is also possible to use websites operated by the Provider without cookies. The storage of cookies can be deactivated or limited to certain websites in the respective browser, or the browser can be configured in such a way that it notifies the user once a cookie is sent. The user can also delete cookies from the hard drive of their PC at any time
3.3.1. Required information when creating a personalized user account
In order to be able to use the App, the user must provide the required information “e-mail address” and “password”. These are used to identify the user and for the purpose of communication between the Provider and the user. The e-mail address and all other user data cannot be viewed by other users. A different situation applies only if the user is using the “Buddies” feature (see 3.3.8). The data are stored on the basis of the consent of each user under Article 6(1)(a) GDPR.
3.3.2. Use of the WELMI app with the feature "Sign Up With Apple" / "Continue With Apple"
The user has the option to create a WELMI account via his or her Apple account. The user can register for or log in to WELMI with this Apple account ifhe or she uses the "Sign Up With Apple" button on the website or the "Continue With Apple" button in the app when registering. When logging in usingthe Apple ID, the personal e-mail address can be hidden or shared with WELMI. With “Hide e-mail address”, the user can use Apple's e-mail relayservice to generate a generic alias address through which messages from WELMI are forwarded to their private e-mail address. “Continue with Apple''uses two-factor authentication. An additional password does not have to be assigned. Further information about the method of operation andsettings is available at: https://support.apple.com/HT210425
The watchOS app for the Apple Watch can additionally be downloaded and used through the Apple Watch itself, unless it is automatically coupled withthe user's iPhone. In this case, registration must take place using the feature “Continue With Apple”.
3.3.3. Use of the WELMI app with the feature "Sign Up With Google" / "Continue With Google"
The user has the option to create a WELMI account via his or her Google account. The user can register for or log in to WELMI with this Google accountif he or she uses the "Sign Up With Google" button on the website or the "Continue With Google" button in the app when registering. In this regard,WELMI collects and stores the user's personal data through the Google account, such as the user's e-mail address, optionally also first and last names,and the user's profile picture. The user can individually adjust the data transfer to WELMI in their Google account under privacy settings. Furtherinformation about the method of operation and settings is available at: https://support.google.com/accounts/answer/2541991
3.3.4. Use of the WELMI App without personalized user account
An existing anonymous user account can be converted into a personalized account at any time by adding an e-mail address and password.
It is not possible to attribute an anonymous account to a user, meaning that if the mobile end device is lost, it is not possible for WELMI to restore theaccount.
3.3.5. Data provided by the user
When creating a personalized user account, the user can optionally provide, in addition to the required information (e-mail address and password),first name, last name and place of residence, which are then recorded by WELMI.
In addition, WELMI records data that are provided by the user through a personalized or anonymous user account, which can be entered when usingthe App. This comprises a user profile, which includes, but is not limited to, the below-listed body and health data:
— Age/date of birth
— Gender
— Height
— Diet (e.g., vegan)
— Goal (e.g., lose weight)
— Activity level (high/low)
— Recorded activities
— Calories consumption and activity calories
— Steps
— Starting weight, weight progress and target weight
— Blood pressure
— Status of the App user (PRO subscription in place: yes/no)Fasting details (e.g., hours fasted)
— Water consumption
— Favorite recipes
The data are collected on the basis of the user’s consent under Article 6(1)(a) GDPR. The provision of body data is necessary in order to be able to usethe App's features. In particular, it is necessary to provide starting weight/target weight, gender, date of birth and height so WELMI can calculate theuser's personal calorie goal.
Other data, such as water consumption, enable the user to track the amount of water they drink. These data are used solely for the stated purposesand, as a rule, cannot be seen by third parties. A different situation applies only if the user is using the “Buddies” feature (see 3.3.8.).
3.3.6. Data automatically recorded by Welmi
When the App is installed, the following are recorded one time:
Date of installation
Date of registration
Operating system of the device used (Android/iOS)
Country and language (using locale: the “locale” is a set of settings that contains the region parameters (local parameters) for computer programs. These primarily include the language of the user interface, the country and settings for the character set, keyboard layout, andformats for payments, currencies, dates and times.)
These data are recorded in order to improve and personalize our services, and this takes place on the basis of our legitimate interest pursuant toArticle 6(1)(f) GDPR.
3.3.7. Data recorded while using the App
When the App is being used, WELMI furthermore records the following:
Current IP address
App version being used
Current time zone
These data are recorded in order to improve and personalize the offered services, and this takes place on the basis of WELMI’s legitimate interestpursuant to Article 6(1)(f) GDPR.
3.3.8. Contractual relationship and payment procedure
Where a contractual relationship between the user and WELMI is to be established, substantively structured or changed, WELMI stores personal data ofthe user on the basis of Article 6(1)(b) GDPR (see the list of personal data under No. 3.3.5 to 3.3.7), provided this is necessary for the performance ofthe contract. Through an in-app purchase, the user has the ability to acquire a PRO version of the WELMI App in connection with a subscription,optionally at the start of a seven-day free trial phase (trial subscription). If the user decides to acquire the PRO version and presses the order button,they will be forwarded directly to the Apple App Store, the Google Play Store, depending on their operating system, even ifthey had first opted for the seven-day free trial phase during the temporary subscription. In that case, the corresponding amount for the subscription will be automatically debited after the seventh day of the trial phase.
When the user is forwarded to the appropriate app store, WELMI transmits the starting and ending date and, if applicable, the subscription terminationdate, as well as the reason for termination (e.g., after a possible cancellation). The payment processing data are collected directly by the app stores.The data protection policies of the app stores can be viewed here:
Apple App Store: https://www.apple.com/privacy/
Google Play Store: https://policies.google.com/privacy
The PRO version of the App can also be purchased through the WELMI Website. Depending on the selected payment option (Apple Pay, Google Pay,SEPA payment or credit card payment), the user must provide the relevant account data, even if they are first using the seven-day trial subscription.
Applicable to the payment transactions are the business terms and conditions and the data protection policies of the respective payment serviceproviders, which are available on the respective websites or transaction apps:
Further processing is handled by the payment service provider Stripe. The service is offered by Stripe Payments Europe Ltd, Block 4, HarcourtCentre, Harcourt Road, Dublin 2, Ireland. Information provided by the user (name, e-mail address, credit card data, start and end date, and, ifapplicable, termination data of subscriptions, invoice amount) is transmitted by WELMI to Stripe pursuant to Article 6(1)(b) GDPR as part of theorder process. User data are shared solely for the purpose of payment processing with the payment service provider Stripe Payments EuropeLtd. and only to the extent they are necessary for this.Further information about data protection by Stripe is available at https://stripe.com/legal .
Moreover, WELMI makes the mobile payment system Apple Pay of Apple Inc., One Infinite Loop, 95014 Cupertino, USA, available to users in theWELMI App. When Apple Pay is used, Apple does not store any original credit card, debit card or prepaid card numbers used by the user. Applehas no access to them. In addition, no backup of transaction data takes place that permits conclusions to be drawn as to the user.Further data protection notices can be found at https://www.apple.com/privacy/.
In addition, the mobile payment system Google Pay of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, is also available tousers. Google stores information about the transaction made by the user and the payment method selected (debit or credit card). It collectsdata such as date, time, merchant location, merchant name and merchandise description. Google may combine these data with the informationof other Google services that the user uses with their Google account.Further information is available at https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice.
WELMI takes the protection of personal user data very seriously. For this reason, WELMI treats personal data confidentially and in accordance withstatutory provisions concerning data protection as well as this Data Protection Policy. WELMI therefore collects and stores only data that are providedby third-party providers on the basis of the respective user consent under Article 6(1)(a) GDPR and transmits corresponding data to them. Subject tostatutory or contractual permissions, WELMI processes the data in a third country or has the data processed there only where the specialrequirements of Articles 44 et seqq. GDPR are met. Processing takes place, e.g., on the basis of special safeguards, such as the observance ofofficially recognized, special contractual obligations (“standard contract clauses”).
For data transfers to the USA, WELMI primarily relies on the EU-U.S. Trans-Atlantic Data Privacy Framework (DPF), which has been recognised as asecure legal framework by an adequacy decision of the European Commission. Standard contractual clauses may also exist. Further information onthe DPF and a list of certified companies can be found (in English) at https://www.dataprivacyframework.gov/.
If the European Commission does not attribute to a third country the same level of data protection as the EU, then WELMI ensures the maintenance ofthe European level of data protection through the use of standard contract clauses (SCC) and binding company rules pursuant to Article 46(1) and (2)(c) GDPR. Nevertheless, it is possible under certain circumstances that authorities in a third country may access user data for control and monitoringpurposes and, in this regard, that effective legal remedies and data subject rights may not be enforceable.
The following providers and data are affected:
4.1. Google Fit
WELMI offers its users the option to link the App with Google Fit, a health platform of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4,Ireland (“Google”). Google Fit logs the physical activities of the respective user using sensors of the mobile device or activity sensors. The followingdata may be transmitted in the case of a linking with WELMI:
Total activity
Workouts completed (time, duration, type, calories burned)
Steps (distance, number)
Further data protection notices, particularly about the purpose and scope of data collection and the further processing and use of data by Google Fitas well as the rights in this respect and the settings options concerning data protection, are available at https://policies.google.com/privacy.
The use of information that WELMI obtains from Google APIs and the sharing of it with other apps takes place pursuant to Google API Services-User Data Policy, including the requirements for limited use.
4.2 Google Health Connect
WELMI offers its users the option to link the app with Google Health Connect, an integrated health data platform provided by Google Ireland Limited,Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Health Connect facilitates the consolidation of health and wellness data acrossmultiple applications.
When users link WELMI with Health Connect, the following categories of data may be accessed or shared:
Activity Data
Body Measurements
Heart & Vital Signs
DataNutrition
GeneralHealth Data
This integration allows users to enhance their experience within the WELMI app by providing more comprehensive health insights and personalizedrecommendations based on aggregated data.
WELMI adheres to the Health Connect Permissions Policy, including Limited Use requirements, ensuring that any data obtained is solely utilized forthe enhancement of user features within the app. Users maintain full control over their data and can modify their permissions or unlink HealthConnect at any time through the WELMI app settings, being informed of any potential impacts on app functionality.
Further data protection notices, particularly concerning the purpose and scope of data collection and the further processing and use of data by Google Health Connect, as well as the rights in this respect and the available settings options concerning data protection, can be found at https://policies.google.com/privacy.
4.3. Apple Health
Users also have the option to link their App with Apple Health, a mobile app of the technology group Apple Inc., One Infinite Loop, 95014 Cupertino, USA. The below-listed data may be transmitted to WELMI in the course of this:
Total activitySteps (distance, number)
Workouts (time, duration, type, calories burned)
Weight, waist measurement
Systolic blood pressure, diastolic blood pressure, blood glucose level
Body mass index
Menstruation cycle
In addition, the below-listed data may be transmitted by WELMI to Apple:
Total activity
Physical values (weight, waist measurement, blood sugar, systolic and diastolic blood pressure, blood glucose level, body mass index)
Nutritional energy, macronutrients, micronutrients, vitamins
WELMI has the ability to directly access the data pool of Apple Health at any time if the user has consented to this. Apple Health collects health-relevant user data and displays them as processed in the App. Further data protection notices can be found at https://www.apple.com/privacy/.
4.4. Samsung Health
Furthermore, health, diet and fitness data of users of Samsung Health, a platform of Samsung Electronics, Ltd, 129, Samsung-ro, Yeongtong-gu, Suwon-si, Gyeonggi-do 16677, Republic of Korea, and Samsung Medison, Pangyogeok-ro, 145, Bundang-gu, Republic of Korea, can be transmitted to WELMI if the user uses the connect option in the WELMI App:
Total activity
Workouts completed
Steps (distance, number)
Weight
Samsung Health manages the mentioned user data in order to support its users on the path to greater fitness and well-being. WELMI has the ability to directly access the data pool of Samsung at any time. Further information is available at https://privacy.samsung.com/privacy/samsung.
4.5. Huawei Health
Health and fitness data of users can be transmitted by Huawei Health, an official app of Huawei, G1, HUAWEI Industrial Base, Bantian, Longgang District, Shenzhen 518129 P.R. China, to WELMI if the user uses the connect option in the WELMI App:
Total activity
Workouts completed
Steps (distance, number)
Weight
WELMI Health monitors the health and physical activities of users. WELMI has the ability to directly access the data pool of Huawei at any time. Further data protection notices are available at: https://consumer.huawei.com/minisite/cloudservice/health/privacy-statement.htm?code=HK&language=en_us.
Welmi uses the customer service platform “Zendesk” of Zendesk Inc., 989 Market Street #300, San Francisco, CA 94192, USA, to process userenquiries made through the Website. The Website provides a contact form in which users manually enter their data (name, e-mail address, iOS orAndroid version, possible PRO status, description of the problem). Based on this information, the Welmi Support Team knows the user data that arestored in the user's App.
These personal data that the user provides to Welmi in connection with this contact request are needed only for responding to the user's enquiry orto make contact and are used for the technical administration associated with this. The data are not shared.
If the user has consented to the storage of their data, they have the right to withdraw the granted consent with prospective effect. In such cases,their personal data will be erased without delay. The user's personal data will be erased even without their withdrawal if Welmi has processed theirrequest or the user has withdrawn the consent to storage granted here. This also takes place where storage is impermissible for other statutoryreasons.
Zendesk is utilized based on the user’s consent under Article 6(1)(a) GDPR and a processing contract pursuant to Article 28(3) GDPR.
The Zendesk data protection provisions can be viewed here: https://www.zendesk.com/company/privacy
WELMI regularly notifies its users by e-mail about current diet trends, recipes and other interesting offers and tips from the field of nutrition, weight loss, etc. Registration is voluntary and takes place using a double opt-in procedure. After registering, the user receives an e-mail requesting that they confirm their registration. This is necessary so that a third party cannot register to receive the newsletter using someone else's e-mail address. In order to document that the registration meets the legal requirements, it is logged on the basis of WELMI's legitimate interest pursuant to Article 6(1)(f) GDPR.
As part of registration on the Website or in the App, the user consents to the processing of the provided data for the purpose of sending and receiving e-mails (Article 6(1)(a) GDPR). Furthermore, the user consents that WELMI may collect and process data about their usage behavior (namely, opening the e-mail and clicking on links in it) so that the content of the mailings can be tailored to the respective needs, e.g., if a user repeatedly clicks on links about topic A but not about topic B, they will receive only links about topic A in future mailings.
The consent granted by the user to receive these emails may be withdrawn at any time and without providing reasons with prospective effect by sending an e-mail to support@welmi.ai.
In addition, receipt can be stopped by using a link found at the end of each newsletter. Welmi may store the provided e-mail address and the data stored in connection with logging the registration for up to three years on the basis of its legitimate interest in order to be able to demonstrate that consent had previously been given. The processing of these data is limited to the purpose of possible defense against claims. An individual erasure request is possible at any time, provided that the former existence of consent is confirmed at the same time.
WELMI is aware of the importance of additional measures to protect the privacy of children. Persons under the age of 16 may not open an account unless a parent has consented in accordance with applicable law. Should WELMI learn that personal data about a child under the minimum age were collected without parental consent, WELMI will initiate steps to erase these data without delay. Parents who believe that their child has sent us personal data and would like to have these erased should contact WELMI using the contact data provided in No. 1.
Based on the user's consent within the meaning of Article 6(1)(a) GDPR, WELMI utilizes various tools and plug-ins for the purpose of web analysis,remarketing and retargeting. In doing so, cookies are used that forward the IP address and/or record and analyze different types of data. Thisincludes, for example, the number of Website visitors, visit duration, average page-loading time and visitor origin. These cookies are used for thepurpose of being able to put together more targeted offers for WELMI users.
Specifically:
8.1. Google Tag Manager/Google Analytics/Google Optimize/Google Analytics by Firebase
WELMI utilizes Google Tag Manager on its Website. The provider is Google Ireland Ltd. (“Google”), Google Building Gordon House, Barrow Street, Dublin4, Ireland. Google Tag Manager is a tool used to embed tracking or statistics tools and other technologies on the Website. Google Tag Manager doesnot itself create any user profiles, store any cookies, or perform any independent analyses. It is merely used to manage and run the tools embeddedthrough it. For this purpose, however, Google Tag Manager records certain aggregated data for the purpose of diagnosing how the tracking andstatistics tools are running. These data do not contain any IP addresses or IDs that can be linked to a specific person.
WELMI uses Google Analytics and Google Optimize on the Website and in the App for the purpose of analyzing use of the Website. The provider of bothweb analysis services is Google Ireland Ltd. (“Google”), Google Building Gordon House, Barrow Street, Dublin 4, Ireland.
Google Optimize is a tool integrated in Google Analytics. It enables the Provider to adjust and improve parts of its Website in a targeted manner tomatch user behavior.
Firebase provides app developers with a technical infrastructure and a variety of tools, including Google Analytics by Firebase. With it, WELMI canrecord and analyze user behavior in order to adjust the App to meet the needs of users and to better control features and events. Google Analyticsand Google Optimize use cookies, which facilitate an analysis of the use of the Website by users. The information generated by the cookie about useractivities on this Website is normally transferred to a Google server in the U.S. and stored there. On behalf of WELMI, Google uses this information inorder to evaluate user activities on the Website, to compile reports about Website activities for WELMI, and to provide additional services associatedwith Website use and internet use. In addition, Google will, if necessary, transmit this information to third parties if this is required by law or if thirdparties process these data on behalf of Google.
Further information about Google's use of data for marketing purposes can be found at https://www.google.com/policies/technologies/ads. If the user wishes to object to interest-related advertising by Google marketing services, they can use the settings and opt-out options provided by Google at http://www.google.com/ads/preferences.Google's data protection policy is available at https://www.google.com/policies/privacy.
8.2. Google Ads Remarketing/conversion tracking
On the Website and in the App, the Provider uses Google Ads Remarketing, an online advertising program of Google Ireland Ltd. (“Google”), GoogleBuilding Gordon House, Barrow Street, Dublin 4, Ireland. In connection with Google Ads Remarketing, WELMI uses what is known as conversiontracking. If the user clicks on an advertisement placed by Google, a cookie is set for the conversion tracking. These cookies lose their validity after 30days and are not used to personally identify users. If the user visits certain pages on this Website and the cookie has not yet expired, Google and theProvider can recognize that the user clicked on the advertisement and was redirected to this site.
Each Google Ads Remarketing customer receives a different cookie. The cookies cannot be tracked across the websites of Ads Remarketingcustomers. The information obtained with the aid of conversion cookies is used to compile conversion statistics for Ads Remarketing customers thathave elected to use conversion tracking. Customers learn about the total number of users who clicked on their advertisements and were redirectedto a site furnished with a conversion tracking tag. However, they do not receive any information that can be used to identify the user. If a user wishesto decline to take part in tracking, they can object to such use by deactivating the Google conversion tracking cookie through their internet browserunder user settings. In addition, the user can prevent the capture and processing by Google of the data generated by the cookie relating to their useof the Website (including their IP address) by downloading and installing the browser plug-in available at the following link:tools.google.com/dlpage/gaoptout. The user will then no longer be included in conversion tracking statistics. However, this will likely limit thefunctionality of this Website.
The information generated by the cookie about the user's use of this Website is transferred to a Google server in the U.S. and stored there. In theevent of activation of IP anonymization on this Website, however, the user’s IP address is first truncated by Google within the Member States of theEuropean Union or in other Contracting States of the Agreement on the European Economic Area. Only in exceptional cases is the full IP addresstransferred to a Google server in the U.S. and truncated there. Google uses this information on behalf of the operator of this Website in order toevaluate the user's activity on the Website, to compile reports about Website activities, and to provide other services to the Website operatorassociated with Website use and internet use.
More information about Google Ads Remarketing and conversion tracking can be found in the data protection provisions at https://safety.google/privacy/ads-and-data/.
8.3. Apple Search Ads
WELMI utilizes Apple Search Ads in the App. Apple Search Ads is an online advertising program of the technology group Apple, One Infinite Loop,95014 Cupertino, USA. Through Apple Search Ads, the Provider's App will be displayed to the user as the top result when the user searches in the AppStore.
The user can view and limit their personal data that Apple uses in order to display relevant advertising to them. In addition, the user can preventlocation-specific information from being used to find out which advertisements they can see. Further data protection notices are available at https://searchads.apple.com/privacy.
WELMI stores the user's personal data for the period of use of the App. If the user account is deleted, the e-mail address, first name, last name, profilepicture and links to third-party providers will be definitively and irretrievably deleted.
The user has the ability to reset their account. In this regard, a new account will be transparently set up and settings will be copied (e-mail address,password, settings, goals, etc.). The e-mail address, first name, last name and—if applicable—Fitbit ID, Polar ID, Stripe ID and AppsFlyer ID previouslyassociated with the original account will be deleted in it.
The user has the following rights, which, with the exception of No. 14.9, can be asserted with the controller or the data protection officer. The contact data can be found in No. 1.
13.1. Right of access (Article 15 GDPR)
The user has the right at any time to obtain free information about their personal data stored by WELMI, the origin and recipients of the data, the purpose of data processing and the planned duration of data storage, including a copy of the personal data that are the subject of the processing.
13.2. Right to rectification (Article 16 GDPR)
In addition, the user has the right at any time to have inaccurate or incomplete personal data rectified or completed without undue delay.
13.3. Right to withdraw consent (Article 7(3) GDPR)
The user has the right to withdraw their consent to data processing at any time with prospective effect, without there needing to be a ground for withdrawal.
13.4. Right to erasure (Article 17 GDPR)
Subject to the prerequisites of Article 17 GDPR, the user may request erasure of their personal data. Their entitlement to erasure depends, inter alia, on whether the data concerning them are still needed by WELMI for fulfilling its statutory duties.
13.5. Right to restriction of processing (Article 18 GDPR)
Subject to the prerequisites of Article 18 GDPR, the user may request restriction of the processing of the personal data concerning them.
13.6. Right to data portability (Article 20 GDPR)
The user has the right to receive their provided personal data in a structured, commonly used and machine-readable format or to transmit those data to another controller, where the processing is based on consent and the processing is carried out by automated means.
13.7. Right to object (Article 21 GDPR)
The user may at any time make use of their right to object to the creation of user profiles and to the processing of personal data concerning them, where the processing takes place on the basis of Article 6(1)(e) or (f) GDPR. The personal data will no longer be processed unless compelling, legitimate grounds outweigh the user's interests, rights and freedoms. Where a user’s personal data are used for direct marketing purposes, they of course have the right to object at any time to such processing.
13.8. Right not to be subject to automated decision-making (Article 22 GDPR)
The user has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
13.9. Right to lodge a complaint (Article 77 GDPR)
In addition, the user has the right to lodge a complaint with the supervisory authority responsible for the Provider:
T-SHAPED APPS LTD
Griva Digeni, 51
ATHINEON COURT, Flat/Office 202
8047, Paphos, Cyprus
Email: support@welmi.ai
Web: www.welmi.ai
This Data Protection Policy is currently valid in the version of June 2025.If our Website or our Product is enhanced, or if legal requirements should change, it may become necessary to amend this Data Protection Policy. The current version of this Data Protection Policy can be viewed and printed out at any time by visiting https://www.