FASCINE

PREAMBLE

This Privacy Policy describes how MODELABS SAS, owner of the FASCINE brand, collects, uses, protects, retains, and shares the personal data of users of the FASCINE application and compatible connected products.

This Policy is established in accordance with Regulation (EU) 2016/679 (GDPR), the European Data Act, and other applicable regulations.

FASCINE was designed according to the principles of "Privacy by Design" and "Privacy by Default". Only the data strictly necessary for the operation of the services is processed.

Use of the FASCINE application requires the mandatory creation of a user account. Without an account, it is not possible to access the application, pair a connected product, or use the features offered.

1. DEFINITIONS

Application: the FASCINE mobile application.

Connected product: a watch, ring, or any other compatible device.

User account: a personal account enabling authentication and data synchronization.

Health data: data relating to physical activity or physiological indicators generated by the connected product.

Technical data: information necessary for the operation of the application and the maintenance of the products.

User: any person using the FASCINE application.

2. DATA CONTROLLER

Data Controller:
MODELABS SAS
107 rue La Boétie, 75008 Paris - France
Email: service.clients@modelabs.com

MODELABS determines the purposes and means of the processing carried out within the FASCINE application.

3. SCOPE

This Policy applies to all processing carried out through use of the FASCINE application, the associated cloud services, the artificial intelligence features, as well as the exchanges between the application and compatible connected products.

It applies to both the Android and iOS versions of the application.

4. USER ACCOUNT

Creating a user account is a mandatory condition for using FASCINE.

This account notably enables:

• authentication of the User
• secure synchronization of data
• restoration of data when changing phones
• use of features requiring identification
• protection of data against accidental loss

The account is free of charge. The User remains the owner of the data generated by their connected product.

5. CATEGORIES OF DATA COLLECTED

Depending on the features used, FASCINE may process:

A. Identification data

• email address
• username
• profile photograph (optional), which may be visible to other authorized users as part of the community features

B. Profile data

• sex
• date of birth
• height
• weight

This information is used to improve the accuracy of the calculations displayed.

C. Activity and health data

Depending on the capabilities of the connected product:

• number of steps
• distance traveled
• calories burned
• duration of activity
• heart rate
• blood oxygen saturation (SpO2)
• sleep data
• stress level

Certain measurements are taken automatically according to the settings defined by the User; others are triggered manually.

D. Technical data

In order to ensure the proper operation of the application, FASCINE may process:

• phone model
• Android or iOS version
• application version
• firmware version of the connected product
• technical logs strictly necessary for diagnosing malfunctions

E. Data relating to community features

The FASCINE application may offer features enabling users with a FASCINE account to interact with one another.

When the User chooses to use these features, certain additional data may be processed to ensure they function properly.

Depending on the features used, this data may notably include:

• invitations sent or received
• relationships established between users
• the profile photograph chosen by the User
• reactions or interactions carried out within the application
• information that the User chooses to share with the persons they have authorized

Community features rely exclusively on voluntary interactions between users holding a FASCINE account.

6. PERMISSIONS REQUESTED

Depending on the features used, the application may request access to:

• wireless connectivity in order to communicate with the connected product
• notifications in order to deliver alerts from the connected product
• location, when required by the operating system or necessary for GPS features
• the camera and photo gallery in order to personalize the profile

These permissions may be withdrawn at any time from the phone's settings. Certain features may then be limited.

7. PURPOSES OF PROCESSING

Personal data is used exclusively to:

• enable the normal operation of the application
• ensure communication with the connected product
• display health and activity indicators
• synchronize data across devices
• enable interactions between authorized users
• ensure the operation of community features
• manage invitations, relationships between users, and related interactions
• restore data when changing phones
• install software and firmware updates
• provide technical support
• improve the stability and security of the application
• comply with legal obligations

Personal data is never sold to third parties for commercial purposes.

8. LEGAL BASES

Processing is based on:

• performance of the contract (Article 6(1)(b) GDPR)
• compliance with legal obligations (Article 6(1)(c))
• MODELABS' legitimate interest in ensuring the security and maintenance of the service (Article 6(1)(f))
• the User's explicit consent for the processing of health data (Article 9(2)(a))

9. DATA SYNCHRONIZATION

Data necessary for the operation of FASCINE is synchronized with cloud services in order to ensure its availability, backup, and restoration in the event of a phone change.

Synchronization occurs only after the User has authenticated through their FASCINE account.

Synchronized data is limited to that which is necessary for the operation of the services offered. Purely local application settings may remain stored on the device only, where their synchronization is not necessary.

When certain community features are used, the information necessary for their operation may also be synchronized to enable interactions between the users concerned.

10. DATA HOSTING

Synchronized data is hosted on Amazon Web Services (AWS) infrastructure located in the United States (US West - Northern California).

Where any processing involves a transfer of data outside the European Economic Area, MODELABS ensures that appropriate safeguards required by the GDPR are implemented, including Standard Contractual Clauses (SCCs), an adequacy decision, or any other mechanism recognized under applicable regulations.

11. SHARING WITH APPLE HEALTH AND GOOGLE FIT / HEALTH CONNECT

The User may, if they wish, authorize the sharing of certain health data with Apple Health (iOS) or Google Fit (Android).

This synchronization is entirely optional and may be enabled or disabled at any time from the application's settings.

FASCINE does not transmit any data to these services without the User's explicit authorization.

12. ARTIFICIAL INTELLIGENCE ASSISTANT

FASCINE offers analysis and recommendation features powered by an artificial intelligence assistant.

In order to respond to requests made by the User, certain data may be transmitted to the artificial intelligence service provider, notably:

• sex
• age
• height
• weight
• number of steps
• sleep data
• heart rate
• blood oxygen saturation (SpO2)
• stress level

This data is transmitted solely to generate the requested response.

Conversations are stored in the phone's local storage. They are not accessible to MODELABS.

The responses generated by the assistant are produced automatically by an artificial intelligence system and are provided exclusively for informational purposes and wellness tracking.

NOTICE

The artificial intelligence features offered by FASCINE do not constitute a medical device and are not intended to diagnose, treat, cure, or prevent any disease or medical condition. The measurements, analyses, recommendations, and responses generated by the assistant are provided for informational purposes only and do not, under any circumstances, replace the advice, diagnosis, or treatment of a physician or any other qualified healthcare professional. If in doubt, or in the presence of symptoms or a health concern, consult a healthcare professional.

13. COMMUNITY FEATURES

The FASCINE application may offer community features enabling several users holding a FASCINE account to interact with one another.

These features rely exclusively on voluntary invitations and connections between users.

No information is made public.

Any information shared is accessible only to users to whom the User has voluntarily granted access, in accordance with the operation of the relevant feature.

Depending on the features used, certain elements of profile, activity, or wellness data may be shared between authorized users.

The categories of data actually shared depend on the features enabled and on how the application evolves.

The User may end a connection or remove another user from their circle where this option is offered by the application.

Removing a connection ends the sharing of the information associated with it, subject to any data that must be retained in accordance with applicable legal obligations.

14. SECURITY MEASURES

MODELABS implements appropriate technical and organizational measures to ensure the confidentiality, integrity, and availability of personal data.

These measures notably include:

• encryption of communications (TLS 1.2 or higher)
• encryption of stored data, where applicable
• access control based on the principle of least privilege
• logging of security events
• regular backups
• monitoring of security incidents

Despite these measures, no computer system can guarantee absolute security.

15. PROCESSORS

MODELABS may use specialized providers for hosting, maintenance, technical support, sending notifications, or artificial intelligence features.

These providers act solely on MODELABS' instructions, are bound by contractual confidentiality obligations, and implement a level of protection consistent with the GDPR.

16. RETENTION PERIODS

Personal data is retained only for the period necessary to fulfill the purposes described in this Policy.

The main applicable retention periods are as follows:

• synchronized data: a rolling thirty (30) day window within the cloud services
• inactive accounts: deletion after two (2) years of inactivity
• technical and diagnostic logs: ninety (90) days, unless otherwise required by law
• data relating to relationships between users and to community features: retained only for as long as necessary for their operation, or until deleted by the users concerned, subject to applicable legal obligations

At the end of these periods, data is deleted or anonymized where possible.

17. ACCOUNT DELETION

The User may request the deletion of their account at any time by contacting FASCINE support.

Deleting the account results in the deletion of the associated data, subject to legal retention obligations or data that must be retained for the defense of MODELABS' rights.

This action is irreversible.

Deleting the account also results in the deletion of connections established with other users, as well as information associated with community features, subject to legal retention obligations.

18. YOUR RIGHTS

In accordance with Regulation (EU) 2016/679 ("GDPR"), you have the following rights:

• the right to access your personal data
• the right to rectify inaccurate or incomplete data
• the right to erasure ("right to be forgotten") where the legal conditions are met
• the right to restrict processing
• the right to object where processing is based on MODELABS' legitimate interest
• the right to data portability, where applicable
• the right to withdraw your consent at any time, where processing is based on consent

Requests are processed following a reasonable verification of the requester's identity in order to protect data against unauthorized access.

19. EXERCISING YOUR RIGHTS

Any request relating to your personal data may be sent by email to:
service.clients@modelabs.com

MODELABS endeavors to respond as promptly as possible, and no later than within the timeframes provided for by applicable regulations.

Where a request is complex or where a large number of requests are being processed simultaneously, this timeframe may be extended in accordance with the GDPR. The User will be informed accordingly.

20. PROVISIONS RELATING TO THE DATA ACT

In accordance with the European Data Act, users have a right of access to the data generated by their connected product.

As of the date of this Policy, the FASCINE application does not offer a feature enabling the automatic export or direct download of this data.

Requests for access to, communication of, or transmission of data generated by the connected product must be sent to FASCINE support by email.

Each request is reviewed individually and processed manually in accordance with the GDPR, the Data Act, and within the limits of the technical capabilities of the services offered.

Where technically possible and legally applicable, MODELABS will provide the requested data in an appropriate format.

Requests that are manifestly unfounded, excessive, or repetitive may be refused or subject to the measures provided for by applicable regulations.

21. COMPLAINTS

If you consider that the processing of your personal data does not comply with applicable regulations, you may lodge a complaint with the competent supervisory authority of your country of residence.

In France, the competent authority is the Commission Nationale de l'Informatique et des Libertés (CNIL).

Lodging a complaint does not affect any other administrative or judicial remedies available to you.

22. CHANGES TO THIS POLICY

This Privacy Policy may be amended to take into account:

• changes in legislation or regulations
• technical developments to the application
• the addition, modification, or removal of features
• recommendations from competent authorities

The version in force is the one published on FASCINE's official website and within the application.

Where required by regulation, or where a change is likely to have a significant impact on your rights or on the processing of your personal data, appropriate notice will be provided before it takes effect.

23. CONTACT

For any question relating to this Privacy Policy or to the exercise of your rights:

MODELABS SAS
107 rue La Boétie
75008 Paris - France
Email: service.clients@modelabs.com

We are committed to handling every request diligently and in compliance with applicable regulations.

CONCLUSION

This Policy constitutes the reference version applicable to users of the FASCINE application.

It is intended to be read together with the Terms of Use, the user manual, and any specific documentation relating to FASCINE connected products.