LEGAL NOTICE AND WEBSITE CONDITIONS

Decentralized Biotechnology Intelligence Co., Ltd. (hereinafter referred to as "VITBIO" or "the Company") provides information on the general terms and conditions of use of the Website that governs access to and use of the Website.

The purpose of the Website is to provide the user with information relating to the products and services offered by the Company.

In this regard, the following information is strongly recommended before using the Website. The contracting of the Company's products and services will be governed in accordance with the terms specified therein.

Access and use of the Website attribute the status of user thereof to the person browsing it (hereinafter, the "user") and will imply knowledge of the Terms of Use and their acceptance.

1.    Information
from the owner of the Website.

In accordance with the provisions
of the regulations governing electronic commerce, the mandatory information
required by this regulation is indicated.

-         
Company name: Decentralized Biotechnology Intelligence
Co., Ltd.

-         
Tax ID (Taiwan equivalent of VAT/NIF): 83103782

-         
Registered address: 3F-1, No. 309, Sec. 3, Roosevelt
Rd., Da'an Dist., Taipei City, Taiwan

-         
Contact email: info@vitbio.ai

-         
Customer service line: +886-2-2366-0988

2.   
Legal Notice

Mere access to
the Website does not imply the existence of any type of commercial or
contractual relationship between VITBIO and the user.

These General
Conditions do not exclude in any case that certain services presented through
the Website are subject to other terms and conditions.

VITBIO reserves the right to
modify the conditions and terms of use of the Website. Any changes or
modifications in this regard will be published visibly on the website,
indicating the date of the last update. If the user continues making use of the
services provided on the Website, it is understood that accept the
modifications made.

3.  
Navigation and access

Access to and
browsing of the Website implies acceptance and knowledge of the legal warnings,
conditions and terms established therein. The Company will make every effort to ensure that navigation takes
place in the best conditions and to avoid damage of any kind that may be caused
during it.

VITBIO will not
be responsible for any damages of any kind that may be caused to users by the
use of other browsers or versions other than the browsers for which this
Website has been designed.

4. Correct use
of the Website and non-permitted uses.

The Terms of Use
of the Website are subject to current legislation and to the use by the user
taking place in accordance with the principles of good faith and lawfulness,
and any type of action to the detriment of the Company and contrary to this Legal Notice and regardless of
the use of the mobile application is prohibited.

All users must
use the Website without engaging in activities that could be considered illicit
or illegal, that infringe the rights of the Company or third parties, or that
may damage, disable or deteriorate the Website or prevent the normal use of the
Website by other users.

Specifically, it
is prohibited, including but not limited to:

·   Use the Website in an unlawful manner, or in
any other way that may damage, overburden, or impair the Site itself.

·   Introduce computer viruses, defective files or
host, store, share or distribute any material or computer program that may
cause damage or alteration to the content, programs or systems of the Website.

·  Use
or resell for unauthorised commercial purposes the content included on the
Website without the Company's consent.

VITBIO shall be entitled to
adopt, at its discretion, at the request of a third party or the competent
authority, the necessary measures in the event of non-compliance with the
provisions of this Clause, without the adoption of these measures granting the
user the right to claim any compensation.

5.
Responsibilities arising from the use of the Website

The user shall
be entirely responsible for the access and correct use of the Website, and
shall abide by the principles of good faith, morality and public order,
undertaking to diligently observe any instructions that may be provided by
VITBIO in relation to such use and access.

Likewise, the
user is obliged to make reasonable use of the Website and its contents, being
the only one responsible for the information or content that may be
communicated through the Website.

6. Disclaimer

If any of the
contents, files, information, concepts, opinions or images hosted on the
Website are contrary to the law, morality or public order or contain any type
of computer virus, they will be removed.

VITBIO is not responsible for
the contents, files, information, advertising, concepts or images that do not
depend on the Website or are not managed by the Company.

VITBIO will not assume any
liability arising from the misuse of the Website or its contents by the user,
who will in any case assume the consequences, damages or actions that may arise
from their access or use of the Website or the contents hosted therein,
including their reproduction or communication.

Nor is it
responsible for any of the contents, files, information, advertising, concepts
or images that are broadcast, published or distributed, directly or indirectly,
through any website accessed through this Website through links or any of the
services that are linked or related to this site that is interconnected.

VITBIO provides the services
and content on an ongoing basis, using the technical means at its disposal to
ensure the correct provision.

In this regard, VITBIO may make modifications,
improvements or corrections to the information contained on the Website, in the
services or in the contents, without this giving the user the right to file any
claim or request compensation, nor does it imply the recognition of any
liability.

VITBIO shall not be liable for
any damages that may arise from the availability and continuity of the
operation of the Website or the existence of unintentional errors. In any case,
the Company will carry out all the necessary actions to restore services in the
event of a technical failure.

7. Links and
hyperlinks.

Links

This Website may
contain links or hyperlinks to other websites managed by third parties,
therefore, VITBIO does
not assume any liability arising from the content that third parties have
included in the hyperlinks to which this website refers.

The
establishment of a hyperlink does not imply in any case the existence of a
relationship of any kind between the Company and the owner of the Website on which it is
established.

Likewise, the
existence of a hyperlink on the Website does not imply at any time the
acceptance and approval by the Company of its contents. However, in those cases
in which it is considered that such content may be inappropriate, we ask the
user to bring this circumstance to our attention through the means indicated in
the first section of this document.

Hyperlinks

Any user who
intends to establish a hyperlink or technical link from their website to this
Website must obtain prior written authorisation from VITBIO.

The
establishment of this hyperlink does not imply in any case the existence of
relations of any kind between VITBIO
and the owner of the Website on which it is established, nor the
acceptance of its contents.

The Company may prohibit or use the
hyperlink established to this Website at any time.

8. Intellectual
and industrial property of the Website.

VITBIO owns all
rights to the software on the Website. VITBIO does not transfer ownership of
its software or grant any license or authorisation of use of any kind on its
intellectual and industrial property rights, trade secrets or any other
property or right related to the Website or its contents.

The contents of
this Website are protected by intellectual and industrial property regulations
and any unauthorised use of any material on this Website may violate the
regulations on copyright, trademarks and any other applicable regulations in
this regard.

This Website may
contain products and services that are not owned by the Company whose trademarks
are registered in favour of their respective owners, and as such are recognised
by this Company.

9. Changes and
modifications to the Terms of Use.

VITBIO may, at any time, modify
these conditions or introduce new conditions of use, for which purpose it is
sufficient to notify us through the Website, unless the applicable regulations
require another form of communication or acceptance of the modifications.

10. Governing
Law and Jurisdiction.

These Terms
shall be governed by and construed in accordance with the laws of the
jurisdiction in which VITBIO is established, without regard to its conflict of
law rules. You agree to submit to the personal and exclusive jurisdiction of
the courts located in such jurisdiction.

11. Data
protection.

The collection
and processing of personal data that may be provided by the user or through the
website, as well as the exercise of rights over such data, will be governed by
the website's Privacy Policy [...].[Autor1] 

12. Contact

If you have any
questions about these Terms, you can contact us via email info@vitbio.ai.
These Terms and Conditions were last updated on 19/05/2026,

By using our
Website and the Services offered, the user acknowledges that user has read,
understood and agreed to be bound by these Terms and Conditions.

 [Autor1]Hyperlink to Privacy Policy

COOKIES POLICY

Decentralized Biotechnology
Intelligence Co., Ltd. (hereinafter, “VITBIO” or the “Company”),
with Tax ID No. 83103782 and registered office at 3F-1, No. 309, Sec. 3,
Roosevelt Rd., Da’an Dist., Taipei City (Taiwan), hereby informs users of the
Policy governing the use of cookies on its Website, in compliance with the
applicable data protection regulations and, in particular, Regulation (EU)
2016/679 of the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal data
and on the free movement of such data (hereinafter, the “GDPR”).

1.    What
are cookies

Cookies are any type of data
storage and retrieval device used on a user’s terminal equipment for the
purpose of storing information and retrieving information already stored. They
are sent to the browser of the Website user and stored on the user’s device.

2.    Types
of cookies

According to the entity
managing them:

·     
First-party cookies: These
are cookies for which the Website owner itself is responsible and which are
generally sent to the user’s terminal equipment from equipment or a domain
managed by the Website owner itself and from which the service requested by the
user is provided.

·     
Third-party cookies: These
are cookies for which an entity other than the Website owner is responsible and
which are sent to the user’s terminal equipment from equipment or a domain that
is not managed by the Website owner.

According to their
purpose:

·     
Technical or strictly necessary
cookies: These are cookies necessary for the proper
functioning of the Website and cannot be disabled within VITBIO’s systems.

These cookies enable
the operation and management of browsing through the Website. They are
generally configured to respond to actions requested by the user, such as
adjusting privacy preferences, logging into the Website, completing forms,
carrying out the purchase process for an order or managing payment
transactions.

Users may configure
their browser to block or alert them to the presence of these cookies; however,
certain parts of the Website may not function properly as a result.

These cookies do not
store personally identifiable information and are exempt from the obligation to
obtain user consent.

VITBIO uses these
cookies in order to ensure the proper technical functioning of the Website,
maintain and protect user sessions, manage traffic and system stability, and
enable essential functionalities during the user’s browsing experience,
including where applicable, functionalities associated with the shopping cart.

·     
Analytical or measurement cookies:
These cookies enable monitoring and analysis of user behaviour on the Website.

The information
collected through these cookies is used to measure activity on the Website in
order to implement improvements based on the analysis carried out regarding
users’ interaction with the Website.

VITBIO uses these
cookies on the Website to analyse traffic and usage for the purpose of
improving performance and enhancing the user experience.

·     
Marketing or behavioural
advertising cookies: These cookies store information regarding user
behaviour obtained through the observation of browsing habits, enabling the
development of a specific profile in order to display advertising based on such
analysis.

VITBIO uses these
cookies to carry out marketing campaigns and measure their effectiveness.

·     
Preference or personalization
cookies: These cookies allow information to be remembered so
that users may access the service with certain characteristics that
differentiate their experience from that of other users; in other words, they
enable the creation of a profile based on users’ interests in order to display
personalised advertising.

VITBIO uses these
cookies to remember the Website language settings, the number of search results
to be displayed when a user performs a search, or where a user visits the
Website and is subsequently shown advertisements such as “improve your
performance with AI-based analysis” or “download OmniGmot”.

According to the period
of time for which they remain active:

·     
Session cookies:
These cookies are designed to collect and store data while the user accesses a
webpage. They are temporary in nature and are deleted once the user closes the
browser.

·     
Persistent cookies:
These are cookies whereby the data remains stored on the user’s terminal
equipment and may be accessed and processed for a period defined by the party
responsible for the cookie.

3.    Cookies
Purposes

Cookies are used to collect
information regarding users’ browsing activity in order to analyse how users
interact with the VITBIO Website and thereby optimise the user browsing
experience.

The cookies used on the Website
shall be updated whenever changes are made to the services offered through the
Website or to the categories of cookies used for such purposes.

4. How to disable
cookies

Users may reject, in advance, the
use of cookies on their device or terminal equipment through their browser
settings; however, this may result in a less satisfactory browsing experience
and could even affect the proper functioning of certain areas of the Website.

Users may block cookies through the
configuration tools available in their browser settings.

Likewise, should users wish to
withdraw their consent to the use of cookies, they may do so at any time
through the settings and configuration options of their Internet browser.

5.
Acceptance, Rejection and Configuration of Cookies

Upon their first visit to the
Website, users may accept or reject non-essential cookies through the cookie
consent banner. Consent may be modified or withdrawn at any time through the
Website settings.

Users accept the use of cookies and
this Cookies Policy by ticking the corresponding box. Any mechanism involving
the tacit acceptance of cookies without the user’s explicit consent shall not
be considered valid.

Where users accept the use of
cookies and this Cookies Policy, the cookie banner containing the first-layer
information notice shall not be displayed again during the relevant session.

Likewise, users may configure or
reject cookies at any time through the “Configure Cookies” tab by selecting the
corresponding option.

Consent for the use of cookies
shall remain valid for a period of 12 months. Once such period has elapsed,
users’ consent shall be requested again in order to refresh the legal basis
legitimising the collection of users’ browsing data.

6. Withdrawal or
Revocation of Consent

Users may revoke at any time the
consent initially granted for the installation and use of cookies through the
configuration panel available on the Website.

7 Amendments to the
Policy

VITBIO reserves the right to amend
this Cookies Policy in accordance with the applicable legislation whenever
relevant changes occur in relation to the collection of cookies, new cookies
are implemented, or legislative amendments require the Website owner to modify
the content of this Policy.

Accordingly, VITBIO recommends that
users periodically review this Cookies Policy in order to remain informed about
the manner in which their personal information is protected.

8. Contact details of
the Website owner

Should users have any questions
regarding the installation or collection of cookies or, in particular,
regarding this Cookies Policy, they may contact VITBIO at the following email
address: info@vitbio.ai.

Privacy Policy: OmniGmot

Decentralized Biotechnology
Intelligence Co., Ltd. (hereinafter, “VITBIO” or the “Company”)
is committed to protecting the privacy and personal data of users accessing and
using the OmniGmot application and the related services associated therewith
(hereinafter, the “Services”).

This Privacy Policy applies to the
processing of users’ personal data in connection with the provision and
operation of the Services, in accordance with the applicable data protection
legislation and, in particular, Regulation (EU) 2016/679 of the European
Parliament and of the Council of 27 April 2016 (hereinafter, the “GDPR”).

Users are advised to carefully
review this Privacy Policy before accessing or using the Services, through
which detailed information is provided regarding the processing of their
personal data.

I.
 Data Controller

The controller responsible for the
processing of the personal data of users accessing OmniGmot and the Services
provided therein is Decentralized Biotechnology Intelligence Co., Ltd. (VITBIO),
with Tax ID No. 83103782, having its registered office at 3F-1, No. 309, Sec.
3, Roosevelt Rd., Da’an Dist., Taipei City, Taiwan, and contact email address info@vitbio.ai.

In this regard, VITBIO acts as the
data controller in relation to the processing of users’ personal data insofar
as it determines the purposes and means of the processing of such personal
data.

II.   
Scope of Application

This Privacy Policy applies
exclusively to the personal data collected, processed and used in connection
with the provision and operation of the Services.

VITBIO undertakes to process the
personal data of OmniGmot users — “processing” being understood as any
operation or set of operations referred to in Article 4 of the GDPR — in
accordance with the principles of lawfulness, fairness and transparency, purpose
limitation, data minimisation, confidentiality and accountability, ensuring
that personal data is processed solely to the extent necessary for the
legitimate purposes described in this Privacy Policy.

Notwithstanding the foregoing, this
Privacy Policy shall not apply to third-party websites, platforms or services
that may be accessible through available links and which are not operated,
controlled or managed by VITBIO.

Certain personal data may be
necessary for the proper operation and provision of the Services. Should users
choose not to provide the information required to enable certain
functionalities, some features or Services may not be available or may not
function properly

III.      Categories
of personal data processed

In connection with the provision
and operation of the Services, VITBIO may collect and process the following
categories of personal data

·     
Device, technical and connectivity
data: IP address, device identifiers, operating system
information, mobile device information, Mobile Country Code (MCC), Mobile
Network Code (MNC), mobile network-related information, browser-related
information, access timestamps, activity logs and technical information
specifically generated through the use of the Services.

·      Application
permissions and device access data: information relating
to access rights, functionalities and permissions enabled by users, including
access to the camera (including QR code scanning functionalities, portrait
capture and motion capture), access to photographs, GPS geolocation data,
notifications and push notifications, document storage permissions,
functionalities related to the telephone device through which the application
is used and integrations associated with device assistance functionalities,
including Siri and search functionalities.

·     
Physiological metrics and
application-related information: information provided by
users or generated through the functionalities of the Services, including
height, weight, energy expenditure, physical activity and metrics relating to
sports practice and body movement.

In particular, the
Services may collect and analyse information relating to walking and running
(including step count, distance travelled, speed, cadence, foot-strike pattern
and plantar pressure), cycling activity (including pedalling power, cadence and
data associated with shared sports activity) and biomechanical analysis of body
and sports movement, including joint angles, body rotation, three-dimensional
displacement and other metrics related to physical performance and body
mechanics.

·      Support
and communications data: user information contained in
communications, support requests, incident reports, correspondence and
attachments voluntarily submitted by users in connection with the Services.

·      Cookies
and similar technologies: user information contained in
communications, support requests, incident reports, correspondence and
attachments voluntarily submitted by users in connection with the Services.

VITBIO informs users
that certain functionalities of the Services may not operate properly if
cookies or similar technologies are disabled through the settings of the user’s
browser or device.

In this context, VITBIO does not
intentionally collect or process special categories of personal data within the
meaning of Article 9 GDPR for the purpose of carrying out medical diagnoses,
clinical assessments or providing healthcare services.

Notwithstanding the foregoing,
VITBIO informs users that certain information processed in connection with the
use of OmniGmot could, depending on the context and manner in which such
information is processed, potentially qualify by inference as special categories
of personal data in accordance with the definition set out in Article 9 GDPR
and the interpretation of such concept adopted by the European Data Protection
Board (hereinafter, the “EDPB”), particularly in those cases where
physiological metrics collected through data provided by users or certain
behavioural patterns detected through the application may allow conclusions to
be drawn regarding the user’s physical condition or wellbeing.

Furthermore, certain
functionalities of OmniGmot may incorporate automated analysis processes or
artificial intelligence-based functionalities for the purpose of optimising the
user experience, improving the operation of the Services and generating information
related to the performance and use of the application.

In those cases where the processing
of certain information may require it, VITBIO shall adopt the necessary
measures to ensure that the consent provided by users satisfies the conditions
required under the applicable legislation and may be duly evidenced in
accordance with the principle of accountability.

IV.
 Purposes and legal basis

VITBIO may process users’ personal
data for the following purposes on the basis of the legal grounds set out
below:

Purpose of processing

Legal basis

To enable access to, operation, maintenance and
provision of the Services and functionalities associated with OmniGmot.

Performance of a contractual relationship or
implementation of pre-contractual measures

To analyse users’ activity and interaction with the
Services, including usage metrics, sports activity and performance of the
application functionalities.

Legitimate interest of the data controller in improving the operation,
stability, security and user experience of the Services and, where required,
the user’s consent.

To generate recommendations, personalise certain
functionalities and adapt the user experience based on the use made of the
Services and the preferences identified during the use of the application.

User consent and, where applicable, explicit consent
where certain functionalities may involve the processing of special
categories of personal data by inference.

To develop, improve, train, validate and optimise
models, algorithms and functionalities related to artificial intelligence,
data analytics and the performance of the Services.

Legitimate interest of the data controller and,
where necessary, user consent and, where applicable, explicit consent for
special categories of personal data processed by inference.

To prepare aggregated statistics, internal analyses and studies
relating to the operation, use and improvement of the Services.

Legitimate interest of the data controller

To manage requests, enquiries, incidents, technical support and
communications maintained with users.

Performance of the contractual relationship and legitimate interest of
the data controller.

To ensure the security, integrity, availability and proper functioning
of the Services, as well as to prevent unauthorised access, fraudulent use or
security incidents.

Legitimate interest in the data controller and compliance with
applicable legal obligations.

To send VITBIO’s own commercial communications relating to products,
services, functionalities or updates

Explicit consent of the data subject.

Where the processing of certain
personal data requires the user’s consent under the applicable legislation,
VITBIO shall adopt the necessary measures to ensure that such consent is
provided freely, specifically, informedly and unambiguously and, where required,
explicitly.

Furthermore, VITBIO may retain
evidence relating to the granting, configuration, updating or withdrawal of
users’ consent for the purpose of demonstrating compliance with the legal
obligations arising from the applicable data protection legislation.

V. Retention, Cancellation
and Erasure of Personal Data

In accordance with the principle of
storage limitation, users’ personal data processed by VITBIO shall be retained
for the period strictly necessary to fulfil the purposes for which such data
were collected. In particular:

·       
Data relating to the user account and the provision of
the Services shall be retained for as long as the relationship with the user
remains active.

·       
Technical data, activity logs, security-related
information and system logs may be retained for the periods necessary to ensure
the security, integrity and proper functioning of the Services, prevent
unauthorised access, investigate security incidents and comply with applicable
legal obligations.

·       
Information relating to communications, technical
support, incidents or enquiries submitted by users may be retained for as long
as necessary for the proper management and follow-up thereof.

·       
Data processed for analytical, statistical; service
improvement or model and algorithm training and optimisation purposes may be
retained for the period strictly necessary for such purposes, applying, to the
extent technically feasible, measures aimed at anonymisation, pseudonymisation
or data minimisation.

·       
Data processed for commercial purposes or for the
sending of commercial communications shall be retained until the user withdraws
the consent granted or exercises the right to object in accordance with the
applicable legislation.

Once the purposes of justifying the
processing of personal data have been fulfilled, the data shall be subject to
blocking or restricted retention for the legally required periods necessary to
address any potential legal, contractual or regulatory liabilities attributable
to the data controller and shall subsequently be securely deleted or, where
appropriate, anonymised.

VI. Data recipients

The personal data processed by
VITBIO may be disclosed to the Company’s providers or collaborators that
provide services necessary for the proper operation, maintenance, security and
improvement of the Services.

In particular, VITBIO may use
providers relating to cloud infrastructure and data hosting services,
electronic communications and notification services (including push
notification systems), and authentication, identity verification and SMS
communication gateway services used to ensure secure access to and operation of
certain functionalities of the Services.

Furthermore, personal data may also
be disclosed to public, administrative, judicial or governmental authorities
where such disclosure is necessary for compliance with legal obligations or
valid requests made in accordance with the applicable legislation.

VITBIO may disclose personal data
to entities belonging to its corporate structure for internal administrative
purposes.

VII. International data
transfers

As a general rule, the personal
data processed in connection with the provision and operation of the Services
shall be stored and hosted through technical infrastructure located on servers
within the European Economic Area (hereinafter, the “EEA”).

However, certain limited backup,
business continuity, technical support or security-related operations may
involve access to or storage of information outside the EEA, including backup
infrastructures located in Taiwan.

In such cases, VITBIO shall adopt
the appropriate technical, organisational and contractual measures necessary to
ensure an adequate level of protection of personal data in accordance with the
applicable data protection legislation and, in particular, Articles 46 et seq.
of the GDPR.

In particular, any international
data transfers that may be carried out by VITBIO may, where necessary, be based
on recognised appropriate safeguard mechanisms, including, among other
measures, the execution of Standard Contractual Clauses approved by the
European Commission or, where applicable, an Adequacy Decision adopted by the
European Commission.

VII. Artificial
Intelligence and Automated Data Analysis

VITBIO informs users that certain
functionalities of the Services may incorporate automated analysis processes,
advanced personalisation functionalities or artificial intelligence-based
features for the purpose of optimising the user experience, improving the
operation and performance of the Services and generating information related to
the activity and use of the application.

In this regard, VITBIO shall adopt
the necessary measures to ensure that such processing activities are carried
out in accordance with the fundamental principles required under the applicable
data protection legislation.

VITBIO shall periodically assess
the evolution of the regulatory framework applicable to artificial intelligence
systems in order to adopt the governance, transparency and compliance measures
that may be required in light of the nature and functionalities of the
Services.

VIII. Security measures

VITBIO adopts technical,
organisational and security measures that are reasonably appropriate and
aligned with generally accepted industry standards in order to protect personal
data against unauthorised access, disclosure, alteration, loss, destruction or
any other form of unlawful processing.

Among other measures, the Company
may implement access control mechanisms, communication protection measures,
internal security procedures and actions aimed at strengthening the
confidentiality, integrity, availability and resilience of the systems and services
related to the processing of personal data.

Furthermore, VITBIO may carry out
periodic review, monitoring and updating actions in relation to its security
measures.

In the event of security incidents
affecting personal data, VITBIO shall act in accordance with the applicable
data protection legislation and shall adopt the measures reasonably necessary
having regard to the nature and scope of the incident in order to mitigate the
associated risks and, where appropriate, communicate such incidents without
undue delay following an assessment of their scope, nature, categories of data
and number of affected records.

Where an incident is likely to
significantly affect the rights and freedoms of users, the necessary measures
shall be adopted to notify the affected individuals, including the information
required under the applicable data protection legislation.

IX. Rights of data
subjects

Any user providing personal data
may exercise the following rights under applicable data protection legislation:

-         
The right of access, to obtain confirmation as to
whether personal data concerning them is being processed and to request the
information provided.

-         
The right to rectify personal data where such data is
inaccurate or requires updating.

-         
The right to erase personal data where, among other
circumstances, such data is no longer necessary for the purposes for which it
was collected.

-         
The right to restrict processing in the circumstances
provided for under the GDPR.

-         
The right to data portability, by requesting the
transmission of personal data in electronic format to another data controller
in a structured, commonly used and machine-readable format.

-         
The right to object to the processing of personal
data.

-         
The right to withdraw consent at any time, without
affecting the lawfulness of processing based on consent before its withdrawal.

To exercise the rights described
above, users may contact VITBIO through the contact details indicated above
and, in particular, by email at info@vitbio.ai.
Likewise, users will have the right to file a complaint with the competent
supervisory data protection authority.

X. Withdrawal or
Revocation of Consent

Users may object to the processing
of their personal data and may withdraw any consent previously granted at any
time where the processing is based on the data subject’s consent, without
affecting the lawfulness of the processing carried out by VITBIO prior to such
withdrawal. For this purpose, users may contact VITBIO by sending an email to info@vitbio.ai.

XI. Changes to the
Privacy Policy

This Privacy Policy may be amended
or updated periodically as a result of legal, regulatory or operational
requirements, as well as improvements and changes relating to the manner in
which the Services are offered and provided.

Any relevant amendment or update to
this Privacy Policy may be communicated to users through the application, the
VITBIO website, notifications or, where appropriate, through other reasonably
appropriate communication channels.

VITBIO recommends that users
periodically review this Privacy Policy in order to remain informed about the
manner in which their personal data is processed and protected.

Privacy Policy: 24hStetho

Decentralized Biotechnology Intelligence Co., Ltd. (hereinafter, “VITBIO” or the “Company”) is committed to protecting the privacy and personal data of users accessing and using the 24hStetho application and the related services associated therewith (hereinafter, the “Services”).

This Privacy Policy applies to the processing of users’ personal data in connection with the provision and operation of the Services, in accordance with the applicable data protection legislation and, in particular, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter, the “GDPR”).

Users are advised to carefully review this Privacy Policy before accessing or using the Services, through which detailed information is provided regarding the processing of their personal data.

I. Data Controller

The controller responsible for the processing of the personal data of users accessing 24hStetho and the Services provided therein is Decentralized Biotechnology Intelligence Co., Ltd. (VITBIO), with Tax ID No. 83103782, having its registered office at 3F-1, No. 309, Sec. 3, Roosevelt Rd., Da’an Dist., Taipei City, Taiwan, and contact email address info@vitbio.ai.

In this regard, VITBIO acts as the data controller in relation to the processing of users’ personal data insofar as it determines the purposes and means of the processing of such personal data.

II. Scope of Application

This Privacy Policy applies exclusively to the personal data collected, processed and used in connection with the provision and operation of the Services.

VITBIO undertakes to process the personal data of 24Stetho users — “processing” being understood as any operation or set of operations referred to in Article 4 of the GDPR — in accordance with the principles of lawfulness, fairness and transparency, purpose limitation, data minimisation, confidentiality and accountability, ensuring that personal data is processed solely to the extent necessary for the legitimate purposes described in this Privacy Policy.

Notwithstanding the foregoing, this Privacy Policy shall not apply to third-party websites, platforms or services that may be accessible through available links and which are not operated, controlled or managed by VITBIO.

Certain personal data may be necessary for the proper operation and provision of the Services. Should users choose not to provide the information required to enable certain functionalities, some features or Services may not be available or may not function properly.

III. Categories of personal data processed

In connection with the provision and operation of the Services, VITBIO may collect and process the following categories of personal data

• Device, technical and connectivity data: IP address, device identifiers, operating system information, mobile device information, Mobile Country Code (MCC), Mobile Network Code (MNC), mobile network-related information, browser-related information, access timestamps, activity logs and technical information specifically generated through the use of the Services.

• Application permissions and device access data: information relating to access rights, functionalities and permissions enabled by users, including access to the camera (including QR code scanning functionalities, portrait capture and motion capture), access to photographs, GPS geolocation data, notifications and push notifications, document storage permissions, functionalities related to the telephone device through which the application is used and integrations associated with device assistance functionalities, including Siri and search functionalities.

• Physiological and cardiac-related data: cardiac auscultation waveforms, heart-sound signals, heart rate information, heart-rate variability (HRV) metrics and other physiological signals generated through the use of the Services and the associated hardware device.

• Support and communications data: user information contained in communications, support requests, incident reports, correspondence and attachments voluntarily submitted by users in connection with the Services.

• Cookies and similar technologies: user information contained in communications, support requests, incident reports, correspondence and attachments voluntarily submitted by users in connection with the Services.

VITBIO informs users that certain functionalities of the Services may not operate properly if cookies or similar technologies are disabled through the settings of the user’s browser or device.

In this context, VITBIO does not intentionally collect or process special categories of personal data within the meaning of Article 9 GDPR for the purpose of carrying out medical diagnoses, clinical assessments or providing healthcare services.

Notwithstanding the foregoing, VITBIO informs users that certain data processed through 24hStetho may constitute or reveal information relating to the health status or physiological condition of users within the meaning of Article 4(15) GDPR.

Furthermore, certain functionalities of 24hStetho may incorporate automated analysis processes or artificial intelligence-based functionalities for the purpose of optimising the user experience, improving the operation of the Services and generating information related to the performance and use of the application.

In those cases where the processing of certain information may require it, VITBIO shall adopt the necessary measures to ensure that the consent provided by users satisfies the conditions required under the applicable legislation and may be duly evidenced in accordance with the principle of accountability.

IV. Purposes and legal basis

VITBIO may process users’ personal data for the following purposes on the basis of the legal grounds set out below:

Purpose of processing Legal basis
To enable access to, operation, maintenance and provision of the Services and functionalities associated with 24hStetho Performance of a contractual relationship or implementation of pre-contractual measures
To collect, process and analyse physiological and cardiac-related information generated through the use of 24hStetho, including heart-sound signals, heart rate and heart-rate variability (HRV) metrics, for the purpose of enabling the functionalities and operation of the Services.


User consent and, where applicable, explicit consent for the processing of health-related data
To generate personalised information, recommendations and wellness-related insights based on the use of the Services and the physiological information processed through the application.
User consent and, where applicable, explicit consent for the processing of health-related data

To develop, improve, train, validate and optimise models, algorithms and functionalities related to artificial intelligence, data analytics and the performance of the Services.
Legitimate interest of the data controller and, where necessary, user consent and, where applicable, explicit consent for the processing of health-related data

To prepare aggregated statistics, internal analyses and studies relating to the operation, use and improvement of the Services.
Legitimate interest of the data controller

To manage requests, enquiries, incidents, technical support and communications maintained with users. Performance of the contractual relationship and legitimate interest of the data controller.

To ensure the security, integrity, availability and proper functioning of the Services, as well as to prevent unauthorised access, fraudulent use or security incidents.
Legitimate interest in the data controller and compliance with applicable legal obligations.
To send VITBIO’s own commercial communications relating to products, services, functionalities or updates
Explicit consent of the data subject.



Where the processing of certain personal data requires the user’s consent under the applicable legislation, VITBIO shall adopt the necessary measures to ensure that such consent is provided freely, specifically, informedly and unambiguously and, where required, explicitly.

Furthermore, VITBIO may retain evidence relating to the granting, configuration, updating or withdrawal of users’ consent for the purpose of demonstrating compliance with the legal obligations arising from the applicable data protection legislation.

V. Retention, Cancellation and Erasure of Personal Data

In accordance with the principle of storage limitation, users’ personal data processed by VITBIO shall be retained for the period strictly necessary to fulfil the purposes for which such data were collected. In particular:

• Data relating to the user account and the provision of the Services shall be retained for as long as the relationship with the user remains active.

• Technical data, activity logs, security-related information and system logs may be retained for the periods necessary to ensure the security, integrity and proper functioning of the Services, prevent unauthorised access, investigate security incidents and comply with applicable legal obligations.

• Information relating to communications, technical support, incidents or enquiries submitted by users may be retained for as long as necessary for the proper management and follow-up thereof.

• Data processed for analytical, statistical; service improvement or model and algorithm training and optimisation purposes may be retained for the period strictly necessary for such purposes, applying, to the extent technically feasible, measures aimed at anonymisation, pseudonymisation or data minimisation.

• Data processed for commercial purposes or for the sending of commercial communications shall be retained until the user withdraws the consent granted or exercises the right to object in accordance with the applicable legislation.

Once the purposes of justifying the processing of personal data have been fulfilled, the data shall be subject to blocking or restricted retention for the legally required periods necessary to address any potential legal, contractual or regulatory liabilities attributable to the data controller and shall subsequently be securely deleted or, where appropriate, anonymised.

VI. Data recipients

The personal data processed by VITBIO may be disclosed to the Company’s providers or collaborators that provide services necessary for the proper operation, maintenance, security and improvement of the Services.

In particular, VITBIO may use providers relating to cloud infrastructure and data hosting services, electronic communications and notification services (including push notification systems), and authentication, identity verification and SMS communication gateway services used to ensure secure access to and operation of certain functionalities of the Services.

Furthermore, personal data may also be disclosed to public, administrative, judicial or governmental authorities where such disclosure is necessary for compliance with legal obligations or valid requests made in accordance with the applicable legislation.

VITBIO may disclose personal data to entities belonging to its corporate structure for internal administrative purposes.

VII. International data transfers

As a general rule, the personal data processed in connection with the provision and operation of the Services shall be stored and hosted through technical infrastructure located on servers within the European Economic Area (hereinafter, the “EEA”).

However, certain limited backup, business continuity, technical support or security-related operations may involve access to or storage of information outside the EEA, including backup infrastructures located in Taiwan.

In such cases, VITBIO shall adopt the appropriate technical, organisational and contractual measures necessary to ensure an adequate level of protection of personal data in accordance with the applicable data protection legislation and, in particular, Articles 46 et seq. of the GDPR.

In particular, any international data transfers that may be carried out by VITBIO may, where necessary, be based on recognised appropriate safeguard mechanisms, including, among other measures, the execution of Standard Contractual Clauses approved by the European Commission or, where applicable, an Adequacy Decision adopted by the European Commission.


VII. Artificial Intelligence and Automated Data Analysis

VITBIO informs users that certain functionalities of the Services may incorporate automated analysis processes, advanced personalisation functionalities or artificial intelligence-based features for the purpose of optimising the user experience, improving the operation and performance of the Services and generating information related to the activity and use of the application.

In this regard, VITBIO shall adopt the necessary measures to ensure that such processing activities are carried out in accordance with the fundamental principles required under the applicable data protection legislation.

VITBIO shall periodically assess the evolution of the regulatory framework applicable to artificial intelligence systems in order to adopt the governance, transparency and compliance measures that may be required in light of the nature and functionalities of the Services.

VIII. Security measures

VITBIO adopts technical, organisational and security measures that are reasonably appropriate and aligned with generally accepted industry standards in order to protect personal data against unauthorised access, disclosure, alteration, loss, destruction or any other form of unlawful processing.

Among other measures, the Company may implement access control mechanisms, communication protection measures, internal security procedures and actions aimed at strengthening the confidentiality, integrity, availability and resilience of the systems and services related to the processing of personal data.

Furthermore, VITBIO may carry out periodic review, monitoring and updating actions in relation to its security measures.

In the event of security incidents affecting personal data, VITBIO shall act in accordance with the applicable data protection legislation and shall adopt the measures reasonably necessary having regard to the nature and scope of the incident in order to mitigate the associated risks and, where appropriate, communicate such incidents without undue delay following an assessment of their scope, nature, categories of data and number of affected records.

Where an incident is likely to significantly affect the rights and freedoms of users, the necessary measures shall be adopted to notify the affected individuals, including the information required under the applicable data protection legislation.



IX. Rights of data subjects

Any user providing personal data may exercise the following rights under applicable data protection legislation:

- The right of access, to obtain confirmation as to whether personal data concerning them is being processed and to request the information provided.
- The right to rectify personal data where such data is inaccurate or requires updating.
- The right to erase personal data where, among other circumstances, such data is no longer necessary for the purposes for which it was collected.
- The right to restrict processing in the circumstances provided for under the GDPR.
- The right to data portability, by requesting the transmission of personal data in electronic format to another data controller in a structured, commonly used and machine-readable format.
- The right to object to the processing of personal data.
- The right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise the rights described above, users may contact VITBIO through the contact details indicated above and, in particular, by email at info@vitbio.ai. Likewise, users will have the right to file a complaint with the competent supervisory data protection authority.

X. Withdrawal or Revocation of Consent

Users may object to the processing of their personal data and may withdraw any consent previously granted at any time where the processing is based on the data subject’s consent, without affecting the lawfulness of the processing carried out by VITBIO prior to such withdrawal. For this purpose, users may contact VITBIO by sending an email to info@vitbio.ai.

XI. Changes to the Privacy Policy

This Privacy Policy may be amended or updated periodically as a result of legal, regulatory or operational requirements, as well as improvements and changes relating to the manner in which the Services are offered and provided.

Any relevant amendment or update to this Privacy Policy may be communicated to users through the application, the VITBIO website, notifications or, where appropriate, through other reasonably appropriate communication channels.

VITBIO recommends that users periodically review this Privacy Policy in order to remain informed about the manner in which their personal data is processed and protected.