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PRIVACY POLICY FOR KAMLEON APPLICATION

If you're between 14 and 17 years old, we have a privacy policy explained for you at this link.

In compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of individuals with regard to the processing of personal data and the free movement of such data ("GDPR") and Organic Law 3/2018, of December 5, on the protection of personal data and guarantee of digital rights ("LOPDGDD"), below, Jungle Ventures S.L. as the developer and responsible for the operation of the Kamleon Application provides the user with information about the processing of their personal data carried out in the Kamleon application (hereinafter the "Application").

The Application allows users to link urinals that collect samples and perform analysis (hereinafter "Devices") to their Device user profile (hereinafter "User") to receive the results of the analyses provided by the Devices.

1. Who is responsible for the processing?

The data controller (hereinafter "Controller") will depend on the entity managing the data collected by the Device.

a) When the Device is owned by the User or directly managed by Kamleon, the Controller is:

IdentityJungle Ventures, S.L. (hereinafter "Kamleon")

NIF (National Identification Number)B55748586

Postal addressAvenida Paisos catalans, 18, 43007 Tarragona (Tarragona)

Email address info@kamleon.com

b) When the Device is managed by an entity that has registered the User, allowing them to link the Device to their profile and access the generated data, the data controller will be the entity identified as the managing entity of the Device at the time of linkage.

In this scenario, Kamleon will process User data as a processor.

When a User profile has Devices linked from different managing entities, each of them will be responsible for the data they process. In this regard, we inform you that Device Controllers exclusively access information collected from the Device or Devices they manage and will not access information generated on other Devices that may be linked to the User.

2. For what purpose and legal basis do we process personal data?

If you are a User of the Application, you should know that the Controller may process your data based on the following purposes and legal bases:

Application installation

For the correct installation and operation of the Application on the mobile phone or device chosen by the User, it is necessary to know and process certain technical information, such as the installed operating system or available memory space.

Legal basis: the processing of User personal data will be carried out based on legitimate interest.

User registration and management in the Application

For the User to access the Application, it is necessary to provide the data required for registration.

Once the User is created, the data will be used for profile management, which implies that data may be added, modified, or deleted while the User remains active.

Legal basis: the processing for the management of User registration will be carried out for the performance of a contract in which the User is a party (article 6.1.c) of the GDPR).

Optional profile data

Additionally, data such as height or weight are requested, these data are marked as optional for users and if provided, will be used to carry out scientific and technical studies and analyze the type of users who use the Device.

Legal basis: the processing of User personal data will be carried out based on the user's consent provided when providing non-mandatory data.

Device data

For each use that the User makes of a Device, they will receive in their profile the result of the urine analysis with values such as hydration percentage, electrolytes, or urine volume. These values are calculated taking into account information provided by the User.

It is intended to make available to the User and Device managers basic information on important physical parameters relevant to physical well-being that allow detecting anomalies in the data collected and showing alerts when values that fall outside the ranges determined as normal for a standard person of the User's characteristics are reached.

Legal basis: The processing of User physiological data, including, will be carried out based on the explicit consent necessary for the registration of the User with access to Devices.

See information on consent.

Application queries management

If you contact to ask a question or file a complaint related to the Application, your personal data will be used to respond and manage, if applicable, the query or complaint.

Legal basis: all processing of personal data related to a query or complaint will be carried out based on the User's consent given when making the query, complaint, or complaint, or based on the execution of a contract, if related to the service received.

Compliance with legal obligations

The processing of User personal data may be carried out to comply with legal obligations imposed on the Controller, including, where appropriate, communication to competent authorities.

Legal basis: the processing of User personal data will be carried out based on a legal obligation imposed on the Controller.

Commercial communications

Whenever there is a legal basis that allows it, User data will be used to send information about the Application and commercial communications informing about news or events organized that may be of interest.

Legal basis: the processing of User personal data will be carried out based on the consent given or based on legitimate interest, as appropriate.

Satisfaction and quality surveys

Kamleon may contact you, occasionally, to assess the level of satisfaction with the use of the Application and improve the quality of our products and services.

Legal basis: the processing of User personal data will be carried out based on legitimate interest.

Kamleon may process anonymized User data to generate statistics and aggregated data that we will use to improve our services.

3. How long will personal data be retained?

Personal data will be processed for the period of time necessary to fulfill the purposes described in this Privacy Policy and the obligations imposed by applicable laws, legal prescription periods, and for the formulation, exercise, or defense of claims, in which case, personal data will be duly blocked.

The physiological data collected by the Device and displayed in the User profile will be deleted once the User profile is deactivated.

4. To which recipients can your data be communicated?

Without prejudice to the fact that your personal data must be communicated under legal obligation to competent authorities, the Controller will communicate your personal data to third parties who process your personal data as data processors.

5. International transfers

We may transfer your personal information to a country outside the European Economic Area (EEA) when the processing is carried out by service providers who are considered data processors. Such transfers are always made to ensure that there is adequate protection of personal data by using the safeguards permitted by the regulations, such as the use of standard contractual clauses approved by the European Commission.

6. Data origin

The data collected includes the information provided by Users at the time of registration and any data that may be gathered throughout the User's lifetime. Only in cases where an invitation is sent to Users, the data required for the invitation will be previously collected by the Controller, who ensures its lawful origin.

7. Automated data processing

The use of the Device by the User implies that the data collected by the Device together with the data reported in the User's profile will be processed automatically, to perform the calculation and provide the results obtained from the analysis to the User.

8. What are your rights?

Right to request access to personal data: you can ask if we are processing your data, and if so, access it.

Right to request rectification if the data is inaccurate or complete the data we have incomplete.

Right to request the deletion of your data.

Right to request the limitation of its treatment: in this case, we will only keep your information for the exercise or defense of claims.

Right to object to the processing: we will stop processing personal data, except if they must continue to be processed for legitimate reasons or for the exercise or defense of possible claims.

Right to data portability: if you want your data to be processed by another data Controller, we will facilitate the transfer of your data to the new Controller, provided that it is technically possible.

Right not to be subject to a decision based solely on automated processing of your personal data.

Since the Controller processes data based on consent, you should know that the User can withdraw consent at any time, without the withdrawal of consent affecting the legality of the processing carried out prior to withdrawal.

To exercise your rights, you can contact the Controller through info@kamleon.com or in writing to the postal address indicated in point 1 of this privacy policy. Likewise, the User may file a complaint whenever deemed appropriate before the competent authority, in this case, the Spanish Data Protection Agency (https://www.aepd.es), especially when satisfaction of their rights has not been found before the Controller.

9. Additional information

Policy on child use

The provisions of this campaign are exclusively aimed at persons over fourteen (14) years of age. We do not knowingly collect information from children under fourteen (14) years of age. In the latter case, if you are a mother, father, or legal representative and believe that the minor has provided personal data through the Application, contact us by sending an email to info@kamleon.com.

Links

The Application may contain links to other websites that Kamleon considers of interest to the User. Please note that the Controller is not responsible for the processing of personal data that may be carried out by third-party owners of the domains of these links.

Updates

The processing of User personal data will be carried out in accordance with this privacy policy. In case the Application carries out a modification of its policies, the User will be informed accordingly.

Update date: 25/03/2025