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PRIVACY POLICY FOR KAMLEON PLATFORM

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 the Council, dated April 27, 2016, regarding the protection of individuals concerning the processing of personal data and the free movement of such data ("GDPR") and Organic Law 3/2018, dated December 5, 2018, on the protection of personal data and guarantee of digital rights ("LOPDGDD"), below, Jungle Ventures S.L., the development company and operator of the Kamleon Platform, provides the user with information about the processing of their personal data carried out on the Kamleon Platform (hereinafter the "Platform").

The Platform 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 the data controller?

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 data processor.

When a User profile has Devices linked from different Device managers, each of them will be responsible for the data they process. In this regard, we inform you that Device Controllers access exclusively the 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 Platform user, you should know that the Controller may process your data based on the following purposes and legal bases:

User registration and management on the Platform

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

Once the User is created, the data will be used for profile management, allowing the addition, modification, or deletion of data while the User remains active.

Legal basis: Once the User is created, the data will be used for profile management, allowing the addition, modification, or deletion of data while the User remains active.

Optional profile data

Additionally, optional data such as height or weight is requested. These data are marked as optional for users, and if provided, they will be used for scientific-technical studies and to analyze the typology of users using the Device.

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

Device data

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

The aim is to provide the User and Device managers with basic information on important physical parameters relevant to physical well-being that allows detecting anomalies in the data collected and displaying alerts when values outside the determined normal ranges for a standard person of the User's characteristics are reached.

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

Consult the information on consent.

Platform query management

If you contact us to ask a question or file a complaint related to the Platform, 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 granted when formulating the query, complaint, or in the execution of a contract, if related to the service received.

Compliance with legal obligations

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

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

Commercial communications

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

Legal basis: The processing of User's personal data will be carried out based on the consent granted or based on legitimate interest, as the case may be.

Satisfaction and quality surveys

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

Legal basis: The processing of User's personal data will be carried out based on legitimate interest

From Kamleon, we may process anonymized data of Users to generate statistics and aggregated data that we will use to improve our services.

3. How long will we keep personal data?

Personal data will be processed for the period necessary to fulfill the purposes described in this Privacy Policy and comply with the obligations imposed by applicable laws, legal deadlines, 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's profile will be deleted once the User's 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 ensuring that there is adequate protection of personal data by using safeguards allowed by the regulations, such as the use of standard contractual clauses approved by the European Commission.

6. Data origin

The data collected are those provided by Users at the time of registration and those that can be collected during the User's life. The data necessary for sending invitations to Users are collected in advance by the Controller, and it is the Controller who guarantees their lawful origin.

7. Automated data processing

The use of the Device by the User implies that the data collected by the Device along with the data reported in the User's profile will be processed automatically, to calculate 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 incomplete data.

Right to request the deletion of your data.

Right to request the limitation of its processing: 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 that 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 it is technically possible.

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

The Controller processes data based on consent, and it should be noted that the User can withdraw consent at any time, without the withdrawal affecting the lawfulness of the processing carried out prior to the 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. Also, the User may file a complaint whenever deemed appropriate with 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 with the Controller.

9. Additional information

Policy on child use

The features of this campaign are exclusively for individuals over fourteen (14) years old. We do not deliberately collect information from individuals under fourteen (14) years of age. In this case, if you are a mother, father, or legal representative and believe that the minor has provided personal data through the Platform, contact us by sending an email to info@kamleon.com.

Links

The Platform 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's personal data will be carried out in accordance with this privacy policy. In the event that the Platform modifies its policies, the User will be adequately informed.

Update date: 25/03/2025