Of course, we are aware that you provide us with highly sensitive personal information especially when using our Ovy App. Your health data is particularly protected since it is a so-called ‘special category of personal data’ according to Article 9 of the GDPR. We process your sensitive data only if you give us your explicit consent. Below you will find the content of the consent that we request from you as part of the registration and usage of the Ovy App. Therefore, if you tick the relevant Opt-in box during the registration process, you give us your consent to use your personal information as described in detail below. To use the Ovy App you must be at least 16 years old.
If you want more information, feel free to contact us at email@example.com.
1. Persons in charge
Company registered at: Hamburg
Local Court (Amtsgericht) of Hamburg, HRB 140562
Management board: Lina Wüller, Eva Wüller
VAT ID DE305785062
The data protection officer can be reached via the Ovy GmbH. In the following you find the contact details:
Name: Waldemar Kornewald
2. Processing of your personal data
The subject of this data policy is your personal data. ‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to information such as your name, postal address, e-mail address or telephone number, but also and especially information on cycle tracking and other data that we collect about you. In section 3.1 we explain to you which data we collect through the Ovy App and in section 3.2 we explain to you which data we collect through the website.
3. Your consent to process personal data that you have provided via the Ovy App
After setting up a profile in the Ovy app, your data will be saved on the Ovy GmbH servers in order to provide you with a backup function. When you sign up to the Ovy App and give us your consent, we collect, store and process the following information about you, if you chose to provide it:
- Profile data in the registration process including email address, an encrypted password, period dates and length, your age, average cycle lengths, intended use of the Ovy App, date of birth, possession of a basal thermometer, if and when you were on hormonal contraceptives. You can skip some of this information when setting up the Ovy App so it will not be tracked. The details can be found in the registration form. In addition, we store the device type of your smartphone, the operating system you use, the country from which you access the Ovy app, the language of the app you use and the time zone you are in.
- You can use both your real name or a pseudonym when creating your profile. In addition, we do not verify your email address, so you can use the Ovy App even without an active e-mail address. The e-mail address will only function as a user identification. You will solely need the email address later if you forget your login information and you would like to request a new password. This information will be sent to the e-mail address you entered during the onboarding process. Still, you will always be able to adjust this address in your profile
- Your settings data will be used by Ovy to save adjustments made by you. This includes all data entered in the registration process, activated reminders, and specific notifications. As a result, the Ovy app will function as you need it, even if you restore it after a backup.
- Cycle tracking data and general health information, including everything you add daily via the Ovy app. These include basal body temperature, cervical mucus, cervical condition, confounding factors, period, hygiene, pain, sexual activity, ovulation test results, pregnancy test results, illness, medication, notes, sleep, mood and activity.
- If you have set up a profile in the Ovy App, your data will be continuously stored on the Ovy’s servers in order to provide you with a backup function and additional functions within the scope of services.
Information on processing of data that we collect via the Ovy Website
- When you visit the Ovy website, our web server collects the following information: Your IP address, the website from which you were taken to our website (e.g. via a link), pages you visit on our website, the browser you use, your operating system, the date and duration of your visit.
- Furthermore, we process your personal data if you contact us via a contact form or if you place an order in our web shop. Your name, e-mail address and postal address are stored here.
3. Links to other website
Our website contains links to other websites of third parties. Ovy GmbH is not responsible for the privacy policies or the content of these third-party websites and cannot make any statements about the level of data protection prevailing on these third-party websites. Responsible is solely the respective site operator.
4. Purposes of processing your personal information
Below we would like to inform you about the specific purposes for which we process your personal data. These purposes vary, depending on whether we collect data through the Ovy App (section 5.1) or through the Website (section 5.2).
5. Purposes of processing data that we collect through the Ovy App
We need your personal information specified in section 3.1 in order to offer you all the functions of the Ovy App. For example, you should enter your health data in the Ovy App on a daily basis to get a reliable cycle prediction.
In addition, by admitting to the registration process, you agree that Ovy may store and process this information in order to generally improve Ovys’ services.
Furthermore, by giving your consent, you agree that we may send you information about Ovy’s offers (advertisement consent) and reminders via the Ovy App or to the email address you have provided.
Ovy may use your anonymized data for gynaecological research where Ovy warrants that such research data will neither be associated with you nor identify you in any way. Any information that identifies individuals will be removed. We may publish the results of internal research in the form of data visualizations or contributions in our own name. We would like to point out to you that we do not make this on the basis of your consent, but that this topic stands outside the applicability of the GDPR since we are dealing with anonymized data here.
Through your profile, you can access, review and change your personal data provided to Ovy at any time. You can enter new data yourself. Further rights can be found under section 8 (Affected rights).
The transmission of your information takes place via an encrypted connection.
Through your profile, you can access, review and change your data provided to Ovy at any time. You can enter new data yourself. Further rights can be found under in section 8 (Affected rights).
The transfer of your information happens via an encrypted connection.
6. Purposes of processing data that we collect through the Ovy Website
The IP addresses and other data collected when visiting our website in accordance with section 3.2 are processed by us for the following purposes:
- Ensuring a smooth connection to our website
- Ensuring comfortable use of our website
- Evaluation of system security and stability as well
- For further administrative purposes
You can create a customer account by registering on our website. With your customer account accessible through your email address and password of your choice, you have at all times access to your previous orders and you can control your personal data to process orders. You can also check out as a guest without setting up a customer account.
Upon request we delete your customer account. Until then, we will save the corresponding data without time limitation, so you have access to it at any time. We block data for specific orders when deleting the customer account after the completion of the order (expiry of the warranty period) and delete it after expiration of the statutory retention periods. The data which is entered as part of an order as a guest, we also lock after the completion of the order (expiry of the warranty period) and delete them after expiration of the statutory retention periods.
You can buy the Ovy Thermometer or other fertility products through our website. To purchase the Ovy Thermometer, fill in an order form stating the following information: first name, last name, address, telephone number and e-mail address (personal data). We use the data to fulfil the contract, in particular to deliver the thermometer and to contact you if we have any questions.
Furthermore, personal data such as first name, name, e-mail address via our website can be specified voluntarily to pre-order the Bluetooth Thermometer.
7. Disclosure of your personal data
8. Legal Basis
According to the GDPR, we are obliged to inform you about the legal grounds on which we base our data processing. We are happy to comply with this obligation.
As far as we carry out the processing of your data on the basis of your consent, which you give us in the course of the registration process, the legal basis is Article 6 (1) sentence 1 lit. a GDPR. In order to make it easier to understand which specific processing operations are based on your consent, we have clearly highlighted (in bold) the concept of consent in this document.
According to Art. 7 (3) GDPR, you have the opportunity to revoke your consent once given to us. As a result, we are no longer allowed to continue the data processing based on this consent for the future. However, it is unfortunately the case that, according to the GDPR, we are only allowed to process your health data on the basis of your consent. Therefore, we will not be able to provide you with any or at least not all functions of the Ovy App after your withdrawal.
Insofar as we process your data for the purpose of fulfilling a contract, in particular for the purchase of the thermometer or other fertility products via our website, the legal basis is Article 6 paragraph 1 sentence 1 lit. b GDPR.
9. Rights of the data subject
You have the following rights:
- in accordance with Article 15 GDPR to request information about your personal data processed by us. In particular, you have the right to obtain information on why we process data, the category of personal data we collect, the categories of recipients to whom your data has been disclosed, the planned retention period. You have the right to rectification, deletion, limitation of processing or opposition, the right to lodge a complaint, to find out the source of your data, if it was not collected from us, and the existence of automated decision-making including profiling and, where appropriate, meaningful information about their details.
- in accordance with Article 16 GDPR to immediately demand the correction of incorrect or incomplete personal data stored with us
- in accordance with Article 17 GDPR to erasure of your personal data held by us, except if the processing is required for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims
- in accordance with Article 18 GDPR to demand the restriction of the processing of your personal data as far as the accuracy of the data is disputed by you, the processing is unlawful, but you reject their deletion and we no longer need the data, but you assert this, Exercise or defense of legal claims or you have objected to the processing in accordance with Article 21 GDPR
- in accordance with Article 20 GDPR to receive your personal data provided to us in a structured, standard and machine-readable format or to request the transfer to another person responsible
- in accordance with Article 7 paragraph 3 GDPR to revoke your once given consent to us at any time (see above). As a result, we are not allowed to continue the data processing based on this consent for the future
- in accordance with Article 77 GDPR to complain to the supervisory authority of your habitual residence or place of work if you feel it infringes these Regulations.
Right of objection
If your personal data is processed accordance with Article 6 paragraph 1 sentence 1 lit. f GDPR is processed on our legitimate interests, you have the right to file an objection against the processing of your personal data in accordance with Article 21 GDPR. Still, this applies only if there are reasons for this arising from your particular situation or the objection is directed against direct mail. In the latter case, you have a general right to objection, which is implemented by us without requiring specification of any particular situation.
If you would like to exercise your right of revocation or objection, please send an e-mail to firstname.lastname@example.org.
10. Further guidance
Please be aware of the in accordance with Article 13 paragraph 2 lit. e GDPR to the following:
The provision of your personal data to us is not required by law. However, the specification of mandatory fields in the registration process is a prerequisite for a contract with us. You are not required to provide us with additional personal information. Not providing us with this information will not result in any negative consequence for you.
We assign you in accordance with Article 13 paragraph 2 lit. f GDPR: We do not process your personal information for the purpose of automated decision-making.
11. Data security
We use the widespread SSL (Secure Socket Layer) method for every website visit, in conjunction with the highest level of encryption supported by your browser. In general, this is a 256-bit encryption. If your browser does not support 256-bit encryption we’ll use 128-bit v3 technology instead. Whether an individual website of our website is encrypted is shown by the closed representation of the key or lock icon in the lower status bar of your browser.
We also take appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or total loss, destruction or against unauthorized access by third parties. We are continuously improving our security measures in line with technological progress.
12. Storage and deletion of the data
On quarterly basis, we check whether the data transmitted to us is still needed for the information exchange with you. Data that is no longer needed will be deleted by us immediately, provided that no statutory storage periods are in place.
We reserve the right to have medical data such as cycle lengths and body signals stored in anonymous form on the servers of Ovy GmbH (for details see section 5.1 above). However, this data cannot be assigned in any form to a person and is used solely for research purposes. If you want to delete your data yourself, you can do this in the Ovy App in your profile independently. You can also withdraw your consent at any time by requesting that Ovy deletes your account for you. To do so please write an email to email@example.com and put “Deletion of personal data” in the subject heading.
Please be aware that once you decide to delete your data, we will not be able to restore that data.
13. Data protection
If you have an account in the Ovy App, your personal information about yourself and your cycle, as well as the information added on a daily basis, will be stored separately. Thereby we guarantee a very high security of your data. Your password is stored encrypted.
When transferring your data between your device and Ovy’s servers, the HTTPS protocol is used for encryption. HTTPS is the same technology used to make secure connections to your web browser and is indicated by a padlock icon in the browser.
While we cannot guarantee that there will never be misuse, loss or alteration, we make every reasonable effort to protect your personal information in our power from misuse, loss and alteration.
We take reasonable action to ensure the security of your personal information in a technically feasible and reasonable manner. Your data will be carefully protected against loss, destruction, falsification, manipulation and unauthorized access or disclosure.
14. Age restriction for the use of the services of Ovy (Article 8 GDPR)
Ovy does not collect and use personal information from children under the age of 16. When registering for an Ovy Account, you must confirm that you are at least 16 years old. If Ovy becomes aware that this information is incorrect, we reserve the right to delete this information immediately. The use of the Ovy App is therefore only permitted at the age of 16 or older.
15. Data transfer outside of the EU and third-party applications (Chapter 5 GDPR)
All personal information that you collect may only be transferred to countries outside the European Union / European Economic Area (EEA) if in compliance with applicable privacy policies, and to ensure that your privacy is protected.
As a startup, we depend on working with cooperation partners or investors. It is also possible to merge with a company later on (for example as part of an acquisition). In the context of such cooperation and transactions, it may be necessary to disclose the data provided by the users to investors, cooperation partners, acquirers or other third parties. By using our app, you hereby agree. Even in such cases, we will handle all data in a highly sensitive manner and resort to statistical, aggregated, pseudonymous or anonymized data.
Apple Health (iOS)
Ovy will not share personal information with Apple’s Health App without your prior consent. The approval will be granted by you in the corresponding settings of the Health app or in the Ovy app during the initial configuration of the user profile or via the Ovy app settings. The consent can be withdrawn at any time. Once you have given your consent, Ovy will be able to interact with the Health app on your iOS device and read and / or write information between the Ovy App and Health. This may include the transfer of your personal information to Apple servers outside the European Union. You can choose whether and to what extent your personal information is shared between Ovy and Apple Health by granting or revoking appropriate permissions in Apple’s Health App settings. For more information, see the Apple Health privacy information.
Google Fit (Android)
Ovy will not share personal information with Google Fit without your prior consent. This approval will be granted by you in the appropriate settings of Google Fit or in the Ovy app during the initial configuration of the user profile or via the Ovy app settings and can be revoked by you at any time. Once you’ve given your consent, Ovy can interact with Google Fit on your Android device and read and / or write information between the Ovy App and Google Fit. This may include the transfer of your personal information to Google servers outside the European Union. You can choose to share your personal information between Ovy and Google Fit by granting or revoking permissions in the Google Fit settings. For more information, see the Google Fit privacy information.
We use the functions of the web analytics service Google Analytics. Provider is Google Inc. 1600 Amphitheater Parkway Mountain View, CA 94043, USA. Google Analytics uses so-called “cookies”. These are text files that are stored on your device and that allow to analyze the use of the app or Ovy website by you. The information generated by the cookie about your use of this app is usually transmitted to a Google server in the United States and stored there. However, if IP anonymization is enabled in our app, Google will truncate your IP address beforehand within member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. Google will use this information to evaluate your use of the app, to compile reports on website activity, and to provide us with other services related to the use of the app and internet usage. The IP address sent from your device as part of Google Analytics will not be merged with any other data provided by Google. You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent your data from being collected on future visits to this site You can also avoid Google retargeting by clicking this link and choose to Opt-out.
Cycle sharing with third parties
You can share your Ovy Account data with external persons. Contacts with which you share your cycle will see your past, present and future periods, ovulations, fertile phases and possibly other body signals. You can revoke your consent at any time by removing the approval or contacts. This removal takes place immediately.
You can prevent the storage of cookies by adjusting the settings of your device accordingly. However, we point out that in this case, you may not be able to use all the features of this app in full. In addition, you can prevent the collection of data generated by the cookies and related to your use of the app (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link.
17. Social Media Plugins
On our website and in the Ovy App, we use buttons (“plugins”) of different social networks through which you can make use of the interactive possibilities of the social networks you’re using on our website. These plugins provide different functionalities. These are determined by the providers of social networks.
By activating the social media buttons, you agree to the transfer of your data to the respective network. The social media providers based in the USA may have a different level of data protection than in the EU member states, i.a. due to legal access rights of state authorities.
Please note that Ovy is not a provider of social networks and has no control over the data processing by the respective service providers. More information about the individual plugins can be found on the websites of the respective operators.
Within our offer, due to our legitimate interests in the analysis, optimization and economic operation of our online offer and for this purpose, the so-called Facebook pixel of the social network Facebook, operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2 , Ireland (“Facebook”) is being used.
With the help of the Facebook pixel, it is on the one hand possible for Facebook to identify the visitors of our offer as a target group for the presentation of advertisements, so-called “Facebook ads” or “Instagram ads”. Accordingly, we use the Facebook pixel to display the Facebook ads we have posted only to those Facebook users who have also shown an interest in our offer or who have certain characteristics (e.g. Interests in certain topics or products that are determined by the websites visited) that we submit to Facebook (so-called “custom audiences”).
With the help of the Facebook pixel, we also want to make sure that our Facebook ads are in line with the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also understand the effectiveness of the Facebook ads for statistical and market research purposes, in which we see whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion”). Based on data collected via our web shop, e.g. e-mail addresses, we create “lookalike audiences” to reach interested parties with our offers.
For our advertising, we use the services of the company AdRoll, 972 Mission St., 3rd Floor, San Francisco, CA 94103, USA. AdRoll helps us to show you our ads on other websites. AdRoll specifically targets users who have previously shown interest in our offer. To do this, AdRoll stores a cookie on your computer to better understand your interests. No personal data is stored. You can object to the anonymous analysis of your surfing behavior and the display of interest-based advertising by clicking on the opt-out button. For more information about AdRoll data collection, processing, and usage, visit.
This website uses Hotjar, an analysis software of Hotjar Ltd. (“Hotjar”), 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta, Europe). With Hotjar, it is possible to measure and analyze the usage behavior (clicks, mouse movements, scroll heights, etc.) on our website. The information generated by the “tracking code” and “cookie” from your visit to our website will be transmitted to the Hotjar servers in Ireland and stored there. The tracking code collects the following information:
Device dependent data. The following information may be recorded through via your device and your browser: IP address of your device (collected and stored in an anonymous format), e-mail address including your first and last name, assuming you have provided it on our website, screen size of your device, device type and browser information, geographic viewpoint (country only), the preferred language for displaying our website. The following data is automatically generated by our servers when Hotjar is used: Referring domain, visited pages, geographic location (only the country), the preferred language to represent our website, date and time when the website was accessed.
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Automatically collected information
For reasons of system security and to detect and track inadmissible access attempts and access to our app or our web server, certain information is automatically collected and stored in a log file. This happens as soon as you download our app, visit the website, or retrieve content.
This automatically collected information in the app includes: your smartphone’s device number, operating system, software version used, the date and time of usage and the error logs. This automatically collected information on the Ovy website includes: browser type / version, operating system used, referrer URL, IP address or host name of the accessing computer, date and time of the request, visited subpages, device type (mobile / web) and location. The storage of this data is done to ensure the stability and reliability of the app and to detect cases of abuse. This data is also deleted or overwritten on a quarterly basis, providing that there has been no suspicion of unlawful access to our app. The analysis of the automatically collected data only takes place in the case of such suspicion and only by authorized persons for purposes of data protection control, data storage or to ensure the proper operation of a data processing system. If you contact our service by sending an e-mail to the support team, e.g. to communicate with Ovy at firstname.lastname@example.org or otherwise, we will record the communication history as well as the information you send in this context (e.g., e-mail address). This ensures that we can process requests and provide appropriate support.
19. Newsletter, Advertising
Ovy uses your personal information, such as your email address and name, to contact you with messages, emails, and newsletters. These include push notifications and in-app messages, health-related information sent to you by email and occasional promotional material that may be of interest to you and can also be sent via email.
Such services will only be provided to you if you have signed up for the newsletter service separately or have given your consent to these notifications. You can withdraw your consent at any time from both. You can unsubscribe from our newsletter by clicking the unsubscribe link at the bottom of the message and disabling notifications sent by Ovy to your device settings.
For the sending of newsletters, we ask for a separate consent specifically for the newsletter dispatch. This consent is completely independent of the consent given to us for the purposes of using the Ovy App. If you do not give us consent for the sending of the newsletters or revoke it, this has no influence on the use of our app. We only engage in advertising beyond newsletters if we are legally entitled to do so.
To provide these services, Ovy may forward information such as your email address to third parties to perform such newsletter service or notifications. These providers are Rocket Science Group LLC (“MailChimp”), based in Atlanta, USA, which processes your email address, name, and usage information to email informative and occasionally commercial content about Ovy; Leanplum Inc. (“Leanplum”), based in San Francisco, USA, which processes your email address and a user ID to send in-app messages, information and occasionally commercial content for Ovy via email; and Message Systems Inc. (“SparkPost”), based in San Francisco, USA, which processes the names and email addresses, as well as the personal information that may be contained in transactional emails (for example, “I have lost my password” or “confirm your account”).
20.Links to other websites
Our app contains links to other websites of third parties. Ovy GmbH is not responsible for the privacy policies or the content of these third-party websites and cannot make any statements about the level of data protection prevailing on these third-party websites. Responsible is solely the respective site operator.
Ovy is operated by Ovy GmbH. To exercise your rights, please contact:
c/o We Work
Data protection officer: Waldemar Kornewald, email@example.com
Date of last change 18th of May 2018