Geberich OÜ offers this privacy policy (“Policy”) on the use of the mobile application “Idealis” (hereinafter – “Idealis App”), that allows you (hereinafter - the “User”), access to several functions described below.

This Policy describes what information Geberich OÜ collects and how that information is used. By using the Idealis App, the User confirms that he has read, understood, and unconditionally accepted the Policy. Any questions about the use of the Idealis App and the Policy can be directed by e-mail to: growapp@ver-us.com.

We use technical and organizational measures in order to protect confidential data against unlawful accidental or intentional manipulation, loss, destruction, alteration, dissemination or against access and other unlawful actions by unauthorized persons.

The mobile application “Idealis” is a commercial application distributed via online application stores. It does not however provide medical advice, and is intended for informational purposes only. The mobile application is not a substitute for professional medical advice, diagnosis or treatment. Never ignore professional medical advice in seeking treatment because of something you have read or see by using the mobile application “Idealis”. If you think you may have a medical emergency, address the healthcare specialists immediately.

Please read this disclaimer before applying any of the information received via the “Idealis” mobile app. Following the recommendations on altering habits and suggestions received online regarding possible causes of symptoms is not always without risk, even for healthy individuals. As a stand-alone measure such actions are not sufficient to prevent the development of any medical conditions or cure them outright.

You are responsible for Your health and safety at all times. You are not to use the Content of the Idealis App for any kind of exhaustive self-diagnostics or self-treatment.

Used Terms:

«Geberich OÜ», «Geberich», «We», «Our», etc. means Geberich OÜ, reg.# 12018330, with a registered office at Laeva tn 2, Kesklinna linnaosa, Tallinn, Harju maakond, 10111, an owner of the Idealis App and all related IP rights thereto;

«User», «You», «Your», etc. means a natural person downloading this mobile application «Idealis», having accepted the terms of its’ use and familiarized themselves with this Policy.

«Device» means Your portable/mobile device (i.e. smartphone, tablet, laptop etc.) using an iOs or Android operating system and technically fitting to install the Idealis App on and use it according to its’ functionality.

«Products» means the food supplements distributed by Neo Elementum OU (an Estonian company registered at the address: Järvevana tee 9, 11314 Tallinn, Estonia, reg#1431020).

1. Data gathered by Us.

We gather the following technical and personal data about You:

1.1. Technical data:

• IP-based location of the User – approximate location of the Mobile device You use to get access to the Idealis App.

• App interaction data – a list of events like running the application, clicking on banners or folders, following links or employing functions of Idealis App.

• Purchase data and Advertisment – data on types of subscription You elected and paid for, and of any interactions with goods and services ads and other content of Our third-party partners displayed on the Idealis App.

• Crash/Malfunctions data - Idealis App records the errors occurred during its’ use.

• User device ID and tech data, i.e. IP-address, mobile device model and identifiers (IDFA, GADID, IDFV, IMEI, MAC) – used to identify the User and compare the relevant User-related information. Gathered only if the User allows it. Note: We store the information in Our system and share or distribute it only to third persons who are bound to us by contract as our processors or are regulatory bodies empowered to inquire and receive such information.

1.2. User data:

• Gender, as set by the User in the Idealis App;

• User interests, as specified by the User when setting up the Idealis App, as chosen from the preset options in the in the Idealis App;

• Name;

• E-mail address and telephone number;

• Address of residence.

All provided data (except for that explicitly stated to be kept on the Your Device) can be forwarded to Our partners for the purposes of optimizing their advertising materials. Using the collected data, We may provide, maintain and develop existing services or create new ones. In addition, these data are needed to target Your wishes to receive content more accurately.

2. How We use collected data.

2.1. Use of technical data:

• IP-based location of the User – used to segment the Users based on their countries of residence for the purposes of internal analysis directed at improvement of User experience based on studying the popularity and frequency of using specific functions of the Idealis App.

• App interaction data, purchase data and Advertisement – processed jointly to facilitate internal research aimed at betterment of User experience by studying the User interaction with the application (use of buttons, screens and other interactive elements of the Idealis App).

• Crash/Malfunctions data - used by Us to analyze how the Idealis App functions and make improvements in further updates and versions of Our software.

• User device ID and tech data, i.e. IP-address, mobile device model and identifiers (IDFA, GADID, IDFV, IMEI, MAC) – used to track User’s cross-application interactions and to personalise the advertisements displayed via the Idealis App, provided the User allows such use of data (or, starting from the iOs 14.5 – when the User allows the cross-application tracking), and to provide additional segmentation of the Users based on their Devices used. This assists in internal analysis directed at improvement of User experience based on studying the popularity and frequency of using specific functions of the Idealis App.

2.2. User data:

• Gender, as set by the User in the Idealis App – used to acquire statistics on the audience of the Idealis App for marketing purposes, and to customize advertisements displayed to You while You are using the Idealis App;

• User interests, as specified by the User when setting up the Idealis App, chosen from the preset options in the in the Idealis App – used to assemble statistical data on the overall user interests, and to provide You with the recommendations on behavior alterations to improve Your condition, and to personalize materials depicted via the “Habits” and “Journey” functions.

• Name, E-mail address, telephone number, address of residence – used to form an order for purchase of Products via the Idealis App. The data is gathered by Geberich OU and transferred to Neo Elementum OU to be processed according to their Terms and Conditions and Privacy Poilicy of Neo Elementum OU, located at https://neoelementum.com/.

3. Transfer Of Your personal information.

Your information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. We will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your personal information will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

4. Disclosure of Your personal information

If We are involved in a merger, acquisition or asset sale, Your personal information may be transferred. We will provide notice before Your personal information is transferred and becomes subject to a different Privacy Policy. Under certain circumstances, we may be required to disclose Your personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

5. Retention of Your Personal Information

We will retain Your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your information to the extent necessary to comply with Our legal obligations (for example, if we are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

6. Information Regarding Your Data Protection Rights Under General Data Protection Regulation (GDPR)

For the purpose of this Policy, We are a Data Processor of Your personal information.

If You are from the European Economic Area (EEA), Our legal basis for collecting and using Your personal information, as described in the Policy, depends on the information We collect and the specific context in which We collect it. We may process Your personal information because:

• We need to perform a contract with You, when You download and use Our Idealis App;

• You have given Us permission to do so;

• The processing is in Our legitimate interests and it's not overridden by Your rights;

• To comply with the applicable law;

If You are a resident of the European Economic Area (EEA), You have certain data protection rights. In certain circumstances, You have the following data protection rights:

• The right to access, update or to delete the personal information we have on You;

• The right of rectification;

• The right to object;

• The right of restriction;

• The right to data portability;

• The right to withdraw consent;

Please note that We may ask You to verify Your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about Our collection and use of Your personal information. For more information, please contact Your local data protection authority in the European Economic Area (EEA).

7. Third-Party Disclosure

We do not disclose information about You to third parties, except when:

i) You expressly allowed the transfer of information. We may ask You for Your consent to transmit User data to third parties. We may also ask You for identification;

ii) the transfer of information is required under applicable law. Confidential information may be requested by public authority (for example, in the case of the delivery of justice or crime investigation). We will examine the powers of the public authority to receive information;

iii) the transfer of information occurs as a result of the legal succession of the Company (restructuring, etc). In that case information will be protected as it was before the succession;

iv) the recipient of the information is bound to Us contractually as our processor, and is obliged to keep received information confidential and secure as diligently as We would.

8. Privacy Policy Changes. Applicable Law

We may amend this Privacy policy from time to time. The revised Policy takes effect from the date of its posting, unless otherwise provided in the new version of the Policy. The Policy and the relationship between the You and the Company are subject to the laws of Estonia.

OUR DETAILS:

Geberich OU

Address: Laeva tn 2, Kesklinna linnaosa, Tallinn, Harju maakond, 10111

E-mail: growapp@ver-us.com