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  1. Terms and Definitions
  2. "Application" means Lap, a mobile application, that is also the means by which the Personal Data of the User is collected and processed.
  3. "Cookies" means portions of code that is transferred to a User's mobile device assisting the Owner in providing the Service according to the purposes described. The User may find out more about the use of cookies on
  4. "Data Controller" (or "Owner") means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the Application. The Data Controller, unless otherwise specified, is the Owner of the Application.
  5. "Data Processor" means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
  6. "Data Subject" means the natural person to whom the Personal Data refers.
  7. "Personal Data" (or "Data") means any information that directly, indirectly, or in connection with other information – including a personal identification number – allows for the identification or identifiability of a natural person.
  8. "Usage Data" means information collected automatically through the Application (or third-party services employed in the Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use the Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
  9. "User" means the individual using the Application who, unless otherwise specified, coincides with the Data Subject.
  10. "Service" means the service provided by the Application as described in it and in the relative terms (if available).
  11. Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
  1. Types of Data collected
  1. Among the types of Personal Data that this Application collects, by itself or through third parties, there are: the name and a phone number of the User, Usage Data, Cookies and unique device identifiers for advertising (IDFA, for example). In addition, the Application collects, uses and share User location Data in order to provide location-based services. Most devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.
  2. Personal Data may be freely provided by the User, or collected automatically when using the Application.
  3. Unless specified otherwise, all Data requested by the Application is mandatory and failure to provide this Data may make it impossible for the Application to provide the Service. In cases where the Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
  4. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
  5. Any use of Cookies – or of other tracking tools – by the Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User.
  6. Users are responsible for any third-party Personal Data obtained, published or shared through the Application and confirm that they have the third party's consent to provide the Data to the Owner.
  1. Mode of processing the Data

A. Methods of processing

  1. The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
  2. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

B. Legal basis of processing

  1. The Owner may process Personal Data relating to Users if one of the following applies:
  1. provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  2. processing is necessary for compliance with a legal obligation to which the Owner is subject;
  3. processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
  1. In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

C. Retention time

  1. Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
  1. Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  2. Personal Data collected for the purposes of the Owner’s legitimate interests and compliance with a legal obligation to which the Owner is subject shall be retained as long as needed to fulfill such purposes.
  1. The Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
  2. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
  1. The purposes of Personal Data processing
  1. The purposes of Personal Data processing are as follows:
  2. To provide the Service.
  3. For remarketing and behavioral targeting. This type of service allows the Application and its partners to inform, optimize and serve advertising based on past use of the Application by the User. This activity is performed by tracking Usage Data that is transferred to the partners that manage the remarketing and behavioral targeting activity. The User may opt out of these practices by visiting the Network Advertising Initiative opt-out page. The User may also opt out from remarketing and behavioral targeting provided by Facebook, as provided here.
  1. The Owner may also provide User with information of commercial or promotional nature concerning other Owner`s products.
  1. Data transfer to third parties
  1. The Owner may share Personal Data with service providers for analytical, advertising and other purposes so that the Owner can better consider new features or otherwise tailor or enhance the Service, particularly:
  1. Data transfer outside the EU
  1. The Owner may transfer Personal Data to Data Processors around the world in accordance with this privacy policy. Personal Data collected by the Owner will be transferred to the United States, Israel and Ukraine for the purposes as described in this privacy policy. These data transfers are necessary to provide the Service to the User.
  2. The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below:
  3. Data transfer abroad based on standard contractual clauses. If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to "standard contractual clauses" provided by the European Commission. This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
  4. Data transfer abroad based on consent. If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards. In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
  5. Data transfer from the EU to the U.S based on Privacy Shield. If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. Privacy Shield. In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data.
  1. Further information about Personal Data
  1. Users declare themselves to be adult according to their applicable legislation. Minors may use the Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use the Application.
  2. The Application may send push notifications to the User.
  1. The rights of EU Users
  1. Users from the European Union ("EU Users") may exercise certain rights regarding their Data processed by the Owner. In particular, EU Users have the right to do the following:
  1. Object to processing of their Data. EU Users have the right to object to the processing of their Data.
  2. Access their Data. EU Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  3. Verify and seek rectification. EU Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  4. Restrict the processing of their Data. Where Personal Data is processed for legitimate interests, f. e. for direct marketing purposes pursued by the Owner, EU Users may object to such processing by providing a ground related to their particular situation to justify the objection.
  5. Have their Personal Data deleted or otherwise removed. EU Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  6. Receive their Data and have it transferred to another controller. EU Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on a contract which the EU User is part of or on pre-contractual obligations thereof.
  7. Lodge a complaint. EU Users have the right to bring a claim before their competent data protection authority.
  8. Any requests to exercise EU User rights can be directed to the Owner through the contact details provided in this document. These requests will be addressed by the Owner as early as possible and always within one month.
  1. Cookies
  1. This Application uses Cookies to save the User's session and to carry out other activities that are strictly necessary for the operation of this Application.
  2. Some of the services listed in Section 5 above collect statistics in an anonymized and aggregated form and may not require the consent of the User or may be managed directly by the Owner – depending on how they are described – without the help of third parties.
  3. With regard to Cookies installed by third parties, Users can manage their preferences and withdrawal of their consent by clicking the related opt-out link (if provided), by using the means provided in the third party's privacy policy, or by contacting the third party.
  4. Notwithstanding the above, the Owner informs that Users may follow the instructions provided on the subsequently linked initiatives by the EDAA (EU), the Network Advertising Initiative (US), Digital Advertising Alliance (US) and the DAAC (Canada) or other similar services.
  5. Since the installation of third-party Cookies and other tracking systems through the services used within this Application cannot be technically controlled by the Owner, any specific references to Cookies and tracking systems installed by third parties are to be considered indicative. In order to obtain complete information, the User is kindly requested to consult the privacy policy for the respective third-party services listed in this document.
  6. Given the objective complexity surrounding the identification of technologies based on Cookies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of Cookies by the Application.
  1. Data used through TrueDepth and ARKit API (only for iPhone X, iPhone XR, iPhone XS, iPhone XS Max and later)

Our eye traсking wellness assistant for iOS (App) uses the device's TrueDepth camera system through ARKit face tracking public API. This data is used only in order to track movement, position, blinking and winking of your eyes. This allows for the unique user experience — the app you can use with your eyes. In order for this functionality to be possible, the app requires access to your device's camera. This access can be toggled on or off at any time in your device's settings.

The ARKit API data is only used for user guiding purposes. This data is never stored locally or remotely. Camera access is required to start AR session for ARKit API to calculate eye position and state data. The only ARKit API data used is related to the movement, position and blinking of your eyes: whether they are in an "up", "down", “left”, “right”, "neutral" relative position or “blink”, “opened/closed eyes”.

This data is used on the device only for the duration of your current app session. Every time the app is closed, the data is deleted. This data is used to make your app experience more enjoyable.

ARKit API data is never stored remotely, given to third parties, or used for any non-guiding purposes. This data only remains on your device, and never leaves your device at any time.

A. Legal action

  1. The User's Personal Data may be used for legal purposes by the Owner in court or in the stages leading to possible legal action arising from improper use of the Application or the related Service.
  2. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

B. System logs and maintenance

  1. For operation and maintenance purposes, the Application and any third-party services may collect files that record interaction with the Application (system logs) use other Personal Data (such as the IP address) for this purpose.

C. How "Do Not Track" requests are handled

  1. The Application does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

D. Changes to this privacy policy

  1. The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within the Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. If a User objects to any of the changes to the policy, the User must cease using the Application and can request that the Owner remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Owner has about Users.

Last updated: October 17, 2019