Visooma Glaucoma App – Privacy Policy

Our Commitment to Privacy

This digital application (“Visooma“ or “App“) is manufactured and distributed by BAYOOCARE GmbH, Europaplatz 5, 64293 Darmstadt, Germany (“BAYOOCARE“, or “we”, “us”, “our”). By using the App, you share personal data with BAYOOCARE.

We recognize the importance of, and are fully committed to protecting the privacy of personal data related to all individuals with whom we interact. This Policy is designed to assist you in making informed decisions when using the App or interacting with us.

You are recommended to read this Policy carefully before disclosing any personal data. By giving your consent to data processing, you agree to the collection, use and disclosure of your personal data in accordance with this Privacy Policy.

Data Controller / Data Protection Officer

Data Controller

BAYOOCARE processes your data as data controller in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation (“GDPR”)

Data Protection Officer

We hope this privacy policy answers your questions about the processing of your personal data. If you have any further questions, you can reach us at any time at the address given above or contact our data protection officers

Scope of this Policy

This Policy is specifically intended for persons diagnosed with Glaucoma and interested in using the App to access education resources relevant to eye disease Glaucoma.

Personal Data we collect

When you use the App, it may collect and process the following personal data:

a. Personal Data directly provided by you and processed by BAYOOCARE, with Bornholdt Lee GmbH, ABC-Straße 21, 20354 Hamburg, Germany (“Bornholdt Lee”) as a data processor on behalf of BAYOOCARE.

b. Personal Data collected automatically

Personal data related to you may be also collected automatically by your use of our App or whenever you choose to disclose it by updating your User Profile information, completing our “Contact Us” online form or whenever you choose to send us an email.

Such data, indirectly collected, include but is not limited to the following

Purposes and Legal Bases for Data Processing and any Legitimate Interests pursued

We process your data to the extent described below, for the purposes stated in each case and on the legal basis stated in each case. Processing may be based on several legal bases. If one of the legal bases no longer applies, e.g., because you withdraw your consent or object to the processing of personal data, the processing of your personal data may still be lawful based on another legal basis.

You are not obliged to provide us with your personal data. However, if you decide not to provide us with your data, or only to provide us with part of it, you will unfortunately not be able to (fully) use our services where such services require the use of certain data.

In addition to the GDPR, applicable law includes inter alia the supplementary provisions of the German Federal Data Protection Act (“BDSG”) and the Telecommunications Digital Services Data Protection Act (“TDDDG”).

Download of the App

In order to use our App, you must download it from the Google Play Store or the Apple App Store, or from www.visooma.com, the latter of which will contain a link to the Google Play Store and Apple App Store. By downloading the App, certain personal data required for this purpose will be transferred. In particular, your email address, your user name, the customer number of the downloading account, your individual device identification number, payment information and the time of the download are transmitted to the respective App store when you download the App.

We have no influence on the collection and processing of this data, which is carried out exclusively by the app store you have selected. Accordingly, we are not responsible for this collection and processing; the app store is solely responsible for this. Further information on this data processing can be found in the privacy policy of the respective app store operator.

User Account

When you register for a user account (“Account”) and log in, we collect your email address, and a password assigned by you as master data. We only use this data to enable you to use the app and, in particular, to clearly assign the usage data linked to your account to you and to send you important contract-relevant notifications and statements. Any further use will only take place with your express consent. In addition, during the register process, you are asked to share your health related data (e.g. diagnosis, visual field values). Such data is categorized as special category of personal data according to Art. 9 para 1 GDPR.

Your registration for an account is complete when you accept the terms of conditions in the App and we have confirmed your registration by means of a double opt-in procedure. This procedure is necessary to protect your user account.

Through your registration, your data will also be used to manage our relationship, interactions and communication with you, for example to respond to your questions, comments or requests. Your personal data is required to provide you with access to our services.

The processing takes place for the execution of the contract with you, Art. 6 para 1 lit. b GDPR, and on the basis of your consent in case health data is processed, Art. 6 para 1 lit. a GDPR and Art. 9 para 2 lit. a GDPR.

Usage of App

We offer you the opportunity to use our services within the scope of the App and its different applications relating to Glaucoma and treatment adherence. Our service comprises i.e., sending you reminders to take your eye drops and push notifications if you have not used the App for some time. In addition, the App will track and analyze your usage behavior in the App and will provide you with related information, e.g. how many articles you have read and how often you have used your eye drops.

While using the App, you are asked to share different kinds of data, including personal data and health related data. Your health data is processed to enable the proper use of the App, for example to remind you to use your eye drops.

Legal basis for the processing of your health data is your consent, Art 9 para 2 lit. a GDPR. The processing of your personal data for the execution of the contract with you is based on Art. 6 para 1 lit. b GDPR.

Technical Services and Data Security

Your digital data (such as the time and date of login, IP address, device type and version, time zone setting) is processed for technical reasons to provide the services and to ensure system security and stability. BAYOOCARE also uses your data to monitor the proper functioning of the platform and information about its use, and to further develop it to ensure that content from the App is displayed as efficiently as possible for you and your device. The legal basis for the processing of personal data for this purpose is our legitimate interest in the functionalities of our services, their proper performance and system stability and security. The legal basis in this respect is Art. 6 para 1 lit. f GDPR. In addition, if health data is processed, legal basis is your consent, Art. 6 para 1 lit. a GDPR, Art. 9 para 2 lit. a GDPR.

Support Request

If you send us email inquiries (e.g., about support matters or our services) or contact our support team by telephone, we will use the data you provide to receive and process your inquiry, Art 6 para 1 lit. b and lit. f GDPR. In addition, if health data is processed, legal basis is your consent, Art. 6 para 1 lit. a GDPR, Art. 9 para 2 lit. a GDPR.

Improvement of our Services

BAYOOCARE processes data about your use of the App and services, as well as your contact details if you have provided them as part of your support request, in order to improve our services. We may use your data for data analysis, identifying usage trends, to evaluate our services, and your experience. When your data is used for this purpose, it is used in aggregated or anonymized form. In addition, your data is used for the purpose of proof of positive care effects.

The legal basis for the processing of personal data for this purpose is our legitimate interest in continuously improving our services, Art. 6 para 1 lit. f GDPR. In addition, if health data is processed, legal basis is your consent, Art. 6 para 1 lit. a GDPR, Art. 9 para 2 lit. a GDPR.

Combating Abuse

Your personal data may also be used to prevent, deter or investigate misuse of our services or criminal offenses against us. Abuse includes, but is not limited to, fraud, sending spam, harassment and other actions that are prohibited by law.

The legal basis for the processing of personal data for this purpose is our legitimate interest in preventing and investigating the misuse of our services or criminal offenses against us and the fact that your interests, rights and freedoms, which require the protection of your personal data, do not prevail, Art. 6 para 1 lit. f GDPR. In addition, if health data is processed, legal basis is your consent, Art. 6 para 1 lit. a GDPR, Art. 9 para 2 lit. a GDPR.

Fulfillment of Legal Obligations

We also have to process your personal data if we are obliged to do so by law, by judgment or on the basis of official decisions. The purpose of this processing of personal data is to ensure that we comply with our legal obligations. The legal basis for this is Art. 6 para 1 lit. c GDPR, Art. 9 para. 2 lit. f GDPR and according to medical device law, Sec. 29 Medical Devices EU Implementation Act (“MPDG”).

Cookies

The App does not use Cookies.

Storage Duration

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Disclosure of your Personal Data

Your personal data will not be disclosed to unspecified recipients. BAYOOCARE will provide your personal information to the following recipients only to the extent permitted, if they need to know the information in order to pursue legitimate business objectives and as required by applicable law:

The legal basis for the transfer of your data is the legal basis applicable to the respective business purpose.

In addition, we may, in individual cases, pass on your personal data with your express consent in accordance with Art. 6 para 1 lit. a, Art. 9 para 2 lit. a GDPR.

Third Countries

We intend to transfer your data to the following third countries:

The transfer of your data to Switzerland is based on an adequacy decision of the European Commission pursuant to Art. 45 para 1 and para 3 GDPR.

Your Data Protection Rights

This section describes your rights as a user of our App and services. You can assert these rights at any time by contacting our data protection officers via Mail or by letter:

Right to Withdrawal

You have the right to withdraw your consent at any time. Withdrawing your consent does not affect the legitimacy of the processing carried out on the basis of the consent until the withdrawal, Art. 7 para 3 GDPR.

Right to Access

You have the right to obtain information from us at any time upon request about the personal data relating to you that we process within the scope of Art. 15 GDPR. To assert your aforementioned right, please contact us at the address given above. The information will then be provided in the form of an extract stating which personal data we process, the purposes for which we process the data, where the data comes from, to which third parties the data has been transferred and how long the data will be stored.

Right to Rectification

You have the right to request that we rectify your personal data without undue delay if it is incorrect. To do so, please contact us at the contact address given above, Art. 16 GDPR.

Right to Erasure

You have the right to obtain from us the erasure of your personal data under the conditions described in Art. 17 GDPR. In particular, these conditions provide for a right to erasure if the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, as well as in cases of unlawful processing, the existence of an objection or the existence of an obligation to erase under Union Law or the law of the Member State to which we are subject. To assert your aforementioned right, please contact us at the addresses given above.

Right to Restriction of Processing

You have the right to request restriction of processing in accordance with Art. 18 GDPR. This right exists in particular if the accuracy of the personal data is disputed between you and us, for the period required to verify the accuracy, as well as if you request restricted processing instead of deletion in the case of an existing right to deletion; furthermore, in the event that the data is no longer required for the purposes pursued by us, but you need it for the assertion, exercise or defense of legal claims and if the successful exercise of an objection between us and you is still disputed. To exercise your abovementioned right, please contact us at the addresses given above.

Right to Object

In accordance with Art. 21 GDPR, you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data relating to you, which is based, inter alia, on Art. 6 para 1 lit. e or lit. f GDPR. We will stop processing your personal data unless we can demonstrate compelling legitimate interests for the processing that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.

You also have the same right in the case of direct advertising, without the need for special reasons. In this case, we will cease processing your personal data for direct marketing in any case upon your objection.

Right to Data Portability

You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format in accordance with Art. 20 GDPR. To assert your above right, please contact us atdataprivacy@bayoo.net.

Right to Lodge a Complaint with a Supervisory Authority

If you have any questions or complaints about the processing of your personal data, you can contact our data protection officer at dataprivacy@bayoo.net anytime. You also have the right to lodge a complaint with the competent supervisory authority, Art 77 GDPR:

The Hessian Commissioner for Data Protection and Freedom of Information (Der Hessische Beauftragte für Datenschutz und Informationsfreiheit)
Gustav-Stresemann-Ring 1
65189 Wiesbaden
Telephone: +49 (0)611-1408 0
E-Mail: poststelle@datenschutz.hessen.de
Website: https://datenschutz.hessen.de/service/beschwerde-uebermitteln

Status and Changes

We reserve the right to amend this Policy from time to time in accordance with legal requirements to reflect technological advancements and changes in legal and regulatory requirements and our business practices. When we amend the Privacy Policy, such amendments will be reflected in an updated version of this Policy by publishing current versions with the effective date at the end. Therefore, we encourage you to periodically visit the App and our website to continue to be informed about how we use your personal information.

Contact Details

If you have any further questions about this Policy or if you would like to receive further information about our privacy practices, please contact us via dataprivacy@bayoo.net.

Status: September 2025
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