Privacy Policy

1. Information We Collect

We collect and process the following types of personal data:

• Identity & Contact Information: Name, email address, phone number.
• Analytics & Usage Data: IP address, device details, browsing behavior (collected via Google Analytics and similar tracking tools).

Some of this data is strictly necessary for providing our services (for example, creating an account or fulfilling user requests). If you choose not to provide the required data, you may be unable to access certain features or services. Providing other data (such as information for marketing communications) is voluntary, and you can opt out at any time.

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2. Identity of the Data Controller

Pheno AB is the data controller responsible for processing your personal data.

If you have any questions about this Privacy Policy or your personal data, you can contact us at:

• Email: team@pheno.health
• Address: Pheno AB, Döbelnsgatan 16B, 113 58 Stockholm, Sweden
• Web Form: https://www.pheno.health/contact

(Please mention “Data Protection” in your query.)

Pheno AB is registered in Sweden and acts as the data controller for all personal data processed via this website.

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3. Legal Basis for Processing Data

Under GDPR, we process personal data based on the following legal bases:

• Consent – For marketing communications and optional data collection.
• Legitimate Interest – For improving our services, security, and fraud prevention.
• Contractual Obligation – For fulfilling service agreements.
• Legal Compliance – When required by law.

Examples:

• Identity & Contact Data: Processed primarily to fulfill service agreements (contractual obligation) and, with your consent, for marketing communications.
• Analytics & Usage Data: Processed under our legitimate interest to improve the website and user experience.

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4. How We Use Your Data

We use the data we collect for the following purposes:

• To provide and improve our services – Including website performance optimization.
• Marketing & Communication – Sending relevant updates, promotions, and content (with user consent).
• Analytics & Research – Understanding user behavior to enhance user experience.
• Security & Fraud Prevention – Detecting, investigating, and preventing unauthorized access or breaches.

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5. Cookies & Tracking Technologies

We use cookies and tracking technologies such as Google Analytics to collect anonymized usage data. You can manage cookie preferences through your browser settings.

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6. Data Sharing & Third-Party Processors

We do not sell or trade your personal data. However, we may share data with:

• Service Providers: Google Analytics, cloud hosting providers, and payment processors.
• Legal Authorities: If required to comply with legal obligations.

These third parties process data under GDPR-compliant agreements ensuring security and privacy.

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7. Data Retention

We retain personal data for as long as necessary for its intended purpose or as required by law. Retention periods vary:

• Marketing Data: Until users withdraw consent.
• Account Data: While the user has an active account.
• Analytics Data: Retained for up to 26 months, after which it is anonymized.

If we cannot specify an exact retention period, we determine it based on criteria such as the nature of our relationship with you, the sensitivity of the data, and any legal or regulatory requirements. Once the applicable period has expired, we will either securely delete or anonymize your data.

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8. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Access – Request a copy of the personal data we hold.
• Correction – Request corrections to inaccurate data.
• Deletion – Request data deletion (subject to legal obligations).
• Objection – Object to data processing for marketing purposes.
• Portability – Request a structured copy of your data for transfer.
• Withdraw Consent – Opt out of marketing communications at any time.

To exercise any of these rights, please contact us at team@pheno.health or via https://www.pheno.health/contact. Please specify the right you wish to exercise and provide details to help us respond efficiently.

If you believe your data protection rights have been breached, you have the right to lodge a complaint with a supervisory authority, such as the Swedish Authority for Privacy Protection (IMY). You can find their contact details at https://imy.se.

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9. Data Security Measures

We implement technical and organizational safeguards to protect your data from unauthorized access, alteration, or misuse. However, no online service is completely secure, and we encourage users to take precautions when sharing personal data.

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10. Children’s Privacy

Our services are not intended for users under 18 years old. We do not knowingly collect personal data from minors. If a minor has provided us with data, we will take steps to delete it.

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11. International Data Transfers

If we transfer data outside the European Economic Area (EEA), we ensure adequate protection through:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• Other GDPR-compliant mechanisms ensuring lawful cross-border data processing.

You may contact us at team@pheno.health to request more information or a copy of the relevant transfer safeguards (e.g., SCCs) if applicable.

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12. Automated Decision-Making or Profiling

We do not rely on automated decision-making processes, including profiling, that produce legal or similarly significant effects. Should this change, we will update this Privacy Policy accordingly and provide all necessary information under the GDPR.

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13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be available at https://www.pheno.health. We will notify users of significant changes.

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14. Contact Us

For any privacy-related inquiries, you can contact us at:

• Email: team@pheno.health
• Address: Pheno AB, Döbelnsgatan 16B, 113 58 Stockholm, Sweden
• Web Form: https://www.pheno.health/contact
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Last Updated: March 18, 2025