Privacy policy

PRIVACY AND COOKIES POLICY APPLICABLE TO WEBSITES AND SOCIAL NETWORKS

Version of 17.03.2026

1. PREAMBLE

This privacy and cookies policy applicable to websites and social networks (the “Privacy Policy”) describes how your information is processed in connection with the website <https://vivengo.ch> (the “Site” or “Website”) and with our pages available on the networks managed by Vivengo SA (“Vivengo”, “we”, “us”), whose registered office is located at Rue du Pâquis 11a,1033 Cheseaux-sur Lausanne.

Please read this Privacy Policy carefully before using the Websites and our social networking pages. This Privacy Policy explains how information relating to an identified or identifiable person (“Personal Information”) is collected, used and protected.

If you access our pages available on social networks, as well as other third-party websites from our Sites, the information you provide will be subject to the privacy policy of the third party concerned.

By browsing the Website, you acknowledge and agree to the processing of your Personal Data as described in this Privacy Policy. If you do not agree to your Personal Data being processed in accordance with the terms of this Privacy Policy, please do not use the Websites or our pages available on social networks.

2. DATA CONTROLLER

Vivengo SA acts as data controller for the processing of Personal Data collected via its Websites and its dedicated pages on social networks.

3. GENERAL PRINCIPLES

3.1 Our Websites and our pages available on social networks contain the following information and services:

(i) information about our institution and its activities ;

(ii) different ways to contact us;

(iii) the possibility of creating a user account;

(iv) links to other third-party websites and the possibility of sharing content on social networks and other applications (such as e-mail).

3.2 This Privacy Policy does not apply to offline services.

4. PERSONAL DATA WE COLLECT AND PURPOSES OF COLLECTION

Collection sources

4.1. The Personal Data we collect through our Websites and our pages available on social networks fall into two categories:

(i) Cookies (infra B.) ;

(ii) Personal data you provide to us (infra C.).

Cookies

What are cookies and what information do they collect?

4.2. Cookies are files containing a small amount of data that are sent from a website to your browser and stored on your device (computer or mobile device). Other tracking technologies, such as beacons, tags, and scripts (the “Similar Technologies”), may also be used to collect and track information and to improve and analyze our Websites.

4.3. By means of Cookies and similar Technologies, we may collect Personal Data when you visit our Websites or our pages available on social networks. In particular, we may identify certain usage data when you browse or click on content.

4.4. The following information and Personal Data are collected by means of Cookies and similar Technologies:

(i) the IP address of the device capable of connecting to the Internet and requesting connection ;

(ii) the date and time of the connection;

(iii) localization, if activated on the device;

(iv) the resources you access on the Websites;

(v) the name and URL of the file consulted ;

(vi) the website/application from which the connection was established (reference URL) ;

(vii) the browser you use and, if necessary, the operating system of your device capable of accessing the Internet, as well as the name of your access provider.

4.5. To control/limit the collection of this information, you can :

(i) if available, set your browser to refuse all Cookies and similar Technologies or to indicate when a Cookie or similar Technology is being used; or

(ii) delete Cookies and similar Technologies and clean up your browsing data directly from your browser settings.
If you do not accept certain Cookies or similar Technologies, you may not be able to access certain features of our Websites.

For what purposes do we collect information using Cookies (purposes)?

4.6. We use Cookies and similar Technologies that we collect in order to :

(i) authorize access to our Websites;

(ii) to make certain functionalities of our Websites accessible and to offer you additional functionalities;

(iii) to improve the Websites and our pages available on social networks;

(iv) ensure the security of the Websites;

(v) to create statistics on the use of our Sites in order to improve them.

Reason for treatment

4.7. In the case of Cookies and similar Technologies that are necessary for the operation and maintenance of our Websites, the grounds on which we justify the processing of your Personal Data is our overriding private interest in the operation of our Websites and their functionalities.

4.8. In the case of Cookies and similar Technologies used for statistical purposes in connection with our Websites, the basis on which we process your Personal Data is your consent, obtained by means of the Cookies banner displayed on each of our Websites.

Personal data you provide

4.9. We collect Personal Data from you on a voluntary basis when, through our Websites, you :

(i) fill in a form allowing you to contact us, such as the contact form or newsletter form

4.10. This Personal Data may include your first and last name, your e-mail address, the Personal Data you choose to send us in connection with this account (such as your title, last name, first name, postal address, telephone number, e-mail address, and language preference).

For what purposes do we collect Personal Data?

4.12. We use the Personal Data you provide for the following purposes:

(i) to enable you to participate in the interactive features of the Websites where you so wish;

Reason for treatment

4.13. The grounds on which we justify the processing of your Personal Data are: your consent when you participate in the interactive features of the Websites (for example by registering for an event), an overriding private interest when we reply to your messages received via the contact form, you create an account.

5. PERSONAL DATA COLLECTED BY THIRD PARTIES (LINKS TO OTHER WEBSITES OR SOCIAL NETWORKS)

5.1. This Privacy Policy does not cover how your Personal Information is handled by third parties when we link to their websites. We encourage you to read the privacy policies of other websites you visit.

5.2. When you establish a connection with a social network or other website, your browser connects directly to the server of the relevant service provider. Through this connection, the website receives the information accessed by your browser on the corresponding page of our Websites or on our pages available on social networks. This information (including your IP address) is transmitted from your browser directly to the service provider’s server and stored there. If you interact with our pages available on social networks, for example by clicking on the “Like” or “Share” icon, this information will also be transmitted directly to the server of the relevant social network provider and stored there.

5.3. Please refer to the privacy policy of the relevant social network or website for any information in connection with the purpose and scope of the collection of Personal Data by the relevant service provider, the further processing and use of such Personal Data by the relevant service provider, as well as the related rights and setting options to enable the protection of your Personal Data.

6. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

6.1. We may give access to the Personal Data you have communicated to us through our Websites or our pages available on social networks to certain independent co-contractors and affiliated companies in order for them to assist us in the operation of said Websites or said pages available on social networks. To date, these contractors are as follows:

(i) Service provider operating the Site : Vivengo SA, located in Switzerland ;

(ii) Site host : Infomaniak Group SA, located in Switzerland;

6.2. We take all necessary steps to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and applicable law. All our co-contractors undertake to protect Personal Data using procedures similar to ours, unless otherwise provided for in this Privacy Policy.

6.3. The purpose of sharing your Personal Data with the aforementioned third parties is to ensure our business, as well as to maintain and seek to constantly improve our Websites and the services offered to our users. Thus, the justification for this processing is that of our overriding private interests.

7. COMMUNICATION OF YOUR PERSONAL DATA TO THE AUTHORITIES

7.1. We may disclose your Personal Data (including your communications) if we consider this necessary for security reasons, to investigate a potential breach or any other violation of this Privacy Policy and/or to prevent harm that may be caused to other users of our Websites or our pages available on social networks. Consequently, we may need to communicate your Personal Data in order to investigate, respond to or resolve a complaint or dispute in connection with our Websites or one of our pages available on a social network.

7.2. We may be required to disclose your Personal Data where we are required to do so by law or where we believe in good faith that such disclosure is necessary in order to:

(i) to investigate, prevent or take action in relation to potential or actual illegal activities or to assist the administrative enforcement authorities;

(ii) to perform an agreement between us and you;

(iii) investigate and defend us against third party claims or allegations;

(iv) protect the security and integrity of our Websites or our pages available on social networks; or

(v) exercise and protect the rights and safety of our users, employees or others.

7.3. We endeavor to notify users of third-party requests for their Personal Data where this seems appropriate from our point of view and where it seems technically feasible, except where we are prohibited from doing so by law or by a decision of an authority, or where the request suffers from an emergency. We may contest such requests where, in our sole discretion, we consider that they are formulated too broadly, are too vague or are unfounded, but we do not guarantee to contest any request.

7.4. The purpose of sharing your Personal Data with the aforementioned authorities is to meet our obligation to comply with a legal obligation to which we are subject.

8. NO DISCLOSURE OF YOUR PERSONAL DATA FOR COMMERCIAL PURPOSES

8.1. We do not sell your Personal Data to third parties. We do not share or otherwise make available your Personal Information to third parties, except as otherwise provided in this Privacy Policy.

9. TRANSBORDER COMMUNICATION OF PERSONAL DATA

9.1. If, as a result of certain services provided by third parties, we are required to transfer your Personal Data to one of their databases outside the European Economic Area, and/or Switzerland, potentially to a State that does not present a level of protection of Personal Data comparable to that prevailing in Switzerland or the European Economic Area, unless otherwise provided in this Privacy Policy, we undertake to enter into an agreement with the third party service provider in order to ensure an adequate level of protection of your Personal Data.

10. PROTECTION OF YOUR PERSONAL DATA AND NOTIFICATION OF A DATA BREACH

10.1 We undertake to use all commercially reasonable means to prevent any exposure or disclosure of your Personal Data. In particular, we implement and maintain measures (including administrative, physical and technical measures) to manage cases of unauthorized disclosure or exposure of your Personal Data.

10.2. In the event of an actual or suspected breach of Personal Data, we undertake to (i) use our best efforts to notify you without delay, where technically feasible, and (ii) cooperate with you in investigating and resolving the breach, including, but not limited to, providing reasonable assistance in notifying aggrieved third parties. We undertake to give you access, without delay and within the limits of a reasonable request, to our files relating to the violation of your Personal Data, provided however that this does not give you access to files which belong to other users or which could compromise their security.

10.3. In the event of an actual or suspected violation of Personal Data, we undertake to notify the competent authority under the applicable law.

11. MANAGEMENT OF YOUR PERSONAL DATA (YOUR RIGHTS)

11.1. Right to access, update and delete your Personal Data: Wherever possible, you may access, update or request the deletion of your Personal Data by contacting us via the contact form, by sending us an e-mail at: support@vivengo.ch

11.2. Right of rectification: You have the right to obtain rectification of your Personal Data if it is inaccurate or incomplete.

11.3. Right to object: Within the limits of the law, you have the right to object to the processing of your Personal Data.

11.4. Right to limit processing: Within the limits of the law, you have the right to obtain a limitation of the processing of your Personal Data.

11.5. Right to portability of personal data: You have the right to obtain a copy of your Personal Data in a structured, commonly used and machine-readable format.

11.6. Right to withdraw consent: Within the limits of the law, you have the right to withdraw your consent at any time when the processing of your Personal Data is based on it. It should be noted, however, that such withdrawal: (i) does not affect the lawfulness of any processing carried out prior to the said withdrawal and based on your consent; and (ii) may result in you no longer being able to use certain features of the Websites or our pages on social networks.

11.7. Right to complain to an authority: You have the right to complain to any competent authority about the collection and use of your Personal Data.

11.8. We may ask you to prove your identity before responding to a request based on the aforementioned rights or otherwise related to your Personal Data.

12. STORAGE OF YOUR PERSONAL DATA

12.1. We retain the Personal Data you provide to the extent required by your access to and use of our Websites and our social networking pages, as well as the features found therein (such as our contact forms), as well as to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Data under applicable law), to resolve a dispute or to enforce agreements we have entered into and our internal regulations.

12.2. The retention period for Cookies and similar Technologies depends on their purpose and is always the same regardless of the person to whom the Personal Data relates.

12.3. We reserve the right to store data in de-identified (i.e. anonymous) form after deletion of your Personal Data.

13. SECURITY OF YOUR PERSONAL DATA

13.1. The security of your Personal Data is very important to us. However, no method of communication over the Internet or method of electronic storage can guarantee 100% security. Consequently, although we endeavor to use commercially acceptable technical and organizational means to protect your Personal Data, we cannot guarantee its absolute security.

14. PERSONAL DATA RELATING TO CHILDREN

14.1. We do not provide services specifically for children via our Websites and we do not proactively collect Personal Data relating to them.

15. CHANGES TO THIS PRIVACY POLICY

15.1. We may change this Privacy Policy at any time by posting a new version on this page or on a deeper page without prior notice. If we do so, we will notify you by posting a notice on the home page of our Websites. By continuing to access or use our Websites or our pages available on social networks after the entry into force of this modification, you acknowledge and agree to the processing of your Personal Data in accordance with the revised Privacy Policy. If you do not agree to these changes, please do not use our Websites or our pages available on social networks.

15.2. We undertake always to treat your Personal Data in accordance with the Privacy Policy in force at the time the Data is collected.

15.3. The new version of the Privacy Policy comes into effect on the day of its publication, the day mentioned at the top of this Privacy Policy corresponding to the effective date.

16. QUESTION?

16.1. Please do not hesitate to contact us via the contact form, or by e-mail at : <support@vivengo.ch> if you have any questions about this Privacy Policy.

16.2. You can also contact us by post at the following address: Vivengo SA, Rue du Pâquis 11a, 1033 Cheseaux-sur-Lausanne.

Vivengo app privacy policy

Vivengo SA (hereinafter “we,” “our”) is a public limited company registered at “Rue du Pâquis 11a, 1033 Cheseaux-sur-Lausanne (Switzerland),” with the national identification number CH-550-1241226-0. Vivengo SA aims to develop and market products in the fields of sports and health, as well as to organize educational programs and events. The medical-sports application called “Vivengo” (hereinafter the “Application” or the “App”) is part of the company’s mission.

This Data Protection Policy (hereinafter the “Policy”) describes how and why Vivengo SA collects, processes, and uses personal data (hereinafter “Data”) of users of the Application upon the creation of a personal account (hereinafter “User(s),” “you,” “your”). Vivengo SA minimizes the use of personal data to protect its Users and their privacy.

The purpose of this Policy is to inform every User how and for what purposes Vivengo SA collects, processes, and uses their personal data. We respect our Users’ privacy and want them to understand our internal procedures regarding Data, as well as the measures we take to protect it.

This Policy clearly outlines:

what personal data is collected and processed;

the purposes for which the Data is used;

who has access to it;

how Users benefit from the processing of their Data;

how long the Data is processed for;

the rights Users have regarding their Data; and

how to contact us.

This Policy is designed to comply with the Swiss Federal Data Protection Act (FADP) and the European General Data Protection Regulation (hereinafter “GDPR”). The provisions applicable to a User will depend on their place of residence and/or nationality.

Regarding residents of the State of California specifically, it is specified that Vivengo SA does not sell any personal information. We use cookies on the Application and/or Vivengo SA’s website. Details in this regard are provided in this Policy.

The California Consumer Privacy Act (CCPA) grants the following rights to California residents: (1) the right to know how their personal information is collected and used; (2) the right to access and request their collected personal data; (3) the right to request the deletion of their personal data; and (4) the right to opt out of the sale or sharing of their personal information. The CCPA limits these rights, for example, by prohibiting companies from disclosing certain sensitive information in response to access requests and by limiting the circumstances under which they must comply with deletion requests.

1. What is this Data Protection Policy about?
Vivengo SA (also “we,” “our”) collects and processes personal data regarding all Users as well as other persons (“third parties”) who are partners of Vivengo SA in connection with its business operations.

Where necessary, we will provide Users with a separate notice for any additional processing activities not covered by this Policy. This Policy applies only to the relationship between Users and Vivengo SA, and not to contracts or relationships between a User and the Platform, as defined in the Terms of Use, nor to contracts between Vivengo SA and other service providers or partners.

The term “Data” refers to the personal data of a User of the Application.

2. Who is responsible for processing your Data and how to contact us?
Unless otherwise expressly stated, the controller of the Data related to the Application is Vivengo SA, a Swiss public limited company registered at “Rue du Pâquis 11a, 1033 Cheseaux-sur-Lausanne (Switzerland),” with national identification number CHE-155.255.171.

For any questions regarding personal data protection and/or to exercise your rights as described below, Users can contact us at:

Email: privacy@vivengo.ch

If you are a User who is a citizen and/or resident of the EU, you may also contact our data protection representative under Article 27 of the GDPR:

Vivengo SA
Rue du Pâquis 11a
1033 Cheseaux-sur-Lausanne
privacy@vivengo.ch

3. What data do we process?
We process different categories of data about you. The main categories include:

Technical data: When you use our website, we collect the IP address of the device you use and other technical data to ensure functionality and security. This includes usage logs of our systems. We generally retain technical data for 12 months. To ensure the functionality of these services, we may assign an individual code to you or your device (e.g., in the form of a cookie, see Section 12). Technical data alone does not allow identification of your identity. However, technical data may be linked to other categories of data (and potentially to your person) in connection with user accounts, registrations, access controls, or contract execution.

Account creation / contractual data: To use the Application, you must create a User account directly within the App. In this context, you are required to provide certain data, and we collect data about how you use the Application. We retain this User data for as long as your account remains active, and for no longer than 12 months after account closure.

Personal data collected may include, but is not limited to:
first name, last name, personal ID associated with the Platform, gender, year of birth, height, weight, endurance level, sleep history, fatigue level, motivation, health status (including injuries), stress level, menstrual pain, available time for training, personal goals, training frequency and volume, and the type of equipment used.

When subscribing to a paid plan, this data also includes the type of subscription and its duration.

Basic Data: These are data collected as part of the use of the free or paid features of the Application, for which a certain amount of information is requested from the User. This data is provided exclusively by you and is collected and processed solely so that our algorithm and AI can determine which services and/or programs are suited to you. Please note that the more numerous and accurate your responses are, the more personalized the services of the Application will be to your person, your goals, your needs, etc.

This data, some of which may be sensitive (e.g., health data), is anonymized immediately after the result provided by the Application’s algorithm is obtained.
We retain this anonymized data for statistical purposes and/or for the development of the Application’s algorithm. This data may be shared with third parties but cannot in any way be used to identify you. The data is retained for 12 months after your subscription is terminated to allow for easy reactivation of your account if you return to the application within that time. After those 12 months, and if you have not returned, your data will be permanently deleted.

Communication Data: When you contact us via the contact form, email, phone, mail, or any other means of communication, we collect the data you exchange with us, including your contact details and communication metadata. If we need to verify your identity (e.g., in connection with an information request or exercising your rights under this policy), we collect data that allows us to identify you (such as a copy of an identity document). We generally retain this data for 12 months from our last exchange. This period may be longer if necessary for evidentiary purposes, legal or contractual obligations, or technical reasons. Emails in the personal inbox and written correspondence are generally kept for at least 10 years.

Communication data includes your name and contact details, the method, time, and place of communication, and usually its content (i.e., the contents of emails, letters, etc.). This data may also include information about third parties. For identification purposes, we may also process your passport or ID card number.

Behavioural and Preference Data: Depending on our relationship with you, we aim to better understand you and tailor our products, services, and offers to your needs. For this purpose, we collect and process data regarding your use of and preferences on the Application. Based on this data, we may determine, for example, the likelihood that you will use certain services or behave in a certain way. This data is known to us through your use of the Application. We anonymize or delete this data when it is no longer relevant for the intended purposes—between 3–4 weeks (for behaviour profiles) and 24 months (for service preferences), depending on the data type. This period may be extended if required for evidentiary purposes or to meet legal or contractual requirements.

Location Data: With your consent, the Application may collect and process location data from your device, including precise location information obtained through GPS or other location technologies. This may include location data collected while the Application is actively in use as well as location data collected in the background when certain features are enabled.
Background location access allows the Application to provide specific services related to training, activity tracking, and personalized coaching features that depend on your geographic position. Location data is used solely to provide and improve the services offered by the Application. When possible, location data is anonymized or aggregated for analytical and improvement purposes. Users may disable location access at any time through their device settings, although certain features of the Application may no longer function properly if location access is disabled.

Most of the data mentioned in this Section 3 is provided directly by you (via forms, during communication with us, while creating a personal account or using the free or paid services of the Application, on the website, etc.). You are not obliged to provide us with data, except in certain cases, such as creating a User account (legal obligations). If you wish to benefit fully from the Application’s services, you must also provide certain data, especially contractual and basic data. Moreover, it is not possible to avoid the processing of technical data when using our website.

However, in the case of behavioural and preference data, you generally have the option to object or refuse consent.

4. For what purposes do we process your data?

We process your data for the purposes outlined below. These purposes serve our interests and possibly those of third parties. You can find more information about the legal basis for our processing in Section 5.

We process your communication data solely to communicate with you, particularly to respond to your requests and the exercise of your rights (Section 11), and to contact you in case of any questions. For this purpose, we use communication and contractual data. We retain this data to document our communication with you, for training, quality assurance, and request tracking.

We process your contractual data to manage your access to the Application.

We process your contractual and basic data for your access to the free or paid services of the Application, the conclusion of your subscription, and its ongoing management.

We also process your data for market research, improving our services and business operations, and for product development.
We constantly strive to improve our products and services (including our website) and to meet changing needs. For this purpose, we analyse how you navigate our website or use the Application. We use basic data, behavioural data, preference data, and communication data for these purposes. Whenever possible, we use pseudonymized or anonymized data.

With your prior consent, we may process location data (including background location data) to enable certain Application features such as activity tracking, training analysis, and personalized coaching services. Location data may also be used in anonymized form to improve the performance and functionality of the Application.

We may also process your data for security and access control purposes.

We process data to comply with laws, guidelines, and recommendations from authorities, as well as internal policies (“compliance with legal obligations”).

We may also process your data for other purposes, such as internal processes, Application development, and administration, but only in anonymized form. These other purposes also include safeguarding other legitimate interests which cannot be exhaustively listed.

5. On what basis do we process your data?

When we request your consent for specific processing activities (e.g., marketing, behavioural study, ad management, etc.), we will inform you separately of the relevant processing purposes. You can withdraw your consent at any time with future effect by sending us written notice (by post) or, unless otherwise stated or agreed, by emailing us. You can find our contact information in Section 2. To withdraw your consent for online tracking, see Section 12.

When you have a User Account, you can also withdraw your consent for certain Data as outlined above by contacting us via the App, the website, or the relevant service. As soon as we receive notification of the withdrawal of consent, we will no longer process your information for the purpose(s) for which you gave consent, unless we have another legal basis for doing so. However, withdrawing consent does not affect the legality of any processing based on your prior consent. Please note that contractual Data is tied to the use of the App and the creation of a personal account.

Where we do not rely on consent for processing, the processing of your personal data is based on the necessity of such processing to initiate or perform a contract with you or on our legitimate interest in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. Our legitimate interests also include compliance with legal regulations, insofar as this is not already recognized as a legal basis by applicable data protection legislation (e.g., under the GDPR in the EEA, and under the FADP in Swiss law).

With regard to so-called sensitive personal data (e.g., health-related data) collected for the use of free or paid features of the App, please note that such data is only stored in anonymized form and is therefore no longer considered Data (see Section 3).

6. What rules apply to profiling and automated individual decisions?
We may automatically evaluate personal aspects relating to you (“profiling”) based on your Data (Section 3) for the purposes outlined in Section 4, for example, to identify preferences, detect abuse and security risks, perform statistical analyses, and plan business activities. We may also create profiles for these purposes, meaning that we may combine behavioural and preference data, as well as contractual and technical data about you, to better understand you as a person – with your various interests and other characteristics.

7. With whom do we share your data?
In the course of our operations, website, legal obligations, protection of our legitimate interests, and other purposes outlined in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:

Service Providers: We work with service providers in Switzerland and abroad who process your data on our behalf, as joint controllers with us, or who receive your data from us as independent data controllers (e.g., IT service providers, advertising service providers, connectivity service providers, platforms). This may include basic Data, but always in anonymized form. For service providers used for the website, see Section 12. The main IT service providers are: UXCam, Voiceflow, and the app stores (Apple App Store and Google Play Store).

Authorities: We may disclose personal data to agencies, courts, and other authorities in Switzerland and abroad if we are legally obliged or authorized to do so or if it is necessary to protect our interests.

8. Is your personal data transferred abroad?
As mentioned in Section 7, we work directly and indirectly with service providers in Switzerland and abroad. The main external providers are:

UXCam: A user experience analytics tool that helps us better understand how users interact with our App. It helps identify areas for improvement in terms of interface and user experience. This service is provided by UXCam Inc., based in California, USA.

Voiceflow: A platform we use to design and manage the conversational flows of our virtual coach. It helps us structure AI-based dialogues and personalize the user experience. This service is provided by Voiceflow Inc., headquartered in Toronto, Canada.

App Stores: Apple and Google Play Store, which act as resellers of our product. The Apple Store is operated by Apple Inc., headquartered in Cupertino, California, USA. The Google Play Store is operated by Google LLC, headquartered in Mountain View, California, USA.

Please note that data exchanged over the internet often passes through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.

9. How long do we process your data?
We process your data for as long as necessary to fulfil our processing purposes, comply with legal retention periods, safeguard our legitimate interests in documentation and evidence, or when technical and/or legal requirements mandate it. More information on retention and processing periods for different categories of data can be found in Section 3, and for cookies in Section 12. In the absence of legal or contractual obligations to the contrary, we will delete or anonymize your data once the retention period has expired or processing has ended, as part of our regular processes.

10. How do we protect your data?
We take appropriate security measures to ensure the necessary protection of your Data, to maintain its confidentiality, integrity, and availability, to safeguard it from unauthorized or unlawful processing, and to minimize the risk of loss, accidental alteration, unauthorized disclosure, or access.

11. What are your rights?
Applicable data protection laws give you the right to object to the processing of your Data in certain circumstances, particularly processing for direct marketing purposes, profiling for direct marketing, and other legitimate interests in processing.

To help you control the processing of your personal data, you have the following rights concerning our processing of your Data, in accordance with applicable data protection law:

The right to request information as to whether we process data about you and, if so, which data;

The right to request the correction of inaccurate data;

The right to request the deletion of data;

The right to request that we provide certain personal data in a commonly used electronic format or that we transfer it to another data controller;

The right to withdraw your consent, where our processing is based on your consent;

The right to receive, upon request, additional information helpful in exercising these rights;

The right to express your point of view in case of automated individual decisions (Section 6) and to request that a human reviews the decision.

If you wish to exercise the aforementioned rights, you can contact us via email; our contact details can be found in Section 2.
To prevent any misuse, we must verify your identity (for example, by means of a copy of your ID card, if identification is not otherwise possible).

You also have these rights with respect to other parties who cooperate with us as independent data controllers – for example, the platform you are using. You may contact them directly if you wish to exercise your rights regarding their processing of your data. You can find information about our main partners and service providers in Section 7, and additional information in Section 12.

Please note that conditions, exceptions, and restrictions may apply when exercising these rights, in accordance with applicable data protection laws. If applicable, we will inform you accordingly.

If you disagree with the way we respond to the exercise of your rights or with our data protection practices, you may inform us or our data protection representatives (Section 2). If you are located in the EEA, the UK, or Switzerland, you also have the right to lodge a complaint with the competent data protection authority in your country. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en
You can contact the UK supervisory authority here: https://ico.org.uk/global/contact-us/
You can contact the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

12. Do we use online tracking and advertising technologies?

On our website and within our app, we use various technologies that allow us – and third parties we engage – to recognize you during your usage and, if applicable, across multiple visits. These include cookies and other tracking tools designed to improve user experience and personalize the services provided.

The Application may also access device location information, including background location data, when necessary to provide certain features of the service, such as activity tracking and personalized coaching functionalities.

Additionally, we offer personalized advice within the app tailored to your specific needs, based on data collected from your interactions with our service.

Essentially, we aim to distinguish your access (via your system) from access by other users, in order to ensure website functionality and perform analytics and personalization. We do not intend to identify you, although it may be possible for us or the third parties we engage to do so by linking this data to registration details. However, even without registration data, the technologies we use are designed to recognize you as an individual visitor each time you access the website — for example, our server (or third-party servers) may assign a unique ID number to you or your browser (called a “cookie”).

Necessary cookies: These cookies are required for the website to function. For example, they ensure that you can move from one page to another without losing information you’ve entered in a form, and that you stay logged in. These are temporary cookies (“session cookies”). Blocking them may cause the website to malfunction. Other necessary cookies store options or input (such as language preferences, consent, or auto-login settings) beyond a single session. These cookies may remain for up to 24 months.

Performance cookies: To optimize our website and related services and better tailor them to user needs, we use cookies to record and analyse website usage, potentially across sessions. We ask for your consent before using these cookies. You may withdraw consent at any time via cookie settings. Performance cookies may have an expiration of up to 24 months. Details are available on third-party providers’ websites.

Marketing cookies: We and our advertising partners aim to target ads as precisely as possible — i.e., only show them to the desired audience. If you consent, we and our partners may use cookies that record viewed content or concluded contracts. This allows us and them to display relevant ads on our site and others. These cookies may expire after a few days or up to 12 months, depending on the circumstances. If you consent, you’ll see tailored ads; if not, you’ll still see ads, just not personalized ones.

Beyond marketing cookies, we use other technologies to manage online advertising on external sites and reduce ad waste.

We may also integrate third-party offerings on our website, especially from social media platforms. These are activated by default. Once activated (e.g., by clicking a button), those providers can determine that you are using our site. If you have an account with them, they may associate this usage with your account and thus track your use of online services. These social media providers process such data as independent data controllers.

We currently use services from the following providers (when they use data or cookies for advertising purposes):

Google Analytics: Provided by Google Ireland Ltd. (Ireland), acting as our processor. Google Ireland uses Google LLC (USA) as a sub-processor (both referred to as “Google”). Google collects information about website behaviour (duration, pages visited, geographic region, etc.) via performance cookies (see above), and generates usage reports. We’ve configured the service to truncate IP addresses in Europe before transmitting them to the US, making them untraceable. We’ve disabled “Data Sharing” and “Signals” options. While we believe the shared info is not personal data for Google, they may infer identities and create personal profiles, linking data to Google accounts for their own purposes.

By consenting to the use of Google Analytics, you expressly accept this processing, including the transfer of your personal data (especially usage data, device info, and unique identifiers) to the US and other countries.
More info about Google Analytics data protection: [https://support.google.com/analytics/answer/6004245]
More about how Google handles your data if you have a Google account: [https://policies.google.com/technologies/partner-sites?hl=en]

13. What data do we process on our social media pages?

We may operate pages and other online presences (“fan pages,” “channels,” “profiles,” etc.) on social media and other platforms run by third parties, and collect data as described in Sections 3, 7, 12, and here.

We receive data from you and the platforms when you interact with us through these online presences (e.g., by messaging us, commenting, or visiting). These platforms also analyse your usage of our pages and combine this data with other data they hold about you (e.g., behavioural and preference data). They also process this data for their own purposes, such as marketing, market research (e.g., ad personalization), and platform management (e.g., what content you see), acting as independent data controllers.

Instagram: We publish on the official Vivengo page. For EU users, the controller is Meta Platforms Ireland Limited. Their privacy policy is available here.

Meta (Facebook): We publish on the official Vivengo page. Meta Platforms Ireland Limited is the controller for EU users. Their privacy policy is available here.

TikTok: We publish on the official Vivengo account. For EU users, the controller is TikTok Technology Limited, Ireland. Their privacy policy is available here.

LinkedIn: We publish on the official Vivengo page. The controller for EU users is LinkedIn Ireland Unlimited Company, Dublin. Their privacy policy is available here.

YouTube: We publish on the official Vivengo channel. YouTube is a subsidiary of Google Ireland Limited, Dublin. Their privacy policy (Google’s) is available here.

14. Can we update this Policy?

Vivengo SA may amend this Policy at any time.
You will be informed of any changes once they take effect.

If you continue to access the Vivengo SA app and/or website after such notification, you will be deemed to have accepted the new Policy.

Last updated: 17.03.2026