1. Introduction

We from SOFY GmbH, office park Donau Inkustraße 1-7, 3400 Klosterneuburg, info@sofy.group, (hereinafter referred to as "SOFY", "we" or "us") have set ourselves the goal of edupression.com® exclusively on the building the foundation of evidence-based medicine. People who are in a difficult time for them, should be given the opportunity to learn online self-help and build expertise, in addition to the existing forms of therapy psychotherapy and psychotropic drugs. Our claim is the science and use of the highest technical level. For this reason, the protection of the personal data of our customers (users) and interested parties is also of particular concern to us in the sensitive area. We process this data solely on the basis of the applicable, strict legal provisions in the European Union and Austria (GDPR, Austrian Dataprotection Law and Telecommunication Law).

2. Registration and Use of edupression.com®

In order to be able to use edupression.com® as an online platform and medical device, thus on the basis of Art 6 (1) (b) DSGVO, the users must register (name, password, valid email address.) In the mandatory onboarding process (with online user manual) must also be confirmed by the users that there are no urgent suicidal thoughts or plans.
When registering, they must also expressly consent to the processing of personal data, in particular to the processing of their health data in accordance with Article 9 (2) (a) GDPR. The registration is only allowed to users from the age of 18 years.

When using edupression.com®, the following data is processed:
a) Data that users actively enter: contact information, form input for the status of knowledge, self-tests, health, activities, forums, etc.
b) Data that can be detected passively via the (mobile) terminals (motion and acceleration sensors, user behavior, GPS data).
These data are the basis for the application and efficacy of the products of edupression.com® as medical devices.

3. Collaboration with science partners and sharing of anonymous data

In R&D we work together with medical-scientific research institutions. Data required for science are transmitted only in an anonymous form, so that the researchers can not draw any conclusions about the person of the individual user.

Our common goal is to further develop edupression.com® in such a way that our users receive the best possible support and support in their illness.

4. Contact

If you want to contact us, you can do this for example. by e-mail to info@sofy.group or by phone. We process your e-mail address, telephone number and the content of your message and communication for the purpose of processing your request and in case of follow-up questions and save it on the basis of Art. 6 (1) (b) GDPR for up to six months.

As far as health data are concerned, these are only processed in accordance with your explicit consent in accordance with Art. 9 (2) (a) GDPR.

5. Online Payment

In order to process the online payment transaction, thus on the basis of Art 6 (1) (b) GDPR, we only pass on the most necessary personal data to the payment service provider (Stripe Inc. or PayPal (Europe) S.à rl et Cie, SCA): Name, Purpose, amount. These data are encrypted and used only to process the payment.

As a US company, Stripe Inc. is privacy-protected under the US Privacy Shield, see also privacy policy stripe.com https://stripe.com/en-en/privacy).

If users use PayPal, they have already agreed to PayPal's terms https://www.paypal.com/at/webapps/mpp/ua/legalhub-full?locale.x=de_AT)

6. Website - Cookies and Analysis Services

Our website uses so-called cookies. These are small text files that are stored on your device using the browser. They do no harm.

We use cookies to make our offer user-friendly and our web service works technically. Some cookies remain stored on your device until you delete them. They allow us to recognize your browser on your next visit i.e. to make our web service faster available.

If you do not want this, you can set up your browser so that it informs you about the setting of cookies and you allow this only in individual cases.

When deactivating cookies, the functionality of our website and our web shop may be limited.

7. Web Analytics: Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offer by the users are usually transmitted to a Google server in the USA and stored there.

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous user profiles of the processed data can be created.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.

The IP address submitted by the user's browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to its use of the online offer as well as the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http: // tools.google.com/dlpage/gaoptout?hl=de.

Use of the Service is based on Google's Privacy Policy https://www.google.com/intl/en/policies/privacy/. Google has been certified under the US Privacy Shield and thus complies with the legal terms as a service provider from a third country under EU GDPR.

8. E-Mail-Newsletter

We send e-mail newsletters to interested parties and our users (customers) and inform them about mental illnesses and our services. The e-mail delivery takes place on basis of the consent of the prospective customer in accordance with Art. 6 (1) (a) GDPR and from the contractual relationship as a customer. The registration takes place in a so-called double-opt-in procedure (the prospective customer receives after the registration an e-mail, in which he is asked for the confirm, only after confirmation the email-newsletter is sent). The user can unsubscribe at any time simply by clicking on the unsubscribe link in the newsletter. To carry out the shipment, we use an e-mail marketing service in France, as a processor. For this purpose, only the following data will be transmitted: name, salutation and e-mail address. In the case of shipping, usage data (reports) are also collected; these are used solely for the purpose of improving our newsletter service and thus for safeguarding our legitimate interests pursuant to Art. 6 (1) (f) GDPR. If you have given your consent to receive email newsletters in accordance with Art. 6 (1) (a) GDPR, we will store your data until your withdrawal of your consent.

Unlike the newsletters, accompanying, personalized communication via e-mail (reminders, information, congratulations ...) is an important component of our service offered to our users, hence a contractual part of our service (Art. 6 (1) (b)).

9. Recipient of personal data

In principle, the transmission and processing of personal data takes place only to the extent necessary for fulfilling the contractual relationship or for the implementation of pre-contractual measures (on the basis of Art. 6 (1) (b) GDPR) to fulfill a legal obligation (Art. 6 (1) (c) DSGVO ), to safeguard legitimate interests (Art. 6 (1) (f) GDPR) or to assert, exercise or defend legal claims (Art. 9 (2) (f) GDPR) or if the user or interested party gives his express consent (Art. 6 (1) (a) or Art. 9 (2) (a) GDPR).

In addition to the order processors listed above, the personal data of the users or prospective customers are transmitted in particular to data centers, IT service providers and accounting service providers.

Furthermore, a transmission amongst others could be required in connection with government inquiries or court orders.

In particular, due to the obligation under the applicable medical device law, we as a manufacturer or distributor are subject to special requirements with regard to monitoring the functionality of the products. Based on this regulatory required monitoring and reporting system may also come to the processing of personal data. Legal basis here is Art. 9 (2) (i) GDPR.

10. Speicherdauer

The storage of your personal data takes place as long as necessary to fulfill contractual obligations and for their purpose. After that the data will be deleted. Exceptions exist for legal storage or storage obligations.

11. Rechte der Betroffenen

We point out that you can assert your right at any time regarding information, data portability, correction, limitation, revocation, opposition and deletion of your personal data. Unless otherwise stated, we will comply with your request in due time. You also have the right to complain to the competent authority: Austrian Data Protection Authority (www.dsb.gv.at, Barichgasse 40-42, 1030 Vienna).

12. Kontakt uns und zu unserem Datenschutzkoordinator:

SOFY GmbH c/o Datenschutzkoordinator
Inkustr. 1-7/Haus G/Stg. 7/2.OG, 3400 Klosterneuburg
E-mail: privacy@edupression.com

13. Datensicherheit

We take appropriate technical and organizational security measures within the meaning of Art. 32 DSGVO to protect your personal data against unintentional or unlawful deletion, alteration or loss, and against unauthorized disclosure or access.

14. Änderung der Datenschutzerklärung

We reserve the right to change the privacy policy in order to adapt it to changing legal situations, or to changes in the service and data processing. However, this only applies to declarations of data processing. If users' consent is required or elements of the privacy policy contain provisions of the contractual relationship with the users, the changes are only made with the consent of the users.

Users are requested to inform themselves regularly about the content of the privacy policy.

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Our vision at edupression.com® is to create a place, where all depressed people feel they are in good hands - empowering them to beat depression!

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