This policy sets out our policy on personal privacy. We take your privacy seriously and information will be used in accordance with European data protection laws and regulations (referred to in this policy as "Data Protection Requirements"). This privacy notice aims to provide you with information about how we collect and process your personal data when you use this website, including any data you may provide through this website when you contact Business Process Technologies LP, https://goallife.axiomalife.biz or otherwise communicate with us.

This website, as well as the GoalLife mobile application, are not directed to children, and we do not knowingly collect data relating to children unless a parent or guardian has given consent on behalf of the child. If you are under 18, you should ask your parent or guardian to give their consent.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we collect or process your personal data, so that you are fully aware of how and why we use your data. This privacy notice supplements those other notices and is not intended to cancel them.

1. Data controller

Business Process Technologies LP is the controller and responsible for your personal data. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing issues in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to execute your legal rights, please contact the DPO using the details set out below.

Email: [email protected]

Postal Address: 4 Queen Street, Suite 1,

Edinburgh, Postcode: EH2 1JE,

United Kingdom, Scotland;

You have the right to lodge a complaint at any time with the EU's independent data protection authority, the EUROPEAN DATA PROTECTION OFFICE (EDPS), (https://edps.europa.eu/). We value the opportunity to deal with your concerns before you apply to the EDPS, so please contact us first. It is important that your personal information is accurate and up to date. Please keep us informed if your personal information changes during your relationship with us.

2. Your consent

By using this website or the 5Llife app, you consent to collection and use of your personal data by us as set out below in accordance with this policy statement. If we decide to change these terms for any reason, the changes will be posted here so that you are always informed about how we collect and use your personal information and when we disclose it.

3. Data security

3.1. We have taken necessary security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

3.2. We have implemented procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

3.3. We use pseudonymization for physical or mental health conditions whose biometric data is considered sensitive personal data so that the person to whom the data relates cannot be identified without the use of additional information that is intended to be kept separate and secure.

3.4. We use high-quality encryption with asymmetric keys for the sensitive personal data base.

4. Data we collect about you

4.1. Personal data means any information about an individual from which that individual can be identified. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

4.1.1. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences;

4.1.2. Usage Data includes information about how you use our website, products and services;

4.1.3. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;

4.1.4. Technical Data includes only your login details that you use to access this website or mobile application;

4.1.5. Transaction Data includes details of payments to and from you and other details of services you have purchased from us;

4.1.6. We do not collect financial data, which includes bank account and payment card details;

4.1.7. Contact data includes billing address, shipping address, email address, and phone numbers;

4.1.8. Identification data includes first name, maiden name, last name, username or similar identifier, marital status, job title, date of birth, and gender;

4.2. We collect special categories of personal data (sensitive personal data) about you (including information about your health).

4.3. When scanning your face via camera, the application receives RR intervals based on the video stream in real time, the video stream itself is not saved and the application does not use it anywhere else.

4.4. when filling out the profile questionnaire in the program, you can provide us with the following information, if you wish: Name, Surname, gender, date of birth, height, weight, country of residence, employment, marital status, income level, whether you drink coffee, alcohol, smoke or not and how much, diet. All this data is stored in an encrypted, anonymized form, is not transferred anywhere and is used solely to adjust the program algorithms individually for you.

5. How we collect personal information about you

5.1 We use different methods to collect data from and about you, including through:

5.1.1 Direct interactions. You may provide us with your identity, contact, by filling in forms or corresponding with us by email or otherwise. This includes personal data you provide when you can:

5.1.1.1 apply for our services;

5.1.1.2 create an account on our site;

5.1.1.3 subscribe to our service or publications;

5.1.1.4 request that we send you information about Goallife;

5.1.1.5 enter a promotion or survey;

5.1.1.6 leave us feedback;

5.1.1.7 scan your face with a camera, thereby providing us with RR intervals based on a non-stored video stream;

5.1.1.8 Fill out your profile about yourself.

6. How we use your personal data

6.1. We will only use your personal data where data protection requirements allow us to do so. Most commonly, we will use your personal data in the following situations:

6.1.1. Where we need to perform a contract we are about to enter into or have entered into with you;

6.1.2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

6.1.3. Where we need to comply with a legal or regulatory obligation.

6.1.4. We do not generally rely on consent as a legal basis for processing your personal data, except in relation to third party direct marketing communications to you via email or text message. You have the right to refuse consent to marketing at any time by contacting us.

7. Purposes for which we will use your personal data

7.1. We may use your personal data to:

7.1.1. register you as a new customer;

7.1.2. process your application to customize your GoalLife program or application, including managing payments, fees, and billing;

7.1.2.1 receive RR intervals. The GoalLife program or application receives RR intervals based on the video stream from the camera. You can start the testing process yourself if you wish. The received video stream is not saved. Only RR intervals are saved as a set of numbers. Based on them, information about energy, stress level, and biological age is generated. These results are not medical and are for entertainment purposes only.

7.1.3. manage our relationship with you, including:

7.1.3.1. to notify you of changes to our terms or privacy policy;

7.1.3.2. to ask you to leave a review or take part in a survey;

7.1.4. to allow you to take part in a full survey;

7.1.5. to administer and protect our business and this website;

7.1.6. to deliver relevant content and advertising to you on the website and measure or understand the effectiveness of advertising we serve to you;

7.1.7. to use data analytics to improve our website, products/services, marketing, customer relationships and experience;

7.1.8. to make suggestions and recommendations about goods or services that may be of interest to you.

7.2. We may share aggregate statistics about sales, customers, traffic patterns and information with third parties, but these statistics will not include any information that personally identifies you

7.3. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data.

7.4. Marketing

We aim to provide you with choices about certain uses of personal data, particularly in the areas of marketing and advertising.

7.5. Marketing offers from us

7.5.1. We may use your Identity, Contact, Technical, Usage and Profile Data to form a picture of what we think you want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you (we call this marketing).

7.5.2. You will receive marketing messages from us if you have requested information from us and have not refused to receive this marketing.

7.6. Third-Party Marketing

We will obtain your explicit consent before we share your personal data with third parties for marketing purposes.

7.7. Refusal

7.7.1. You can ask us to stop sending you marketing communications at any time by contacting us at [email protected] or by unsubscribing using the link in a marketing email.

7.8. Change of Purpose

7.8.1. We will only use your personal data for the purposes for which we collected it, unless we consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.

7.8.2. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

7.9. Please note that we may process your personal data without your knowledge or consent in accordance with the above rules where this is required or permitted by data protection requirements.

8. Disclosure of your personal data

8.1. We may need to share your personal data with

8.1.1. service providers who provide IT and system administration services;

8.1.2. professional advisers;

8.1.3. regulators and other authorities to whom we are required to notify you about processing activities in certain circumstances.

8.2. Personal data shared with third parties may:

8.2.1. relate to the performance of our contract with you;

8.2.2. be necessary for our legitimate interests or for compliance with a legal obligation;

8.2.3. be third parties to whom we may decide to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire or merge with other businesses. If our business changes, the new owners may use your personal data in the same way as set out in this privacy notice.

8.3. We require all third parties to respect the security of your personal data and treat it in accordance with data protection requirements. We do not allow our third party service providers to use your personal data for their own purposes. and only allow them to process your personal data for the stated purposes and in accordance with our instructions.

8.4. The RR intervals received are stored only in your program, are not transferred anywhere and are not used for anything.

9. International Transfers

9.1. Some of our external third parties are based outside the EEA, so their processing of your personal data will involve transferring data outside the EEA.

9.2. Whenever we transfer your personal data out of the EEA, we ensure that it is afforded a similar degree of protection by ensuring that at least one of the following security measures is implemented:

9.3. We will only transfer your personal data to countries that the European Commission has deemed to have an adequate level of protection for personal data. For further information, see European Commission: Adequacy of protection for personal data in non-EU countries;

9.4. Where we use certain service providers, we may use specific contracts approved by the European Commission which afford personal data the same protection as it has in Europe. For further information, see European Commission: Model contracts for the transfer of personal data to third countries;

9.5. If we use US-based providers, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US. For details, see the European Commission: EU-US Privacy Shield.

9.6. Please contact us if you require further information about the specific mechanism we have used to transfer your personal data from the EEA.

10. What are cookies and how do we use them?

10.1. A cookie is a piece of information that is stored on your computer’s hard drive. It is usually sent to you by a web server and enables the server to collect information about your visit to the site.

10.2. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

If you disable or refuse cookies, please note that some parts of this site may become inaccessible or not function properly.

11. Data storage

11.1. We will only store your personal data for as long as necessary to fulfill the purposes we collect it for, including for the purposes of satisfying any legal, accounting, or reporting requirements

11.2. To determine the appropriate period for personal data storage, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

11.3. In some circumstances, you can ask us to delete your data: for more information, see [Request for deletion] below.

12. Your legal rights

12.1 In certain circumstances, you have data protection rights in relation to your personal data.

12.2 You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Otherwise, we may refuse to comply with your request in these circumstances.

12.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to anyone who has no right to receive it. We may also contact you to ask you to provide further information in relation to your request to speed up our response.

12.4 We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you informed.

13. Data protection requirements

You have the right to:

13.1. Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.

13.2. Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of new data you provide to us.

13.3. Request deletion of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data under

local law. Please note that we may not always be able to comply with your erasure request for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

13.4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

13.5. Request restriction of processing of your personal data.

This enables you to ask us to suspend processing of your personal data in the following circumstances:

13.5.1. where you want us to establish the accuracy of the data;

13.5.2. where our use of the data is unlawful but you do not want us to erase it;

13.5.3. where we need to hold the data even if we no longer need it because you need it to establish, exercise or defend legal claims;

13.5.4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

13.6. Request the transfer of your personal data to you or a third party. We will provide to you, or a third party of your choice, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information you initially provided to us for consent, or where we used the information to perform a contract with you.

13.7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will notify you when you withdraw your consent.