This service (hereinafter “App” and “Website”) is made available by Bionic Reading AG, of Masanserstrasse 194, CH-7000 Chur, Switzerland (hereinafter “we” or “us”) as controller according to the applicable Swiss Data Protection Act (DSG).

Furthermore, if and when the EU General Data Protection Regulation is applicable, we will process personal data based on the following legal provisions:

Processing of personal data with the consent of the data subject (Art 6 (1) (a) GDPR).
Processing of personal data for the performance of a contract to which the data subject is party or in order to take steps prior to entering into a contract (Art 6 (1) (b) GDPR).
Processing of personal data for compliance with a legal obligation to which we are subject according to applicable EU law or according to the applicable law of a country in which the GDPR is applicable, in whole or in part (Art 6 (1) (c) GDPR).
Processing of personal data in order to protect the vital interests of the data subject or of another natural person (Art 6 (1) (d) GDPR).
Processing of personal data for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject. Legitimate interests include, but are not limited to our economic interest in being able to make available our Website and App, the security of information, the enforcement of our own legal claims, and compliance with Swiss law (Art 6 (1) (f) GDPR).

The App allows us to show you the following information: The Bionic Reading® App implements a new reading method that facilitates the reading of texts. The reader is only focusing on the highlighted initial letters of a word and lets the brain complete the word. This method allows readers to read faster and comprehend texts considerably more easily. We will process personal data when you use the App. Personal data mean information which pertain to a certain or identifiable natural person. Since we are committed to protecting your privacy when you use the App, we would like to inform you which personal data are processed when you use the App and our website, and how we handle that data. Furthermore, we will inform you on which legal basis we process your data, to the extent the processing of data is necessary to safeguard our legitimate interests, and we will also inform you of our legitimate interests.

Our privacy statement is available at https://bionic-reading.com/privacy-policy/ in the App or on the Website.

For further information on the scope of use and explanations on App versions as well as our license models, go to our Website at https://bionic-reading.com/.

1. Processing of your data

Certain data will already be processed automatically as soon as you use the App. More specifically, the following personal data will be processed.

1.1. Data which are collected when you download the MobileApp:
When you download the App, certain necessary data will be transferred to the App Store you have selected (e.g. Google Play or Apple App Store). Especially your e-mail address, account ID, the download time, payment information as well as the device ID will be processed. These data will be processed exclusively by the App store, and the processing activities are beyond our influence.

1.2. Data which are collected automatically:
We will collect certain data which are necessary for using the App (Mobile App, Desktop App, Web App) automatically once you use the App, including server logfiles (browser type and browser version, version of your operating system, Referrer URL, IP address, internal device ID, time of access, user IP address).

These data are transferred to us automatically in order (1) to allow us to provide the service and its related features; (2) to improve the functions and features of the App, and (3) to prevent and to eliminate misuse and malfunctions. These processing operations are legitimate because (1) they are necessary for the performance of the contract between you as data subject and us in order for you to use the App or (2) because we have a legitimate interest in guaranteeing the functionality and error-free operation of the App and in being able to offer a service in line with the market and your interests which overrides your rights and interests regarding the protection of your personal data.

1.3. Creation of a user account and registration – subscription:
You have to buy a subscription if you want to use all features of Bionic Reading®. You can register either via your Google account login, your Apple ID account or via e-mail (using our Stripe payment system). If you create a user account or register, we will use your access data (e-mail address and password) to give you access to and manage your user account (“compulsory data”). Compulsory data in connection with your registration are marked with an asterisk and are necessary to conclude the user contract. You cannot create a user account without disclosing these data.

We use compulsory data for your authentication during log-in and for password reset requests. We will process and use the data you have provided in connection with your registration in order (1) to verify your authorization to manage the user account; (2) to enforce the terms of use of the App and all related rights and obligations, and (3) to contact you to send you technical or legal notices, updates, safety messages or other messages relating to the management of the user account.

These processing operations are legitimate because (1) they are necessary for the performance of the contract between you as data subject and us in order for you to use the App or (2) because we have a legitimate interest in guaranteeing the functionality and error-free operation of the App.

Furthermore, you may use Bionic Reading® free of charge without registration. In this case, you will only be able to use limited features of the App.

1.4. Use of the App:
Depending on the selected conversion option, you may use the App to enter, manage, and edit various information, tasks, and activities. That information includes, but is not limited to texts, files or even websites converted with the Bionic Reading® method. We will upload the selected files or texts, convert them into the Bionic Reading® format, and display these to the user.

(1) In case of a chargeable subscription (registration necessary), your original text or original file will be saved as long as your contract with us is in effect, unless you delete the converted text earlier or (2) after 24 hours if you use the App without charge (no registration necessary).

The App therefore requires access to the Internet in order to save your entries on our servers. User data are processed only for the provision of the service. These processing operations are legitimate, because they are necessary for the performance of the contract between you as data subject and us in order for you to use the App.

Under no circumstances will we analyse or evaluate your texts.

2. Transfer or disclosure of data
Except in the cases explicitly described herein, your personal data will be transferred without your explicit prior consent only if permitted or necessary by law, for example, if processing is necessary to protect the vital interests of a user or those of another natural person.

2.1. We will transfer the data you have disclosed during registration within our company for internal administrative purposes, including joint customer support, when necessary.

A transfer of personal data is legitimate, because we have a legitimate interest in transferring data for administrative purposes within our firm, and because you have no overriding rights and interests regarding the protection of your personal data.

2.2. Personal data will be disclosed to law enforcement authorities or other agencies and, if necessary, to injured third parties or legal advisers if this is necessary to solve an unlawful or inappropriate use of the App. However, we will only do so if there are indications of unlawful or abusive conduct. Data may also be disclosed if this is necessary to enforce the terms of use or other legal claims. Also, we are obligated by law to provide information to certain public agencies upon their request. These are law enforcement agencies, authorities prosecuting violations carrying penalties, as well as fiscal authorities.

Any such disclosure is legitimate, (1) because processing is necessary for compliance with a legal obligation to which we are subject under national legislation which requires us to disclose data to law enforcement agencies, or (2) for the purposes of legitimate interests in disclosing the data to the above third parties if there are indications of abusive conduct, or to enforce our terms of use, other terms and conditions, or legal claims, and because you have no overriding rights and interests regarding the protection of your personal data.

2.3. We also have to rely on external service providers, including but not limited to IT service providers for the hosting and continuing development of the App, and on payment services providers. Any such disclosure is legitimate, because (1) we have a legitimate interest in transferring the data within our company for administrative purposes and because you have no overriding rights and interests in the protection of your personal data and (2) we have carefully selected, regularly audited and contractually obligated our external service providers to process all personal data exclusively in accordance with our instructions.

2.4. In the course of the ongoing development of our business, our corporate structure may change in that the legal form may change or subsidiaries, corporate shares or components are set up, purchased or sold. Customer information and, where appropriate, along with the transferring part of the business, will be disclosed in the course of these transactions. Whenever personal data are transferred as described above, we will ensure that this transfer is in compliance with this privacy statement and applicable data protection legislation. Any transfer of personal data is legitimate, because we have a legitimate interest in adjusting our corporate form to economic and legal conditions, and because you have no overriding rights and interests regarding the protection of your personal data.

3. Cross-border disclosure of personal data
We are processing data also in countries other than Switzerland. Personal data may be disclosed abroad if the Federal Council has decided that the legislation of the State concerned guarantees an adequate level of protection (Article 16 DSG). At this point, this is evident from Annex I of the Data Protection Regulation.

In order to guarantee the protection of users’ personal rights also in connection with these data disclosures, our contracts with recipients [service providers] abroad contain standard data protection clauses according to Article 16 (2) (d) DSG. Please use the contact details provided in order to learn more about these clauses.

4. Changes in purpose
Your personal data will be processed for purposes other than those described herein only if this is permitted by law or you have consented to the changed purpose of processing. If data are further processed for purposes other than those for which they were originally collected, we will inform you of these other purposes prior to processing and will provide you with any relevant information.

5. Data retention period
We will erase or anonymize your personal data as soon as they are no longer necessary for the purposes for which they were collected or used as described above. We will regularly retain your personal data while you use the App or throughout the term of the App contract, plus an additional 30 days during which we will retain backup copies after erasure, unless a longer retention period is necessary for criminal prosecution or to safeguard, assert or enforce legal claims. Any data and content you have uploaded for conversion will be retained throughout the subscription of registered users, unless you erase such data earlier, or for 24 hours after conversion for non-registered users, without affecting specific information in this Privacy Statement or legal requirements to retain and erase personal data, including but not limited to data which we have to retain according to tax law.

6. Payment procedure
We offer data subjects safe and sufficient payment options in connection with contractual and other relationships, based on legal obligations or otherwise on the basis of our legitimate interests. Besides banks and credit institutions, we rely on the following payment services providers:

Stripe, Inc., of 510 Townsend Street, San Francisco, CA 94103, USA; https://stripe.com. The Stripe Privacy Statement is available at https://stripe.com/privacy.

Apple Inc., of Infinite Loop, Cupertino, CA 95014, USA; (https://www.apple.com/apple-pay/). The Privacy Statement of Apple Pay is available at https://www.apple.com/legal/privacy/en-ww/.

Google Ireland Ltd., of Gordon House, Barrow Street, Dublin 4, Ireland; (https://pay.google.com/intl/en_en/about/). The Privacy Statement of Google Pay is available at https://policies.google.com/privacy.

These payment services providers will process data such as basic data, for example name and address, bank details such as account numbers or credit card numbers, passwords, TANS and checksums as well as information relating to contract, totals, and recipients. This information is necessary for the implementation of the transactions. However, the data entered are processed and retained only by the payment services providers, which means that we will not receive any account-related or credit-card related information, but merely information that the payment was confirmed or not made. Payment services providers might transfer data to credit agencies for the purpose of identity and credit checks. We incorporate the terms and conditions and privacy statements of the payment services providers by reference.

The payment transactions are subject to the terms and conditions and privacy statements of the relevant payment services providers (see above) which are available on their websites or transaction applications. We also incorporate these by reference for the purpose of further information and the assertion of rights of withdrawal, information and other rights of data subjects.

7. Web analysis – Google Analytics 4
Our Website uses Google Analytics 4 of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, to measure and analyse the use of our online offer based on a pseudonym user identification number. This identification number does not contain unique data such as names or e-mail addresses and serves to allocate analysis information to a terminal device to identify the content which users have retrieved during one or several transactions, which search words they have used and retrieved again, or how they have interacted with our online offer. Similarly, the time and duration of use, the sources of users that refer to our online offer, and technical aspects of their terminal devices and browsers are retained. In this context, pseudonym user profiles with information collected from the use of different devices are created and cookies can be set. Google Analytics does not log and save individual IP addresses of users. However, Analytics provides crude geographic location data by establishing the following metadata from IP addresses: city (and derived latitude and longitude of the city), continent, country, region, subcontinent (and ID based matches). The Google privacy statement is available at https://policies.google.com/privacy.

8. Social media
We are active on social media and process user data in this connection in order to communicate with our customers who are active there, or to inform these customers about ourselves and the services we offer. We would like to point out that user data may be processed in countries other than Switzerland and the European Union. This may pose risks for users, because it may be more difficult to enforce the rights of users. We use these services based on our legitimate interest in adjusting, if necessary, the services we offer online (App and Website) to the economic conditions, and because you have no overriding rights and interests in protecting your personal data.

Our Website contains links to the following social media platforms:

Instagram, of Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (https://www.instagram.com/bionicreading/);

Facebook of Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (https://www.facebook.com/bionicreading);

LinkedIn, of LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland (https://www.linkedin.com/company/bionic-reading.com);

YouTube, of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (https://www.youtube.com/@BionicReading_Official);

TikTok, of TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland (https://www.tiktok.com/@bionicreading);

X (formerly Twitter), of Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland (https://twitter.com/bionicreading);

Telegram, Telegram Broadcasts, Dubai (https://telegram.org);

We can see and process the following data which you have published on these platforms:

Basic data (e.g. names, addresses)
Contact details (e.g. email, phone numbers)
Content data (e.g. text entries, photos, videos)
User data (e.g. websites visited, interest in content, access times)
Meta and communication data (e.g. device identifiers, IP addresses).

Furthermore, social networks will regularly process your data for the purpose of market research and advertising. For example, based on your user behaviour and the resulting interests, user profiles can be created. User profiles can, in turn, be used to place ads in and outside of networks that presumably match your interests.

For these purposes, cookies are set on your computers as a rule. Also, data can be saved in user profiles regardless of the devices you use (especially if you are a member of and logged into the relevant platform).

9. Rights of data subjects
9.1. Right of information
You have the right to make a request at any time to access your personal data we have processed within the scope of Articles 25 et seq DSG. You may e-mail your request to the address below.

9.2. Right to data portability
You have the right to receive the personal data concerning you in a commonly used electronic format subject to Article 28 DSG.

9.3. Right to rectification and erasure of data
As a data subject, you have the right to obtain the rectification of inaccurate personal data. Furthermore, according to Article 32 (2) DSG, you have the right to lodge a complaint for the protection of privacy and obtain the erasure or destruction of personal data.

10. Right to file a report with the Federal Data Protection and Information Commissioner (FDPIC)
Furthermore, you have to right to file a report to the FDPIC if there are sufficient indications that a processing operation could infringe data protection legislation.

Federal Data Protection and Information Commissioner, of Feldeggweg 1, 3003 Berne, Switzerland, Phone +41/58 462 43 95 https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt/anzeigeformular_betroffene.html

11. Security
We are committed to security. For reasons of security and for the protection of the transfer of confidential content, such as inquiries you are sending to us as Website operator, this Website uses SSL/TSL encryption. You can recognize an encrypted connection if the browser’s address line switches from “http://” to “https://” and your web browser line displays the lock icon.

If SSL or TLS encryption is activated, any data you send us cannot be read by third parties.

The Bionic Reading® App and the Bionic Reading® Website are hosted on servers in Germany and Switzerland according to the highest security standards.

12. Contact
If you have any questions or comments on how we handle your personal data or if you want to exercise the rights of data subjects referred to in paragraphs 9 and 10, please contact:

Bionic Reading AG
Masanserstrasse 194
CH-7000 Chur
Switzerland
privacy@bionic-reading.com

13. Amendments of this privacy statement
We always keep this privacy statement up to date. We therefore reserve the right to change it from time to time and to subsequently add changes relating to the collection, processing, and use of your data. The updated privacy statement is always available at “Privacy Statement” (https://bionic-reading.com/privacy-policy/) in the App.

Last update: December 15, 2023
Bionic Reading AG, Chur, Switzerland