VitaNet Japan, Inc. Open! App Privacy Policy

1. No Personally Identifiable Information

Open! does not require users to create an account and does not collect personally identifiable information (“PII”) that directly identifies an individual, such as:

• name;
• email address;
• telephone number;
• postal address; or
• other information that directly identifies you.

Open! does, however, access and collect certain pseudonymous device, application, proximity, and location-related information necessary to demonstrate and evaluate its functionality.

Such information is not collected together with your name, email address, telephone number, postal address, or other information that directly identifies you.

Open! does not use collected information to identify individual users, create commercial user profiles, or provide targeted advertising.

2. Location and Proximity Information

Open! uses Bluetooth Low Energy (“BLE”) technology to detect nearby VitaNet Stations.

Depending on your Android version and device configuration, Open! may request Location and/or Bluetooth-related permissions in order to perform BLE scanning and detect nearby VitaNet Stations.

When a VitaNet Station is detected, Open! may access, process, or collect information including:

• the identifier of the detected VitaNet Station;
• the date and time the VitaNet Station was detected;
• information indicating proximity to the VitaNet Station; and
• technical BLE information necessary to demonstrate and measure operation of the service.

A VitaNet Station is installed at a particular physical location or area. Therefore, detection of a VitaNet Station may indicate that a device running Open! was near that location at a particular time.

For this reason, this information is treated as Location data for purposes of Google Play and applicable mobile platform privacy requirements.

Open! does not collect GPS coordinates for VitaNet Station detection and does not continuously track your GPS location.

The Location and proximity information collected by Open! is pseudonymous and is not collected together with information that directly identifies the individual using the device.

3. VitaNet Station and Customer Identifiers

VitaNet Stations use technical identifiers, including a Station identifier and a customer identifier, as part of the VitaNet system architecture.

In commercial deployments of VitaNet technology, a customer identifier may be associated with a VitaNet customer.

Open!, however, is a demonstration application and is not operated for a VitaNet customer. In the Open! demonstration environment, customer identifiers are technical demonstration identifiers and are not used by Open! to provide customer-specific commercial services.

These technical identifiers are used only as necessary to demonstrate, test, operate, and measure the performance of VitaNet technology.

4. Device and Application Identifiers

Open! may generate, access, or use a device-specific or application-specific identifier to operate and evaluate the App and AccuNotify™ service.

Such identifiers may be used to:

• associate technical events generated by the same App installation;
• prevent duplicate processing;
• operate notification functionality;
• measure service performance;
• troubleshoot technical issues; and
• maintain the reliability and security of the demonstration service.

These identifiers are not intended to directly identify the individual using the device and are not combined by VitaNet with names, email addresses, telephone numbers, or other directly identifying PII.

5. Notification and App Activity Information

Open! may collect information relating to the operation and use of notifications and other App functionality, including:

• whether and when a notification was generated or displayed;
• whether and when a notification was opened or tapped;
• the VitaNet Station associated with a notification;
• the content or destination associated with the notification;
• App interaction events; and
• technical information relating to App operation and performance.

This information is collected primarily to demonstrate the functionality of Open! and AccuNotify™ and to measure technical and operational performance, including notification impressions, interactions, and click-through rates.

Open! does not use this information for targeted advertising, commercial profiling, or customer-specific marketing analysis.

6. How We Use Information

Demonstrating Location-Relevant Functionality

VitaNet Station detection and related Location and proximity information are used to demonstrate how Open! can determine when a device is near a VitaNet Station and provide a relevant notification or App experience.

Operating Open! and AccuNotify™

We use VitaNet Station identifiers, timestamps, App or device identifiers, and related technical information to operate Open! and demonstrate the AccuNotify™ service.

Measuring Technical and Service Performance

We use Station detection events, notification impressions, notification interactions, and related technical information to measure:

• whether VitaNet Station detection is functioning correctly;
• whether notifications are generated and displayed as intended;
• notification interaction rates;
• system reliability and response time; and
• overall technical performance of Open! and AccuNotify™.

Improving the Demonstration Service

We may analyze technical and usage information to diagnose problems, improve reliability, develop functionality, and improve the performance of VitaNet technology.

Security and Troubleshooting

Technical information may be used to detect errors, investigate misuse, protect our systems, and provide technical support.

7. Background Operation

A core function of Open! is to demonstrate detection of nearby VitaNet Stations and delivery of relevant notifications.

Where permitted by the Android operating system and by the permissions granted by the user, Open! may use Bluetooth scanning and location-related functionality when the App is not actively displayed on the screen.

This background functionality may result in collection of a VitaNet Station identifier, detection time, and associated proximity information.

Open! does not use this functionality to continuously collect GPS coordinates or create a continuous GPS history of a user's movements.

8. Sharing of Information

VitaNet does not sell or rent personally identifiable information, Location data, or other information collected through Open!.

Because Open! is a demonstration application, information collected through Open! is not provided to VitaNet customers for customer-specific advertising, marketing, profiling, or commercial analytics.

Information may be disclosed only in the following limited circumstances.

Service Providers

We may use cloud infrastructure, hosting, security, analytics, and other service providers to operate Open! and AccuNotify™.

These providers may process information on VitaNet's behalf only as necessary to provide their services and subject to appropriate contractual and security obligations.

Legal and Security Requirements

We may disclose information where required by law, regulation, legal process, or governmental request, or where reasonably necessary to protect the rights, security, or property of VitaNet, our users, or others.

9. Data Security

VitaNet uses reasonable administrative, technical, and organizational safeguards designed to protect information handled through Open!.

Data transmitted between Open! and VitaNet systems is protected using encryption in transit where applicable.

However, no electronic transmission or storage system can be guaranteed to be completely secure.

10. Data Retention and Deletion

We retain pseudonymous Location, proximity, notification, App activity, and technical information only for as long as reasonably necessary to:

• operate and demonstrate Open! and AccuNotify™;
• evaluate technical and service performance;
• troubleshoot technical issues;
• maintain system security;
• improve VitaNet technology; and
• comply with applicable legal obligations.

Information may subsequently be deleted, aggregated, or de-identified as part of VitaNet's normal data retention processes.

Open! does not create user accounts and does not collect information that enables VitaNet to identify an individual user. VitaNet therefore does not maintain a relationship between a person's identity and the pseudonymous technical records generated by Open!.

As a result, VitaNet generally cannot identify which stored technical records relate to a particular individual and cannot perform user-specific deletion based on a person's name, email address, or other identifying information.

This limitation is a consequence of Open!'s privacy-preserving design and its intentional avoidance of collecting personally identifiable information.

11. User Choices and Permissions

Location and Bluetooth Permissions

Users can control Location and Bluetooth-related permissions granted to Open! through their device settings.

If permissions necessary for BLE scanning are denied or revoked, Open! may be unable to detect nearby VitaNet Stations and related functionality may not operate.

Notifications

Users can enable or disable Open! notifications through their device notification settings.

Uninstalling Open!

Users can stop future collection of information by Open! by uninstalling the App.

Uninstalling Open! does not necessarily cause previously collected pseudonymous technical information to be individually identified or immediately deleted. Such information is handled in accordance with the data retention practices described above.

12. Children's Privacy

Open! does not require users to provide their name, date of birth, age, email address, or other information that directly identifies them.

Because Open! does not collect information that identifies an individual user, VitaNet does not determine the age of users based on the data collected through the App.

Open! is not specifically directed to children. As described in this Privacy Policy, Open! does not collect personally identifiable information from its users, regardless of age.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to Open!, the AccuNotify™ service, our information practices, legal requirements, or mobile platform requirements.

When this Privacy Policy is updated, we will revise the “Last Updated” date at the top of this page.

Where required by applicable law, we will provide additional notice or obtain consent for material changes.

14. Contact Us

Questions or concerns regarding this Privacy Policy or VitaNet's handling of information may be directed to: