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Legal Document

PRIVACY POLICY & DATA PROTECTION

Effective as of: 21.11.2025

1

TRUST COMMITMENT (PREAMBLE)

The protection of your privacy is not an option, it is the foundation of our medical ethics. The Novacare Technologies Association (hereinafter "Novacare Technologies"), as a Swiss law association currently being registered, is committed to treating your data with the strictest confidentiality, in accordance with the Swiss Federal Data Protection Act (nFDPA) and the EU General Data Protection Regulation (GDPR).

2

THE DATA CONTROLLER

The entity responsible for collecting and processing your data is:

Novacare Technologies Association

Canton of Vaud, Switzerland

contact@sylvanacare.ch

3

SOVEREIGN & SECURE HOSTING (SWITZERLAND)

Your data is not stored in an obscure "Cloud". It is physically hosted in Switzerland, in the heart of Europe, benefiting from one of the most protective legislations in the world.

Hosting Partner

  • β€’Infomaniak Network SA
  • β€’Headquarters: Rue EugΓ¨ne-Marziano 25, 1227 Les Acacias, Geneva, Switzerland.

Security Certifications

  • β€’Infomaniak's datacenters are certified ISO 27001 (Information Security), ISO 9001 (Quality) and ISO 50001 (Energy Management).

Guarantee

  • β€’Infomaniak commits that data never leaves Swiss jurisdiction.
4

WHAT DATA DO WE COLLECT?

We collect two distinct types of data:

A. Administrative Data (Identity)

Necessary to manage your membership and member account.

  • β€’Last name, First name, Email, Phone
  • β€’Billing address
  • β€’Public Wallet Address for $NOVA Token management

B. Sensitive Data (Health & Wellbeing)

Necessary for the "Copilot" AI operation and your monitoring.

  • β€’Declarative data: Questionnaire responses (Stress, Sleep, Pain, Mood)
  • β€’Connected data (if enabled): Heart rate, physical activity (via Apple Health/Google Fit)
  • β€’Medical history: Documents transmitted for clinical analysis

Important: This sensitive data is subject to enhanced encryption and pseudonymization before any analysis.

5

WHY DO WE USE YOUR DATA? (PURPOSES)

5.1. For Your Care (Primary Purpose)

  • β€’Configure your "Health GPS" and personalize daily recommendations
  • β€’Detect weak signals (e.g.: sleep deterioration) to trigger a preventive alert to our care team

5.2. For "DeSci" Research (Scientific Purpose)

  • β€’Only with your explicit consent (Pioneer Status)
  • β€’Your data is anonymized and aggregated to train our AI models (Deep Phenotyping) on specific cohorts
  • β€’This data serves to build the Global Health OS, in accordance with our Scientific Council's ethical guidelines
6

ARTIFICIAL INTELLIGENCE & AUTOMATED DECISION

Our "Copilot" uses Artificial Intelligence algorithms to analyze your data.

Human Safeguard ("Human-in-the-loop")

  • β€’No critical medical decision (diagnosis, treatment cessation) is made by AI alone. AI only suggests or alerts. Final validation always belongs to a healthcare professional or patient.

Model Security

  • β€’Our models are audited to avoid biases and guarantee response reliability (Trustworthy AI).
7

DATA SHARING

Your personal data is never sold to advertising third parties. It can only be shared:

  • With Novacare Technologies caregivers: To ensure your care
  • With research partners (INSERM, CHU): Only in anonymized and aggregated form
  • With authorities: If Swiss law requires it (e.g.: judicial mandate)
8

YOUR RIGHTS (DATA CONTROL)

In accordance with nFDPA, you have the following rights:

  • Right of access: See all data we have about you
  • Right to be forgotten: Request complete deletion of your data
  • Right to portability: Retrieve your complete medical file in a readable format
  • Right to withdraw consent: Leave the research program at any time
9

MODIFICATIONS

This policy may evolve to comply with legal standards. The online version always prevails.

Questions about your data?

Contact our Data Protection Officer (DPO)

contact@sylvanacare.ch
Privacy Policy and Data Protection | Novacare Technologies | Novacare Technologies