Tempus Privacy Policy

(Last updated 21st August 2022)

1. Summary of this Privacy Policy

At Vaelly, we believe in a right to privacy and that the ownership of personal sensitive data belongs to the user and therefore we are committed to achieving the highest standards of privacy. To achieve this goal, the Tempus Period App has been designed as a privacy first user experience, with no user data leaving your device and no analytics or advertising. All paid content is offline, requires no internet connection and there is no tracking of the user experience.

Put simply: how and why we process your personal data within the Tempus App:

• To use the Tempus App, you are required to provide a username, month and year of birth and acknowledgement of consent. Your age is used to determine the type of consent required and may be used to filter the local paid content based on age rating. No other information is required to create an account. The user account exists locally on the device only and therefore login is not required, though the user can enter an optional privacy pin. The local database is not encrypted. No data intentionally leaves the device and we do not use any form of analytics or third-party service to analyse your usage

• For In app purchases, the app upgrade and paid content are managed within the relevant app store account, i.e. Apple or Google. For the purposes of payment and restoration of in app purchases, Apple or Google may store the relevant information required to complete these activities. The Tempus does not make use of this data apart from the purposes of authorising in app purchases and restoration of prior purchases.

• To submit feedback, you are required to only enter a category and description of the feedback. We do not require an email or further contact details, but if provided these are only used for the purposes of responding to your enquiry.

Please read the whole of this Privacy Policy to understand all this in more detail. We have done our best to make it as clear and comprehensible as possible. If you have any questions, do reach out to us at privacy@vaelly.com.au.

2. Privacy Policy

Vaelly Software Solutions Pty Ltd is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information. We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au

What is Personal Information and why do we collect it?

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. When we collect Personal Information, we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Here are the types of data we collect:

Device data

In the Tempus App we do not automatically collect device data, e.g. model, name or identifiers of device, however this information may be requested to enable us to help fix bugs or respond to user enquiries. On our website, we may collect information about your browser and browser settings, the operating system you use, and the system settings of your device. This information helps us tailor our services to our users' devices and improve our services.

Event and usage data

We do not gather event or usage data IP address In the Tempus App, we do not automatically collect IP addresses.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

• For the primary purpose for which it was obtained

• For a secondary purpose that is directly related to the primary purpose

• With your consent; or where required or authorised by law.

Health and sensitive data

We process health data and sensitive data that you choose to track in the Tempus app to provide our service to you. Such health data may include your cycle information (e.g., period length, pain, or spotting) and depending on the data you provide, it may also contain information about your general health (e.g., weight, body temperature, mood and symptoms) This data is necessary for Tempus to deliver the services you use. We only process the data you provide to us by tracking it in the Tempus app. At no stage does this data leave your data and is processed locally with in the app on your device.

Legal basis: The legal basis for processing the above data is Art 6 section 1(b) of the European General Data Protection Regulation (GDPR). Tempus may use this data for the purpose of improving the Tempus app, the services we provide to you, and to prevent abusive use of our service. In accordance with Art 6, section 1(f) GDPR, we consider that we have a legitimate interest to offer an error-free and functional service.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

• Third parties where you consent to the use or disclosure; and

• Where required or authorised by law.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

Your user account exists on the local device only and therefore login is not required. Note that though the user can enter an optional privacy pin the local database is not encrypted and any exported backups are not encrypted. It is the responsibility of the user to store any backup in a secure location.

No data intentionally leaves the device and we do not use any form of analytics or third-party service to analyse your usage.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions.

If you wish to access your Personal Information, please contact us in writing.

Vaelly Software Solutions Pty Ltd will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information. In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy please contact us at: privacy@vaelly.com.au

3. Communications, Surveys and Newsletter Activities

Vaelly may use your personal information, such as your email address, to contact you with messages, emails, and newsletters. These may include push notifications, in-app messages and emails to deliver health content and occasional promotional materials that may be of interest to you. If you have registered for a newsletter service of Tempus, Vaelly will process your information provided in the registration, which may include your name and email address to send you our newsletters you have subscribed to.

You can unsubscribe from our newsletter by clicking the unsubscribe link at the bottom of the message, and you can disable notifications sent by Tempus in your device settings.

Tempus may communicate with you via email if you have contacted Tempus for questions or support requests in connection with our services or the Tempus app. For certain support requests, Tempus will have to access and process your personal data, including your health data for the purpose of answering your request. You explicitly provide your consent for the processing of your personal data, including your health data for answering your support request.

In order to provide these services, Tempus may share information such as your email address to third-party providers for the sole purpose of carrying out such newsletter services, surveys or notifications.

4. Young Users

The Tempus Period app is a period tracker designed for helping younger children understand and track their periods. Tempus does not gather any identifiable personal data, e.g. names, addresses or email addresses. By downloading and creating a local user account you are required to confirm that you are at least 13 years old, or that your parents have agreed that you can use the Tempus app.

If you are located in the EU, you can only use our services if you are over the relevant age at which you can provide explicit consent to the processing of your data under the laws of your country (this is between 13 and 16 years old, depending on the country you live in) or if you have the consent of your parent or legal guardian.

If you are in the US, please note that Tempus has been specifically designed to not require or collect identifiable Personal Information as defined by the Children's Online Privacy Protection Act of 1998 and the regulation thereunder. Verifiable parental consent is therefore not required.

Regardless of the above, if you are a parent and learn that your child is using Tempus without your permission or if you have any specific question about data privacy at Tempus, do not hesitate to get in touch with us at privacy@vaelly.com.au

As a parent you can delete the local user account, and this will remove all health data from the device.

5. Changes to this Privacy Policy

Tempus reserves the right to amend this Privacy Policy from time to time to reflect changes in the law, our data collection and data use practices, the features of Tempus’s services, or advances in technology. Please check this page periodically for changes and refer to the “last updated” date at the top of the page to know if it has been revised since your last visit. If we make any changes to this Privacy Policy that we consider to be material to your consent, we will notify you of them.