Privacy Notice For Testers

PRIVACY NOTICE FOR TESTERS OF THE AURAX BETA TEST


Through this Privacy Notice for Testers of the Aurax Beta Test, we inform you about the use of your personal data collected when you apply to become a tester (hereinafter, the "Tester") of the MouthX device (hereinafter, the "Beta Product").

Additionally, we detail the purposes of data processing, the legal bases that legitimize such processing, the possible disclosure of your data to third parties, the retention periods of your data, as well as the rights you are entitled to under the General Data Protection Regulation (GDPR) and Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights.

  1. Basic Information


Data Controller 

XPND TECHNOLOGIES, S.L.

Purpose

Management, development, execution, and monitoring of participation in the beta test program.

Legal Basis

Performance of the contract.

Recipients

Service providers. Additionally, international data transfers may occur.

Rights

The right to access, rectify, or delete your data, as well as other rights, in accordance with additional information.

Additional Information

You can find more information below.


2. Who is responsible for processing your personal data?

The data controller responsible for processing personal data is XPND TECHNOLOGIES, S.L., with its registered office at Av. Santa Rosa dels Pins, 99, 08358 Arenys de Munt (Barcelona), and NIF B13919741 (hereinafter, “AURAX”). Contact details for matters related to personal data protection: auraxtechnology@gmail.com.

3. What categories of personal data does AURAX process?

The categories of personal data processed include:

  • Identifying data of applicants requesting to become a Tester: full name, gender, city of residence, phone number, and email address.

  • Information about applicants and descriptions of the potential use of the Beta Product as provided by the applicants.

  • Identifying data of selected Testers: full name, gender, postal address, phone number, and email address.

  • Evaluation-related data: opinions, statements, comments, suggestions, reactions, habits, preferences, and ratings provided by Testers, as well as monitoring of the use of the Beta Product.

  • Audiovisual data: images and voice of the Tester.

  • Data related to subscription to commercial communications: engagement metrics from marketing emails, including email read status and timestamp, as well as subscription management information.

Additionally, special categories of personal data will also be processed:

  • Comments provided by applicants: descriptions in the application form may contain information regarding the applicant's health status or imply health-related deductions.

  • Anatomical data of the Testers: 3D images of the mouth, teeth, and oral structure, exact measurements of the oral cavity, potential dental alignment or misalignment, characteristics of oral tissue, visible anomalies, specific parameters of the personalized Beta Product, and, if applicable, a record of adjustments or modifications made to the device.

  • In some cases, audiovisual data may include information about ethnic origin, religious beliefs, or health data when visible in recordings and/or photographs or mentioned by Testers.

4. For what purposes and on what legal basis are the data processed?

Personal data will be processed for the following purposes:

  1. Managing applications and participation in the Beta Product testing.

  2. Manufacturing the personalized Beta Product.

  3. Preparing and delivering the personalized Beta Product.

  4. Tracking use and optimizing the Beta Product.

  5. Taking photographs and recording in-person test sessions.

  6. Publishing content on social media and other digital platforms.

  7. Evaluating the functionality and quality of the Beta Product, identifying improvements, and addressing potential issues.

  8. Sending commercial communications with information about AURAX products, promotions, giveaways, contests, and updates on our offerings, as well as other current and future AURAX services, and conducting customer satisfaction surveys.

The legal basis for data processing in relation to the aforementioned purposes is the performance of a contract, as per Article 6.1(b) of the GDPR.

The legal basis for processing data for the purpose of sending commercial communications (point h) is your consent, as per Article 6.1(a) of the GDPR.

Regarding the processing of special categories of personal data related to the purposes stated in sections a), b), e), and f), the legal basis for data processing is the consent of the applicants and/or Testers, in accordance with Article 6.1(a) in conjunction with Article 9.2(a) of the GDPR.

5. Are you required to provide your data?

Without providing the personal data described in section 4, points a)–g), it is not possible to apply for or participate in the Beta Product testing. Consent is entirely voluntary and may be withdrawn at any time. If consent for the processing of special categories of personal data is not granted, the Tester will not be able to participate in the AURAX testing program.

6. Security Measures

AURAX is committed to protecting the personal data of applicants and Testers by implementing technical and organizational measures to ensure that data is processed lawfully, fairly, transparently, appropriately, limitedly, accurately, and in an up-to-date manner. AURAX takes all reasonable measures to ensure that inaccurate or incomplete data is deleted or corrected without delay and will apply any other security measures that may be legally required in the future.

7. Who receives your data?

Personal data, including images and recordings, may be shared with service providers with whom AURAX contracts or may contract, acting as data processors. These may include, for example, providers of recording functions as well as data storage services.

8. Are your data transferred to third countries?

Personal data will only be transferred to recipients outside the European Economic Area (EEA) if the European Commission has recognized the third country as providing an adequate level of protection, if an appropriate level of protection has been agreed upon with the data recipient (via EU standard contractual clauses), or if the applicant and/or Tester has provided their explicit consent for such transfer.

9. How long will your data be retained?

Personal data generated during participation in the beta test will be retained for a maximum of five years. Data obtained through consent will be retained until such consent is withdrawn, at which point they will be blocked until the applicable legal retention periods expire. Once these periods have elapsed, the data will be deleted unless there is a legitimate interest or a legal obligation requiring their retention.

10. What data protection rights do you have?

Applicants and/or Testers may exercise their rights of access, rectification, objection, restriction of processing, erasure, portability, and the right not to be subject to automated decision-making at any time by sending an email to dataprotection@aurax.tech. Additionally, you may withdraw your consent at any time with future effect, without affecting the lawfulness of processing based on consent before its withdrawal. If consent is withdrawn, the data will be deleted. Furthermore, the Tester has the right to file complaints with the Spanish Data Protection Agency (Agencia Española de Protección de Datos) if they deem it necessary.

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01.03.2025