Last Updated: 2026 / 06 / 23
Effective Date: 2026 / 06 / 23
1. Special Categories of Personal Data We Collect
Where you voluntarily provide and explicitly consent, we collect and process the following wellness, lifestyle, sexual life, sexual orientation and behaviour-related information, which qualifies as “special categories of personal data” under Article 9 GDPR (particularly when used for wellness assessment or inference):
Chat logs or communication records with customer service personnel, Email correspondence, Product reviews and comments, Order history, Shopping cart contents, and Search query keywords.
The above data, individually or combined, may reveal/infer your wellness status, lifestyle, mental state, dietary habits, diseases, and medication usage. We therefore protect and process it according to “Special Categories of Personal Data” standards.
2. Our Purposes for Using This Data
We use the above Special Categories of Personal Data for the following specific purposes within necessary and appropriate limits:
2.1. Providing, Maintaining, and Improving wellness & Fitness Services:
- Recording/displaying your activity, sleep, and wellness data trends;
- Generating personalised exercise, sleep, stress management, and wellness recommendations;
- Providing assistive wellness management via AI conversations/recommendations (non-medical diagnosis).
2.2. Account and Service Security:
- Using profile pictures etc. to help identify accounts and prevent misoperations;
- Anomaly detection for account/data security.
2.3. Customer Service and Complaint Handling:
- Analysing user complaints/images for issue resolution, product/service improvement, quality/safety tracking.
2.4. Compliance and Risk Management:
- Meeting applicable laws/regulatory requirements;
- Establishing, exercising, or defending legal claims.
We will not use this data for incompatible purposes unless we obtain your renewed explicit consent or another legal basis applies.
3. Legal Basis for Processing Special Categories of Personal Data
Under GDPR, we process your data on these legal bases:
3.1. General Personal Data Processing:
- Art. 6(1)(b) GDPR: Necessary for contract performance (e.g., wellness records/analysis services);
- Art. 6(1)(f) GDPR: Necessary for legitimate interests (without overriding your rights), e.g., product improvement, service security;
- Art. 6(1)(c) GDPR (Where applicable): Necessary for legal obligations.
Special Categories of Personal Data - Additional Conditions:
- Art. 9(2)(a) GDPR: You have given explicit consent to processing these Special Categories of Personal Data; and/or
- Art. 9(2)(h), (i), or (j) GDPR (Where applicable): For wellness/social care, public wellness, or research/statistics under German law.
In consumer commercial contexts, we primarily rely on your explicit consent for processing wellness data etc.
4. Mandatory Provision and Consequences of Non-Provision
You have no legal obligation to provide the above Special Categories of Personal Data. If you choose not to provide or consent to processing:
- Limited/unavailable use of wellness assessment, exercise/sleep analysis, and AI wellness recommendations;
- Basic functions (account registration, basic info display) remain unaffected.
5. Data Protection Measures
Special Categories of Personal Data receives stricter security than general data:
- Industry-standard encryption for transmission/storage;
- Strict access controls (least privilege principle);
- Security logging and regular audits;
- Data minimisation and deletion post-purpose achievement.
6. Data Sharing and International Transfers
Where necessary, disclosure to:
- Data processors on our behalf (cloud, analytics) under GDPR-compliant Data Processing Agreements;
- International transfers: Appropriate safeguards per GDPR Chapter V (e.g., Standard Contractual Clauses, Binding Corporate Rules).
7. Your Rights
- Art. 15-22 GDPR: Access, Rectification, Erasure, Restriction, Objection, and Data portability;
- Right to withdraw consent at any time (does not affect prior processing lawfulness).
To exercise any of the above rights, or if you have questions about our processing of your Special Categories of Personal Data, please contact us via:
Mailing Address: RM 503, 5/F, Hang Seng Castle Peak Road Building, 339 Castle Peak Road, Cheung Sha Wan, Kowloon, Hong Kong, China
Email: data_protect@myusay.com
Phone: +852 69597886
Fison Health Co., Limited
Complaints: Berlin Commissioner for Data Protection and Freedom of Information.