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Consent to the Processing of Wellbeing Data and Measurements

Version 1.0 of 1 November 2026

This version is in force and is applied on the service. The text is under review by a lawyer.

1.1. I, a user of the NAP Store service (https://store.napsystem.com, the "Service"), freely, of my own will and in my own interest, give specific, substantive, informed, conscious and unambiguous separate explicit consent to [LEGAL ENTITY NAME], Republic of Serbia, MB [МБ], PIB [ПИБ], address: [АДРЕС] (the "Operator"), to process data about my wellbeing and the measurements described below.

1.2. These data may be data concerning health — a special category of personal data. Legal basis: Article 9(2)(a) GDPR, Article 17(2)(1) of the Serbian Law on Personal Data Protection (ZZPL), Article 10(2)(1) of Russian Federal Law No. 152-FZ "On Personal Data".

2. Which Data

  1. Questionnaire answers before and after a listening session — my own assessment of how I feel (for example, level of relaxation or tension).
  2. Heart rate and heart rate variability (HRV) — from connected sensors or from the built-in simulator (the Service currently uses a simulator; connecting real sensors is planned).
  3. Timestamps of questionnaires and measurements.
  4. Link to the session — which app I listened to and in which session.

3. Purposes

3.1. The data are used only to:

  1. show me my own dynamics — how my wellbeing changes before and after sessions;
  2. produce anonymised aggregate statistics for app developers. Developers see only aggregated figures; groups of fewer than 5 people are hidden; my individual data are never shown to developers;
  3. improve the Service — only on the basis of aggregated data.

4. What We Do Not Do with These Data

  • We do not use them for diagnosis or treatment. The Service is not a medical service; measurements and questionnaires are for personal wellbeing and relaxation only and do not replace a consultation with a doctor.
  • We do not share them with employers or insurers.
  • We do not sell them.
  • We do not use them for advertising or advertising profiling.

The values shown by the Service are not medical measurements and may be inaccurate. If you feel unwell, consult a doctor.

5. Operations and Recipients

5.1. I consent to the collection, recording, organisation, accumulation, storage, rectification, retrieval, use, anonymisation (for aggregate statistics), blocking, erasure and destruction of these data by automated means.

5.2. The data are stored with the Operator's hosting provider [ХОСТИНГ-ПРОВАЙДЕР] on a server located in: [СТРАНА РАЗМЕЩЕНИЯ СЕРВЕРА], acting as a processor on the Operator's behalf. The data are not disclosed to anyone else in a form that identifies me. If the server is located outside my country of residence, I consent to the cross-border transfer of these data to that country with the safeguards described in the Privacy Policy.

5.3. The data are protected by the same measures as other Service data: encrypted connections (TLS), server-side role-based access control, audit log, daily verified backups.

6. Voluntary

6.1. This consent is voluntary. If I do not give it, the Service works fully except for the questionnaire and measurement features. Refusing does not affect purchases, subscriptions or listening.

7. Retention

7.1. This consent is valid from when I switch the toggle on until I withdraw it or delete my account.

7.2. The data are kept for 365 days from recording (by default) and are then deleted automatically.

7.3. The data are also deleted immediately when I withdraw consent or delete my account. They disappear from backups within 14 days at the latest.

8.1. I can withdraw consent at any time in "Profile → Data & consent" by switching the toggle off, or by sending a request to [E-MAIL ПО ПЕРСОНАЛЬНЫМ ДАННЫМ].

8.2. On withdrawal, all my measurements and questionnaire answers are deleted immediately. Withdrawal does not affect the lawfulness of processing before it. Aggregate statistics already produced in a form that does not identify me are not affected.

9.1. Consent is given via a separate toggle (checkbox) that is not switched on in advance, in "Profile → Data & consent". The text of this consent is available via the link next to the toggle.

9.2. More information on processing is set out in the NAP Store Privacy Policy.

Notes for the lawyer (remove after review)

  1. Written form (152-FZ Art. 10(2)(1), Art. 9(4)). Health data require consent in written form; a profile toggle may be insufficient. Options: simple electronic signature (63-FZ Art. 6(2)) with an e-mail confirmation code and an e-signature agreement in the Terms of Use; keeping evidence (time, text version, account ID). Art. 9(4) also requires the subject's details (full name, address, ID document) — assess applicability.
  2. Data qualification. Self-reported scores and heart rate/HRV for wellbeing purposes are conservatively treated as health data; confirm.
  3. Localisation (Art. 18(5)) if [СТРАНА РАЗМЕЩЕНИЯ СЕРВЕРА] is outside Russia; Roskomnadzor notifications (Art. 22 — stating special categories; Art. 12 — cross-border transfer).
  4. k = 5 threshold for aggregates — assess whether anonymisation is sufficient (incl. differencing risk across repeated queries).
  5. Real sensors. Connecting third-party sensors may introduce new recipients — the consent would need updating.
  6. DPO (ZZPL Art. 56, GDPR Art. 37) and DPIA (ZZPL Art. 54, GDPR Art. 35) — assess the need as the volume of health data grows.
  7. EU representative (Art. 27 GDPR) — if EU users are targeted; a Serbian representative is not needed (the operator is Serbian).
  8. [ХОСТИНГ-ПРОВАЙДЕР], [ПОЧТОВЫЙ СЕРВИС] (no measurement-related e-mails are sent — confirm), technical log retention of [90] days — confirm.
  9. Age — 18+; decide whether health data of persons under 18 should be excluded even via a parent's account.
  10. "Immediate" deletion — confirm that backups (14 days) are acceptable as an exception.

Version 1.0 of 11/1/2026