Account Deletion

How can I delete my AxhiTest account?

In accordance with the European General Data Protection Regulation (GDPR), you have the right to request the deletion of your account at any time. To do so, please send an email to axhitest-dev@willpharma.com with the subject line "Account Deletion Request".

What should I include in my request?

Please include the following information so we can identify and process your request:

• Your full name as registered in the application
• The email address associated with your AxhiTest account

What happens after I request account deletion?

Once we receive your request, WillPharma will verify your identity and proceed with the permanent deletion of your account. Your account and all associated personal data will be removed from our systems within 30 days of your request, as required by Article 17 of the GDPR (Right to Erasure).

You will receive a confirmation email once the deletion has been completed. Please note that account deletion is irreversible and you will no longer be able to access the AxhiTest application with this account.

Data Deletion

How can I request the deletion of my personal data?

Under Article 17 of the GDPR (Right to Erasure), you have the right to request the deletion of your personal data held by WillPharma without deleting your account. To exercise this right, please send an email to axhitest-dev@willpharma.com with the subject line "Data Deletion Request".

What data can I request to be deleted?

You may request the deletion of any or all of the following personal data:

• Daily health entries and symptom records
• Treatment history and related data
• Questionnaire responses
• Any other personal information stored in the application

Are there exceptions to data deletion?

In certain cases, WillPharma may be required to retain some data to comply with legal obligations (Article 17(3) of the GDPR), such as:

• Data required for compliance with regulatory obligations in the pharmaceutical sector
• Data necessary for the establishment, exercise, or defence of legal claims
• Data required for public health purposes in the public interest

If any of these exceptions apply, we will inform you about which data is retained and the legal basis for doing so.

How long does it take?

WillPharma will process your data deletion request within 30 days of receipt. If the request is complex or we receive a high volume of requests, this period may be extended by an additional 60 days, in which case we will notify you. You will receive a confirmation email once the deletion has been completed.

Your other rights under the GDPR

In addition to the right to erasure, you also have the right to:

• Access your personal data (Article 15)
• Rectify inaccurate personal data (Article 16)
• Restrict the processing of your data (Article 18)
• Data portability to receive your data in a structured format (Article 20)
• Object to the processing of your data (Article 21)

To exercise any of these rights, please contact us at axhitest-dev@willpharma.com.

Privacy Policy

Who is the data controller?

WillPharma is the data controller responsible for the processing of your personal data collected through the AxhiTest application. For any questions regarding our privacy practices, you can contact us at axhitest-dev@willpharma.com.

What personal data do we collect?

When you use AxhiTest, we may collect the following categories of personal data:

• Identity data: name, email address, and account credentials
• Health data: daily health entries, symptom records, perceived severity levels, and sweat level indicators
• Treatment data: treatment plans, phases, frequencies, and recurrence information
• Questionnaire data: responses to health-related questionnaires
• Technical data: session information and device identifiers necessary for the functioning of the application

Why do we process your data?

Your personal data is processed for the following purposes and legal bases:

• Performance of a contract (Article 6(1)(b) GDPR): to provide you with the AxhiTest service, manage your account, and track your health entries and treatments
• Explicit consent (Article 9(2)(a) GDPR): to process your health data, which is considered a special category of personal data
• Legitimate interest (Article 6(1)(f) GDPR): to improve the application, ensure security, and prevent fraud
• Legal obligation (Article 6(1)(c) GDPR): to comply with applicable pharmaceutical regulations and legal requirements

How do we protect your data?

WillPharma implements appropriate technical and organisational measures to ensure the security of your personal data, in accordance with Article 32 of the GDPR. These measures include:

• Encryption of data in transit and at rest
• Secure authentication mechanisms with session-based access control
• Access restrictions ensuring only authorised personnel can access personal data
• Regular security assessments and monitoring

Who has access to your data?

Your personal data may be accessed by authorised WillPharma staff for the purposes described above. We do not sell your personal data to third parties. Data may be shared with:

• Service providers: hosting and infrastructure providers who process data on our behalf, bound by data processing agreements
• Regulatory authorities: when required by law or pharmaceutical regulations

How long do we retain your data?

Your personal data is retained for as long as your account is active and as necessary to provide you with the AxhiTest service. After account deletion, your data will be permanently removed within 30 days, unless a longer retention period is required by law or regulatory obligations in the pharmaceutical sector.

International data transfers

Your personal data is stored and processed within the European Economic Area (EEA). If any transfer outside the EEA is necessary, WillPharma will ensure appropriate safeguards are in place, such as Standard Contractual Clauses (Article 46(2)(c) GDPR).

Your rights

Under the GDPR, you have the right to access, rectify, erase, restrict, port, and object to the processing of your personal data. You also have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact us at axhitest-dev@willpharma.com.

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

Changes to this privacy policy

WillPharma reserves the right to update this privacy policy at any time. Any significant changes will be communicated to you via the application or by email. We encourage you to review this page periodically.