Terms and Conditions
Last updated: 15th Feb 2025
Thank you for choosing to use our application Generation Lotus (“App”). We are committed to protecting your personal data and respecting your privacy. This Privacy Terms and Conditions document explains how we collect, use, store, and disclose your personal information in compliance with the EU General Data Protection Regulation (GDPR), Dutch data protection laws, and, where relevant, the U.S. Health Insurance Portability and Accountability Act (HIPAA).
1. Data Controller
The data controller responsible for your personal data is:
Generation Lotus
KvK: 96103094
Hardik.Gala@generationlotus.com
2. Data We Collect
We may collect the following types of data when you use the App:
Personal Identification Information
- Name, email address, and other contact details you provide during account registration.
- Payment details (where applicable) for in-app purchases or subscription services.
- Device and Usage Information
- Device identifiers (e.g., IP address, device model, operating system).
- App usage data (e.g., pages visited, features used, crash reports, log files).
- Location Data (where applicable)
- If you opt in to share your location, we may collect and process location data to provide location-based services.
Voice Interaction Data (AI Voice Counsellor)
- The content of voice interactions you have with our AI voice counsellor.
- These interactions are processed through our HIPAA-compliant voice application programming interface (“VAPI”) to ensure the confidentiality and security of any health-related data. We do not record any or save conversations you shall have with the AI voice counsellor.
Other Information
- Any data you choose to provide to us voluntarily (e.g., user support requests, feedback).
3. Legal Bases for Processing
We process your personal data based on one or more of the following legal grounds:
Consent
- Where you have expressly given consent (e.g., for marketing communications or optional location services).
Performance of a Contract
- To fulfill our obligations under our Terms of Use (e.g., providing the functionalities of the App).
Legal Obligation
- Where processing is necessary to comply with the law (e.g., tax or accounting regulations).
Legitimate Interests
- Where processing is necessary for our legitimate interests, except where overridden by your fundamental rights and interests (e.g., improving our services and user experience).
4. How We Use Your Data
We use the collected data for the following purposes:
Service Provision
- To operate, maintain, and provide the features and functionalities of the App.
Account Management
- To create and manage user accounts, authenticate logins, and process transactions.
Communication
- To respond to your inquiries, send technical notices, updates, and administrative messages.
Voice Counselling Services
- To facilitate AI-based voice counselling via our HIPAA-compliant VAPI voice agent and to provide you with relevant support or guidance.
Personalization
- To tailor the App experience to your preferences (e.g., nicknames).
Analytics & Improvements
- To analyze usage patterns, identify trends, and enhance the App’s performance and user experience.
Marketing & Promotional Materials (where applicable)
- To send promotional offers or information about our services, subject to your consent where required.
5. Data Storage (Firebase) and Retention
Firebase Storage
- We use Firebase, a service provided by Google LLC, to store user account information, usage data, and certain App-related data. Firebase maintains industry-standard security controls and is GDPR-compliant. For more information on Firebase data processing practices, please review Google’s Privacy Policy.
Retention Period
- We will retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Terms and Conditions, unless a longer retention period is required or permitted by law. When data is no longer needed, we will securely delete or anonymize it.
6. Cookies and Similar Technologies
We may use cookies or similar tracking technologies to collect information about your use of the App and to provide certain features. You can manage your cookie preferences through your device’s settings or any cookie consent banner (if applicable).
7. Data Sharing and Disclosure
We do not sell or rent your personal data to third parties. However, we may share your data in the following circumstances:
Service Providers
- With third-party vendors, hosting providers (e.g., Firebase), and other partners who assist us in operating the App or providing services on our behalf. These parties process personal data on our instructions and in compliance with this Privacy Terms and Conditions and applicable data protection laws.
Legal Requirements
- Where we are legally required to disclose your data (e.g., to comply with a court order or regulatory requirement).
Business Transfers
- In connection with a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the acquiring entity.
8. International Data Transfers
Where personal data is transferred outside the European Economic Area (EEA), we will ensure that appropriate safeguards (e.g., Standard Contractual Clauses, Adequacy Decisions) are in place in accordance with the GDPR to protect your personal data. In the event that any data is transferred to the United States for processing in connection with our HIPAA-compliant VAPI or Firebase services, we will ensure compliance with both GDPR and relevant U.S. data protection requirements, including HIPAA for protected health information (PHI).
9. Security Measures & HIPAA Compliance
Technical and Organizational Measures
- We implement reasonable technical and organizational measures to safeguard your personal data against unauthorized or unlawful processing and accidental loss, destruction, or damage.
Firebase Security
- Firebase is ISO 27001 certified and provides encryption in transit and at rest for stored data. We maintain appropriate access controls and configurations to ensure data integrity and confidentiality.
Limitations
- While we strive to protect your personal data, no method of electronic transmission or storage is 100% secure. If you suspect any misuse, loss, or unauthorized access, please contact us immediately.
10. Your Rights as a Data Subject
Under the GDPR and Dutch data protection laws, you have certain rights regarding your personal data, including:
- Right of Access: Obtain a copy of your personal data.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure (“Right to be Forgotten”): Request deletion of your data under certain circumstances.
- Right to Restrict Processing: Request limiting the processing of your data in specific cases.
- Right to Object: Object to certain processing activities, such as direct marketing.
- Right to Withdraw Consent: Where processing is based on consent, withdraw consent at any time without affecting the lawfulness of prior processing.
If you wish to exercise any of these rights, please contact us at: Hardik.Gala@generationlotus.com
11. Complaints
If you believe that our processing of your personal data violates applicable data protection laws, you may lodge a complaint with us, so we can address your concerns directly. You can contact Hardik.Gala@generationlotus.com
12. Changes to This Privacy Terms and Conditions
We may update this document from time to time to address changes in legal, technical, or business developments. When we do, we will revise the “Last updated” date at the top and notify you in an appropriate manner (e.g., via an in-app notification). Your continued use of the App after any such update indicates your acceptance of the revised terms.
13. Acceptance of These Terms
By creating an account or otherwise using the App, you acknowledge that you have read, understood, and agree to this Privacy Terms and Conditions. If you do not agree, please refrain from using the App.
Contact Us
If you have any questions or concerns about this Privacy Terms and Conditions, please contact:
Generation Lotus
Hardik.Gala@generationlotus.com