Last Updated: March 13, 2025.

In accordance with Regulation (EU) 2016/679 of the European Parliament and the Council, dated April 27, 2016, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data (General Data Protection Regulation – GDPR), TMPI MERAKI LTD informs users of the HEADSHAPE application (hereinafter, “the Application”) about the processing of the personal data they voluntarily provide during the registration, access, and use of the service.

The User refers to the healthcare professional who will use the application in compliance with its Terms and Conditions of Use.

TMPI MERAKI LTD, a company based in Cyprus, with Tax Identification Number (TIN) CY60072559D, registered at Efesou 9, Paralimni 5280, Famagusta, Cyprus (hereinafter, “the Data Controller”), is the entity responsible for processing the data provided by the clients of the Application (hereinafter, “the User(s)”).

To proceed with the registration, access, and use of the Application, the User must voluntarily provide personal data (primarily identification and contact details), which will be stored in automated databases owned by TMPI MERAKI LTD.

The collection, storage, modification, structuring, and, where applicable, deletion of the data provided by Users constitute processing operations carried out by the Data Controller, with the following purposes: Ensuring the proper functioning of the Application, Maintaining the service and/or commercial relationship with the User, Managing, administering, informing about, and improving the service

The User’s personal data—particularly their email address—may also be used to send newsletters and commercial communications about promotions and/or advertisements related to the Application, provided that the User has given explicit prior consent to receive such communications electronically.

Headshape collects and processes user data exclusively to provide the app’s functionalities, and data storage ceases when the User deletes their account.

The processing of the User’s data is carried out based on the following legal grounds:

• ▪ The request for information and/or the contractual engagement for the Application’s services, whose Terms and Conditions will always be available to the User for prior express acceptance.
• ▪ The free, specific, informed, and unequivocal consent of the User, provided through explicit acceptance of this Privacy Policy via a clear affirmative action, such as checking a consent box.

If the User fails to provide their data to TMPI MERAKI LTD, or does so incorrectly or incompletely, the use of the Application will not be possible.

The personal data provided by the User will be stored in the systems and databases of the Data Controller for as long as the User continues using the Application and has not requested deletion of their account.

If the User decides to delete their account, all data, including treatment-related information, will be permanently erased from our system.

User data will not be shared with any third party outside of TMPI MERAKI LTD, except in cases of legal obligation or with the User’s explicit prior consent.

However, TMPI MERAKI LTD may grant access to or transmit the personal data provided by the User to third-party service providers with whom data processing agreements have been established. These third parties will only access the data to perform a service on behalf of the Data Controller.

The Data Controller implements necessary measures to ensure the security, integrity, and confidentiality of the data in accordance with Regulation (EU) 2016/679.

While the Data Controller performs regular backups of the content stored on its servers, it is not responsible for accidental loss or deletion of data by Users. Likewise, full recovery of deleted data cannot be guaranteed, as such data may have been permanently removed or modified since the last backup.

The services provided through the Application, except for backup services, do not include data recovery from stored backups when data loss is attributable to the User. In such cases, a fee will be determined based on the complexity and volume of the data recovery, subject to the User’s prior acceptance. Data recovery is only included in the service price if the data loss is caused by the Data Controller.

TMPI MERAKI LTD informs Users that they are entitled to exercise the following rights:

• ▪ Right to information – Users must be informed, in a clear and precise manner, about the collection of their personal data, their rights, and the identity of the Data Controller.
• ▪ Right of access – Users have the right to obtain information about their personal data held by the Data Controller, free of charge.
• ▪ Right to rectification – Users may correct, modify, or update any inaccurate or incomplete personal data.
• ▪ Right to erasure (“Right to be Forgotten”) – Users may request the deletion of inadequate or excessive personal data under the grounds established in Article 17 of Regulation (EU) 2016/679.
• ▪ Right to restriction of processing – Users may request that data processing be limited, which must be clearly noted in the Data Controller’s systems.
• ▪ Right to data portability – Users have the right to receive their personal data in a structured, commonly used, and machine-readable format and to transfer it to another data controller without hindrance.
• ▪ Right to object – Users may object to the processing of their personal data or request that it be stopped.

Additionally, Users have the right to withdraw their previously given consent and to file complaints with the Office of the Commissioner for Personal Data Protection of Cyprus, responsible for implementing Regulation (EU) 2016/679 (GDPR).

TMPI MERAKI LTD will not send unsolicited advertising or promotional communications via email or any other electronic means unless explicitly authorized by the recipient.

For Users who have an existing contractual, legal, or service-based relationship with TMPI MERAKI LTD, the Data Controller is authorized to send commercial communications related to products or services similar to those originally contracted by the User.

If the User wishes to unsubscribe from these communications, they may do so by sending an email to: info@tmpi-pimt.com.