Additional consent: research and product development

1. What this is

This is an additional, optional consent on top of the arrangements in our privacy notice. With this consent you give Pacely permission to also use your data for research and product development, work aimed at making Pacely better for you and for future users.

This consent is voluntary. If you do not give it, Pacely works exactly the same for you, no features are removed, no extra costs, no different service level. In that case we retain no extra rights and use your data solely as described in the ordinary privacy notice.

2. Why we ask this

Pacely is a product in development. To recognise patterns, test hypotheses and design new features, it helps enormously if developers and researchers within Pacely can look at real data. Anonymous summaries do not capture everything, sometimes you have to zoom in on a few concrete examples to understand what is happening.

We therefore ask separately for your consent, so that you can decide for yourself whether your data may be used for this.

3. What you consent to

If you give this additional consent, you agree to the following:

• Authorised Pacely staff may view your data for research and product development. These are the same people who also have operational access (see privacy notice §6); access is strictly limited to a small number of authorised personnel.
• The purpose is always: making Pacely better. Concrete work within this purpose may be pattern recognition, hypothesis testing, feature research, designing new screens, building prototypes, writing or evaluating algorithms.
• Viewing happens within our systems. Your data does not leave Pacely's secure infrastructure in the European Union for this purpose. Locations of storage and processing are in article 8 of the privacy notice.
• Viewing is logged in the same overview described in privacy notice §6. In the "Who has seen your data" overview you recognise R&D access by its own label.

4. What we do not do, not even with this consent

• We do not share your data with third parties, not even for research. Your data does not leave Pacely's systems.
• We do not sell your data, in any form whatsoever.
• We do not use your data for advertising or profiling for commercial purposes outside Pacely.
• We do not use your data for research that is unrelated to Pacely, no academic publications, no collaborations with external researchers, no delivery to third parties, no training of AI models for parties outside Pacely. If any of that should ever come up, we ask you again explicitly for consent.
• We do not publish identifiable data. Results of R&D work that we share externally (for example in a blog post or presentation) are always anonymised or aggregated, so they cannot be traced back to you.
• We do not link your data to other sources (such as public datasets or third-party data) without additional consent.

5. How we limit this

This broader access goes together with the following built-in limits:

• The same confidentiality obligation applies to R&D access as to operational access. Pacely staff with this access have recorded it in writing in an internal declaration.
• Access is logged. R&D work on your data always runs through the auditable paths, not through the direct console access described in privacy notice §6 as a platform exception; that line is solely for necessary maintenance. Every time a staff member views your data for R&D, we record who it was, when and for what purpose. You can view this yourself in the app under "Who has seen your data".
• Data volume stays limited. We do not send copies of your data to external analysis environments or laptops; work happens in our secure infrastructure.
• Outputs of R&D work that involve personal data leave Pacely's systems only in aggregated or anonymised form.

6. Legal basis

This additional consent is your explicit consent within the meaning of article 9(2)(a) GDPR for the processing of special-category data (health data) for research and product development. The consent is fully voluntary and revocable.

7. Withdrawal

You can withdraw this consent at any time:

• In the app, via the same button with which you gave it (in your profile settings).
• By email, via mail@pacely.nl.

From the moment you withdraw, we no longer use your data for research and product development. Processing that took place before the withdrawal remains lawful, the withdrawal works forward, not backward.

Withdrawal has no effect on your use of Pacely. The ordinary privacy notice remains fully applicable.

8. Retention period

The fact that you gave or withdrew this consent we keep linked to your account, with date and version number, so we can demonstrate what you chose and when. We keep this administrative data for as long as the retention period for account data in privacy notice §9 prescribes.

The ordinary retention periods apply to the data itself that you put into Pacely; this consent does not change how data is kept.

9. Changes to these terms

If we change these additional terms substantively, the old version of your consent no longer applies to the new scope. We then ask you again explicitly, so you know what you are agreeing to.

10. Questions or complaints

Questions or remarks? Email mail@pacely.nl. If you feel that we are not handling your data carefully, you can in addition always lodge a complaint with the Dutch Data Protection Authority.