Published on April 2022
OVERVIEW
Your privacy is important to us. This Privacy Policy (“Policy”, “Privacy Policy”) applies to services (“Services”) provided by Digicast Media LTD (“we”, “us”, or “Company”) on our website www.healthy-flows.com (“Site”), and explains what information we collect from users of our Services (a “user”, “you”, or “your”), including information that may be used to personally identify you (“Personal Information”) and how we use it.
We encourage you to read the details below. This Policy applies to any user or visitor of our Site. We will be the data controller of your Personal Information provided to, or collected by or for, or processed in connection with, our Services.
Any Personal Information we collect from you is processed in line with applicable data protection laws including the EU General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA).
This Privacy Policy applies when you interact with us by doing any of the following:
- Use of our Services as an authorized user;
- Visit our Site that link to this Privacy Policy;
- Receive any communication from us including newsletters, emails, calls, or texts.
We reserve the right to change this Policy at any time. You should periodically check our Site, including this Policy, for updates. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of your Personal Information is subject to the updated Policy.
SECTION 1 – CHILDREN UNDER 18
The Services are not directed to individuals who are under age of eighteen (18) and we do not solicit nor knowingly collect Personal Information from children under the age of eighteen (18). If you believe that we have unknowingly collected any Personal Information from someone under the age of eighteen (18), please contact us immediately at [email protected] and the information will be deleted.
SECTION 2 – INFORMATION WE COLLECT
We collect information that you give us when you create an account, contact us, or otherwise access or use our Services, any information you voluntarily submit to us, and information regarding how you use the Services. Specifically, the foregoing includes:
- Your internet protocol address (i.e., IP address);
- Your email address, postal address, telephone number, credit card information and your responses to surveys that we may ask you to complete for research purposes or to help direct Company activities;
- Details of any financial transactions you participate in on the Services, including the amount, currency, and method of payment;
- Browser and device information and information collected through technologies such as cookies.
We may keep records of any questions, complaints, or compliments made by you and the response, if any. Whenever you contact us, we shall collect any information which you choose to provide. We shall store and use this information only to respond to your inquiries.
Prior to start registering your Personal Information on our Site, promotional campaigns or a newsletter, we always ask if you give a specific and informed consent thereto by means of a clear affirmative opt-in.
SECTION 3 – PURPOSE AND LEGAL BASIS
We will only collect and process Personal Information about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested)) and “legitimate interests”.
We collect and use Personal Information about you with your consent to provide, maintain, and develop our Services and understand how to improve them.
These purposes include:
- To deliver you product or service;
- Building a safe and secure environment (to verify or authenticate your identity; and to investigate and prevent security incidents such as breaches, attacks and hacks);
- Providing, developing, and improving our Services (deliver, maintain, debug and improve our products and services; enable you to access Services and set up accounts);
- To provide you with technical and customer support;
- To respond to claims of any violation of our rights or those of any third parties.
We may use Personal Information for other purposes for which we have a legitimate interest or as required or authorized by law.
Where we process your Personal Information to provide a Service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in our legitimate interests to provide Services and to maintain our relationship with you and to protect our business for example against fraud. Consent will be required to initiate services with you. New consent will be required If any changes are made to the type of Personal Information collected. Within our contract, if you fail to provide consent, some Services may not be available to you.
We use IP addresses to collect statistical information about the areas of the Site that users are visiting, and general traffic data and to identify a particular user in relation to items being viewed. This information allows us to determine what is most beneficial for users and facilitates us in continually improving the overall Site for our users.
We may process information about how you use the Services and how you interact with the Site through third-party analytics tools. We process this data under our legitimate interest in analysing the performance of the Services and updating our Services. We aim to minimise the amount of Personal Information included in such information and to anonymise the data wherever possible. Session information is anonymised and used only for research purposes in order to improve and adapt our Services. Third-Party tools cannot connect the data about the session to a specific user.
We may use or disclose your Personal Information in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible and practical to do so, we will tell you in advance of such disclosure.
SECTION 4 – YOUR RIGHTS
We will process all Personal Information in accordance with the principles of GDPR and especially having in mind users’ rights, in particular the following data protection rights:
- to access your personal information that we hold;
- to request the rectification of your personal information that we hold;
- to request the erasure of your personal information that we hold;
- to request to restrict processing of your personal information;
- to object to processing of your personal information by us;
- to request to transfer your personal information that we hold (e.g. data portability);
- to file a complaint to a supervisory authority in your jurisdiction;
- to withdraw any consent related to your personal information given by you.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Company aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information. If you wish to be informed what personal information, we hold about you and if you want it to be removed from our systems, please contact us.
The California Consumer Privacy Act (CCPA) provides California residents with five core rights to data privacy and autonomy, and an additional private right of action of compensation in the event of data breaches:
- Right to Notice: We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used.
- Right to Deletion: California residents have the right to request, at no charge, deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. We will respond to verifiable requests received from California residents as required by law.
- Right to Disclosure: California residents have the right to request and, subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.
- Right to opt out / Do-not-sell (opt-out/opt-in): California residents have the right to opt-out of our sale of their personal information. Further businesses may not knowingly sell personal information about minors under 16 years old without prior express consent.
- Right to equal services and prices: The CCPA prohibits businesses from discriminating against consumers by denying goods or services, charging a different price or rate for goods or services, providing a different level or quality of goods or services, or suggesting that they will do any of these things based upon a consumer’s exercise of any CCPA rights.
You can exercise these rights by sending an email to the contact address on the Site. We may request personal identification documents from you. All documents provided will be destroyed after we have processed your request. We will process your requests to us within 30 days.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during the period for which we hold it.
SECTION 5 – SECURITY
We believe we use reasonable administrative, logical, physical, and managerial measures to safeguard your Personal Information against loss, theft, and unauthorized access, use, and modification. We take all appropriate technical and organizational measures to ensure that the processing of Personal Information takes place in accordance with the applicable legislation. This includes ensuring our staff, partners and any third parties who perform work on our behalf comply with security standards as part of their contractual obligations.
SECTION 6 – RETAINING YOUR INFORMATION
We will retain your personal information for as long as is necessary for the purposes described above. Typically, we will retain your Personal Information to fulfil our business purposes, to comply with legal and regulatory requirements, or for any legal claims. We may keep Personal Information for longer where this is necessary for statistical and historical research purposes. However, we will ensure all personally identifiable information is removed and at the appropriate time.
SECTION 7 – DATA TRANSFER
Your Personal Information may be transferred outside of the European Union from time to time to members or businesses within the Company group or to trusted service providers and third parties.
In all cases, the transfer will be on the basis of a European Commission adequacy decision or we will implement adequate safeguards to protect your personal information, such as the European Commission approved Standard Contractual Clauses. To obtain further information on the data transfer mechanism on which we rely, please contact us as set out below.
SECTION 8 – COOKIES
Our Site uses Cookies. A cookie is a small piece of data sent from a Site and stored in a user’s web browser while the user is browsing that Site. Every time the user loads the Site, the browser sends cookie information back to the server to notify the Site that it recognizes the user.
SECTION 9 – HOW WE RESPOND TO DO NOT TRACK SIGNALS
Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a user’s browser because we do not track our users to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.
SECTION 10 – THIRD PARTY DIRECT MARKETING
We currently do not share Personal Information with third parties for their direct marketing purposes without your consent.
SECTION 11 – CHANGES TO THIS POLICY
We may update this Policy from time to time. We will notify you of the changes where required by law to do so.
SECTION 12 – CONTACT US
If you have any questions or concerns regarding the Privacy Policy related to our Site, please feel free to contact us at the following email, telephone number or mailing address.
