Privacy Policy for Independent Healy World Members
We are committed to protecting your personal information and your right to privacy. This Privacy Policy provides you with information about what personal data is processed by Healy International B.V (hereinafter “Healy World”, “we”, “us”) in connection with your as an Independent Healy World Member (hereinafter “Independent Member”, “IHWM”, “you”). Healy World complies with the European Union’s General Data Protection Regulation (GDPR) considering its underlying principles in how we think about member trust and data privacy as a core pillar of our business.
Healy International B.V. and Healy World GmbH have entered into a joint controller arrangement defining their respective responsibilities. You can request further details by contacting our Data Protection Officer.
For further details, please also review the Privacy Policy of our website (https://eu.healy.shop/privacy/) and the Privacy Policy for Healy World applications.
1. Data Controller
The controller of the processing of your personal data is:
Healy International B.V.
Paterswoldseweg 806
9728 Groningen
Netherlands
The Data Protection Officer of the data controller can be reached at:
Healy World GmbH
Isaac-Fulda-Allee 1
55124 Mainz
Germany
If you have any questions or comments about this Privacy Policy, or if you wish to exercise your rights, please contact the data protection officer at the following e-mail address: dpo@healy.world.
Please note you should only contact us at this email address for privacy related concerns. Other requests will not be answered. If you wish to contact the Service Center, please log in to your back-office and create a ticket.
2. Purposes and legal basis of data processing
In the following, we inform you about the details of the processing of personal data in the context of your membership as an Independent Healy World. If a contract is concluded between Healy World and you, you will only be required to provide the personal data that is necessary for the commencement and performance of the contract or that we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or execute the order, or we will no longer be able to execute an existing contract and may have to terminate it.
2.1. Collection of personal data for the conclusion of your Healy World membership
In order to conclude a membership as an Independent Healy World Member, we collect the following personal data from you:
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- Name
- Gender
- Your address
- Date of birth
- Country
- Language
- Proof of identity
- Company name
- Company phone number
- E-mail address
- Certifications
- Tax number, social security number, registration number (if required)
- Bank details
- IPayout account data
This data collection serves the purposes of establishing, implementing and terminating our business relationship as well on ongoing administration. The legal basis for this data processing is Art. 6 para. 1 letter b of the General Data Protection Regulation (“GDPR”).
Specifically, your personal data will be processed for the following purposes:
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- Administration of their Healy World membership;
- Processing of deliveries / orders;
- Sending advertising and information material;
- Conducting trainings, seminars and internal events;
- Issuing certifications;
- Processing payments and remunerations;
The legal basis for this processing is Art. 6 para. 1 (b) GDPR (performance of a contract) and Art. 6 para. 1 (f) GDPR (legitimate interests).
Data will be stored until the contract has been fully executed. If applicable, commercial and tax retention periods may extend the storage duration to up to 10 years. The legal basis for this processing is Art. 6 para. 1 (c) GDPR (compliance with a legal obligation).
Important notice: Our services are aimed exclusively at persons who have reached the age of 18. Healy World does not process personal data of children or minors.
2.2. Use of personal data by our sales and customer support teams
If you make use of individual consulting services provides by our sales team, your personal data, such as your name, contact information and relevant information about your request, will be processed in order to make the consultation targeted and efficient. This data is processed based on Art. 6 para. 1 letter b of the GDPR (performance of a contract or pre-contractual measures).
If you contact our customer support, the information you provide, such as your contact details and the content of your request, will be used to process your request and provide an appropriate solution. Data processing by our customer support is carried out based on Art. 6 para. 1 letter b GDPR insofar as it is a matter of pre-contractual or contractual communication or based on Art. 6 para. 1 letter f GDPR, insofar as it is our legitimate interest to process your request.
2.3. Collection of Personal Data when using the Healy World website
We offer you the opportunity to log in via our website after concluding a membership as an Independent Healy World Member. When using the log-in option, the personal data transmitted as a result will be processed (e.g. surname and first name, address, telephone number, e-mail address, member name, bank data). Without the processing of this data, the use of the Independent Member area is not possible.
2.4. Use of data for advertising purposes, newsletter
Please note that emails regarding the functionality of the Independent Member area and your membership as an Independent Member do not constitute advertising and are therefore processed for the purpose of the ongoing administration of the business relationship on Art. 6 para. 1 lit. b GDPR. You can unsubscribe at any time by clicking the link included in each email.
Healy World will only process your personal data for the purpose of sending a promotional newsletter if you have given your prior consent. The only mandatory information for sending the promotional newsletter is the e-mail address. The provision of further, separately marked data is voluntary and is used for personal address. After confirmation, Healy World stores your e-mail address for the purpose of sending the newsletter.
This data processing is based on the consent you have given; the legal basis is Art. 6 para. 1 lit. a GDPR. You can revoke your consent to receive the newsletter and unsubscribe from newsletter at any time. You can declare your revocation by clicking on the link contained in every newsletter e-mail.
2.5. Disclosure of data in the genealogy and display in the webshop
In order to support you as an Independent Healy World Member (IHWM) in expanding your business, certain personal data is shared with other IHWM as part of the genealogy. The following information can be displayed to your direct sponsors, Director or Vice President (VP) and members of your downline:
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- Your name
- Your contact information
- Sales and performance statistics (only if consent is granted)
This data processing enables a transparent structure within the IHWM network and facilitates business cooperation and mutual mentoring.
In addition, your first and last name and company name will be displayed in the web shop when a potential buyer enters your referral code. This function is used to assign the purchase to your IHWM account and to calculate any commissions.
The processing is carried out on the basis of Art. 6 (1) (b) GDPR (contract performance) to fulfill your IHWM membership and on the basis of Art. 6 (1) (f) GDPR (legitimate interest) in promoting and supporting the business activities of our IHWM members. You have the right to withdraw your consent in accordance with Article 21 of the GDPR (right to object), by sending an email to the following address: dpo@healy.world.
2.6. Training and quality assurance
Healy International B.V. processes your personal data for training and quality assurance purposes. This data comes from telephone calls (live and/or recorded), e-mails or other written communications. The legal basis for this processing is our legitimate interest in accordance with Art. 6 para. 1 point f GDPR, as it enables us to continuously improve our processes and your experience.
2.7. Contact form and email contact
If you use our contact form or email, we process the transmitted data to process your request. This usually includes the following data:
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- Title
- First and last name
- Postal address
- Email address
- Telephone number
- Optional: order number, information about your Healy World product
The processing of personal data in the context of customer service is based on our legitimate interest in accordance with Art. 6 para. 1 (f) GDPR to provide our members with the necessary support and to maintain our service quality, as well as on the fulfillment of contractual obligations in accordance with Art. 6 para. 1 (b) GDPR in connection with your membership. All personal data processed through the Zoho platform is treated securely and confidentially in accordance with the applicable data protection laws.
2.8. Healy World Academy
The Healy World Academy at https://academy.healy.world offers training and webinars. Registration is done via the same access data as the BackOffice using Single Sign-On (SSO). The legal basis for this is Art. 6 para. 1 point (b) GDPR (performance of a contract).
2.9. Reporting systems for legal violations
As part of our compliance measures, we offer a whistleblower system that you can use to report violations. This also applies to human rights and environmental risks along our supply chains. Whistleblower reports can be anonymous and are handled confidentially. Where legally required, we may share reports with authorities or legal advisors. This data is processed in accordance with Art. 6 para. 1 point c GDPR in conjunction with Section 10 HinSchG (German Whistleblower Protection Act) and Section 8 LkSG (German law on corporate due diligence to prevent human rights violations in supply chains).
3. Recipients of your personal data
3.1. Operation of services in partnership with Healy World
Healy World only passes on your personal data to the extent necessary to carry out our business relationship or to protect the legitimate interests of Healy World. Healy World uses external service providers, such as hosting providers, payment service providers and shipping services providers, to carry out the contract and provide the services. To the extent that these service providers act as processors for Healy World, separate data processing agreements have been established to ensure the protection of customers’ personal data.
To manage the independent members’ area, we utilize the services of the following companies, which act as our processors and supply the required software and infrastructure:
- Jia, Inc.
- Address: 203 Park Plaza Dr, Suite 250, Vancouver, WA 98684, USA
- Known as: Jenkon
- Website: https://www.jenkon.com
- Gleen AI
- Address: 2150 N 1st St, Suite 420, San Jose, CA 95131, USA
- Website: https://gleen.ai/
- Momentum Factor
- Address: 720 Brazos Street, Suite 900, Austin, TX 78701, USA
- Website: https://momofactor.com/
- Zoho Corporation
- Address: Estancia IT Park, Plot no. 140, 151, GST Road, Vallancheri, Chengalpattu District – 603 202, India
- Website: https://www.zoho.com
These companies assist us in processing customer service requests efficiently and effectively, as well as ensuring compliance with relevant regulations.
3.2. Collection and use of personal data
To improve our communication with IHWMs, we use WhatsApp Business, a messaging service from WhatsApp Inc, as well as Telegram, a messaging service from Telegram FZ-LLC, which allows us to communicate directly with our members.
Using WhatsApp Business and Telegram to exchange messages involves processing personal data such as your phone number, e-mail address, username and avatar. Use of this service is optional and assumes that you agree to the WhatsApp Privacy Policy, which can be found on the WhatsApp Privacy Policy page, and/or the Telegram Privacy Policy, also available on the Telegram Privacy Policy page. Please note that WhatsApp and Telegram have access to communications metadata and may store this data outside the European Union.
We recommend that you do not share sensitive personal information via these channels. This data processing is carried out on the basis of Article 6 paragraph 1 letter f of the GDPR, our legitimate interest in being able to tell you about our products and services, or Article 6 paragraph 1 letter b of the GDPR, insofar as it concerns a pre-contractual communication. Use of these services is entirely voluntary. By using WhatsApp or Telegram for communication, you acknowledge that these services process data outside the EU and may not be subject to GDPR-level protection. You can withdraw consent at any time within the application.
We use the payment service provider iPayout to process commission payments. As an IHWM member, you enter into a separate contract with iPayout, which in this context acts as an independent data controller in accordance with the GDPR. Healy World only transmits the data necessary for payment processing to iPayout. This includes: your full name, your account details (iPayout account) and your tax and identification information (if required). iPayout is independently responsible for the processing of this data. Please note that the processing of your data by iPayout is subject to iPayout’s privacy policy, which you can view at the following link: https://www.i-payout.com/privacy-policy.
In addition, Healy World processes certain iPayout-related data for identity verification and fraud prevention purposes. This includes verifying the identity and address data provided by iPayout to ensure that all transactions are carried out properly. This processing by Healy World is carried out on the basis of our legitimate interest in accordance with Art. 6 para. 1 (f) GDPR to prevent abusive and fraudulent activities.
Transfer of data to third countries
Data may be transferred to third countries (i.e., countries outside the European Union or European Economic Area) if necessary to provide services to you, required by law, or authorized by your consent. Additionally, we may transfer your personal data to processors located in third countries.
Please be aware that not all third countries provide a level of data protection deemed adequate by the European Commission. For such transfers, we implement appropriate safeguards to ensure an adequate level of data protection. This includes the use of standard contractual clauses in accordance with Articles 46 and 28 GDPR or obtaining the explicit consent of our users. Additionally, where required, we conduct Transfer Impact Assessments (TIAs) and apply enhanced security measures, such as encryption or pseudonymization, to further protect your data.
You can request a copy of the specific applicable or agreed-upon regulations ensuring an adequate level of data protection. To do so, please refer to the contact information provided in section 1.
4. Storage period
We do not store your personal data any longer than necessary to achieve the respective purposes of the data processing set out in this Privacy Policy. Personal data required for tax and commercial law purposes are stored in accordance with the statutory retention periods (up to 10 years). Please note that marketing data are retained until the consent is withdrawn, and customer support inquiries are retained for 6 years after resolution.
After the respective retention period has expired, these data are deleted, unless they are still needed to fulfill legal obligations or enforce legal claims.
5. Rights of the data subjects
If you are a resident of the European Union or the European Economic Area (EU/EEA), you have certain data protection rights under certain circumstances, for example:
- Right of access: The right to obtain information about your personal data processed by us and the right to obtain a copy of such data;
- Right to rectification: If your personal data is inaccurate or incomplete, you have the right to rectification;
- Right to restriction of processing: This right includes the restriction of the use or the manner of use;
- Right to erasure: You may request the erasure of your personal data, unless there is a retention obligation.
- Right to data portability: This right includes that we transfer your personal data, if technically possible, in a structured, common and machine-readable format for your own purposes;
- Right to withdraw your consent: If you have given us your consent to process, you have the right to withdraw your consent at any time;
- Right to lodge a complaint: You have the right to file a complaint with a data protection supervisory authority, in particular in the Member State of your habitual residence, workplace, or place of the alleged infringement, in accordance with Art. 77 GDPR.
You also have the right to file a complaint with the relevant data protection authority, in particular with the “Federal Commissioner for Data Protection and Freedom of Information” in Germany or the Dutch data protection authority.
6. Security measures
Healy World protects your data from unauthorized access, loss and destruction using technical and organizational measures. Our website is secured by SSL encryption to protect data during transmission. These security measures are continuously adapted to the state of the art.
We reserve the right to update this Privacy Policy at our sole discretion. Any changes will be posted in our back office, along with an updated ‘Status’ date. To the extent permitted by applicable law, your continued use of our services following the posting of changes will constitute your acceptance of those changes.
Status of this Privacy Policy: 25.02.2025