PRIVACY POLICY FOR HEALY APPs

Welcome to Healy World! At Healy World GmbH (“Healy,” “we,” or “us”), we recognize the importance of treating your personal information with care and appreciate the trust you place in us. This Privacy Policy aims to provide you with information regarding the types of information we may collect, how we may use such information, who we may share it with, your choices concerning the collection, use, and sharing of your information, your rights to access and correct your information, as well as the security measures we employ to safeguard your information when you use the Healy Applications (Healy App; Healy 2 App, HealAdvisor Analyse App, HealAdvisor Analyse 2 App; HealAdvisor App; Healy Watch App; Healy Watch 2 App, collectively referred to as “App”). By accessing and using the Mobile Apps and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy.

We prioritize the utmost protection of privacy and are fully dedicated to upholding the highest standards in accordance with relevant privacy laws. As part of this commitment, we strictly comply with the General Data Protection Regulation (GDPR) to ensure the proper safeguarding of personal data. For additional local legislations, please refer to the end of our Privacy Policy.

1. DATACONTROLLER and DPO

The controller of the processing of your personal data is Healy World GmbH, Isaac-Fulda-Allee 1, 55124 Mainz, Germany, contact.emea@healy.world

If you would like to exercise any of the rights described in this Privacy Policy or if you have any inquiries regarding the processing of your personal data, please feel free to reach out to the Data Privacy Officer of the Controller at the postal address below or at dpo@healy.world.

2. PURPOSES AND LEGAL BASES OF DATA PROCESSING

2.1. Collection of personal information: You can access and use the Apps without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered in the Mobile Application, you may be asked to provide certain Personal Information (for example, your name and e-mail address).

We receive and store any information you knowingly provide to us when you create an account in the mobile App. Also, to use the Healy App, you must connect to your Healy customer account. For this purpose, the following personal data might be processed, if applicable:

• Basic personal information (such as name, gender, date of birth, etc.)
• Contact information (such as email address, password, etc.)
• Sensitive personal information (such as heart rate, etc.)
• Certain features on the mobile device (such as camera, etc.)

Your login with the user accounts is used to share information from the user account, such as purchased modules and customized program plans with the apps.

2.2. Connection For the initial connection of the Healy Apps with the Healy device, the serial number of the Healy device is scanned via the Healy App or entered manually in the Healy App. Provided that a connection is established between the Healy device and an App, only the following data is transmitted from the Healy device to the corresponding App: the temporal progress of the program currently activated on the Healy device, the set intensity, mode and type of the program, the amount of current delivered by the Healy device and the frequency delivered by the Healy device. When the Healy App is used on Android devices, location data is accessed to establish the Bluetooth Low Energy connection used by the Healy device. This location data is processed exclusively to establish the Bluetooth Low Energy connection and is not stored on the Healy servers or otherwise processed by Healy.

In addition, your authorization to use the camera of your mobile device is obtained by the Healy App to allow you to scan the QR code on the back of the Healy device using the camera to facilitate the connection process between the Healy device and the Healy App. Scanning the QR code saves you the extra effort of having to enter the serial number of the Healy device when connecting to the Healy app.

Accessing the image folder of your mobile device can be done, for example, to assign a profile picture from the image folder to a client created in the HealAdvisor Analyse App or to perform an analysis of an object that has already been photographed. For the previously mentioned purposes, you can also take a picture directly, which is why access to your mobile device’s camera may also be required. Access to the contacts stored in your mobile device can be done if you want to use contacts from your mobile device to create a client in the HealAdvisor Analyse App.

The legal basis for the processing of personal data of Healy Customers is the performance of the contract concluded by the Customers with Healy for the use of the Healy device as well as for the respective Apps.

If the apps process special categories of personal data as defined in Article 9 of the GDPR, such as heart rate, number of steps, calories burned, Heart Rate Variability (HRV), ECG, blood pressure, stress level, cardiovascular status, Healy frequency programs performed (including the amount of current delivered), intolerances, diet type, existing diseases, symptoms, deficiencies, allergies, etc., the legal basis for this processing is your consent. You can withdraw your consent at any time with effect for the future on your app.

2.3. Healy App and Healy 2 App (“HA”). When using the Healy App, you will be prompted to scan the serial number of your Healy device to establish a connection between the Healy device and your mobile device. The application data, including frequency data generated by your Healy device during use, is then transferred to the Healy App and stored in the cloud. Additionally, log files related to software operations are transferred to Healy’s servers for error analysis. These data processing activities are carried out to fulfill the usage contract via the app. In addition, log files are stored that relate to the number and type of analysis performed on clients.

2.4. HealAdvisor App and HealAdvisor App 2 (”HAA”). When using the HealAdvisor App and the HealAdvisor App 2, you will be asked to provide data related to intolerances, diet type (e.g., vegan), existing diseases, symptoms, and deficiency symptoms. The processing of this data is based on your consent. In addition, basic personal information (such as name, gender, date of birth, etc.) is used to provide customized program recommendations.

2.5. HealAdvisor Analyse App and HealAdvisor Analyse 2 App (“HAAA”). The HealAdvisor Analyse App and the HealAdvisor Analyse App 2 search for your Healy device to establish a connection. The app allows you to create client profiles as part of client management, with their consent, and transfer them to the cloud. You can also use the app and the Healy device to perform analysis and harmonization. You can for example also perform an analysis of your Heart Rate Variability (HRV) analysis parameters. We process this data to fulfill the user contract through our apps.

2.6. Healy Watch App and Healy Watch 2 App. In the Healy Watch App, measurements are taken using the Healy Watch device, and the following parameters are made visible: ECG, step count, distance traveled, calories burned, location, heart rate, and blood pressure. The processing of this data is based on your consent. Furthermore, Heart Rate Variability (HRV) and additional parameters such as order are calculated in the cloud based on the measured ECG and PPG data.

2.7. Data collected automatically: When you use the Mobile Applications, our servers automatically record information that your mobile device sends. This data may include information such as your device’s IP address and location, device name and version, operating system type and version, language preferences, information you search for in the Mobile Application, access times and dates, and other statistics. We may also collect mobile device location information if the user has enabled location features. For diagnostic purposes and troubleshooting, Healy also processes location information if the user is having problems with the app’s location features; information that tells us which app store you downloaded our app(s) from; and evaluations of the health data collected.

Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage of the Apps. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.

2.8. Single Sign-On (SSO) Services: We offer a Single Sign-On authentication method to provide a secure and streamlined login experience for our users. With SSO, you can authenticate yourself once and gain access to multiple services and applications without the need for separate account creation. During the registration process, your data is securely transferred from our website to our system through an encrypted interface. Please note that you are solely responsible for maintaining the security and confidentiality of your login information and must not disclose it to any third parties. The availability and functionality of the SSO Services may be modified or discontinued at any time without prior notice.

2.9. Export of Data as PDF: Our applications provide the functionality to export analysis lists as PDF files, allowing users to conveniently store, share, or print the information contained within the lists. In particular, we collect basic contact information such as name and email address, progress of the modules. We kindly request users to comply with the principles and requirements of the General Data Protection Regulation (GDPR) while exporting the data. The exported PDFs may contain personal information, and it is your responsibility to handle and process this data in accordance with applicable data protection laws. We encourage you to be mindful of the privacy rights of individuals whose data may be included in the exported files.

3. DATA TRANSMISSION

Healy will disclose your personal data only to the extent necessary to perform the contract or to protect Healy’s legitimate interests. Healy uses external service providers, such as hosting providers, payment service providers and shipping service providers for the performance of the contract and the provision of the services. Where such service providers act as processors for Healy, separate processing agreements have been concluded to ensure the protection of customers’ personal data.

With the HealAdvisor app, the program pool and the individually created weekly plans are stored in a cloud. Data transfer to the cloud takes place in the HealAdvisor Analyse App using encryption; the data is protected in the cloud with a “master key”, which is encrypted. This data processing is carried out for the purpose of fulfilling the contract. With the help of the cloud, the user can connect directly via the Healy App to therapists who compile individual programs for the user via the TimeWaver Frequency software that are specifically tailored to the user’s situation and make them available via the cloud for use with the Healy App. This data processing takes place on the basis of the consent given by the user.

In addition, we anonymously track your interaction with the apps offered by Healy. This tracking is limited to your interaction with the Healy apps. We use this information to further improve Healy’s services as a legitimate interest and the information collected is used for internal purposes only and is not sold or shared with third parties.

4. STORAGE PERIOD

We will retain and use your Personal Information for the period necessary to comply with our legal obligations, to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law. The data stored in an app on your end device is generally stored until the app is deleted.

Contractual data linked to a Healy user account is generally stored until the user account is logged off by you and the business relationship between Healy and you is fully settled, i.e. as long as the parties can mutually assert claims. This applies in particular to outstanding payments.

In addition, a user can also manually delete certain data such as program lists and weekly schedules at any time. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

5. Privacy of children

We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Apps. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Apps, please contact us to request that we delete that child’s Personal Information from our Services.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Apps without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.

6. data security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Mobile Application and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.

7. RIGHTS OF THE PERSONS CONCERNED UNDER GDPR

Individuals affected by data processing might have the following rights under certain conditions and exceptions as provided for by the GDPR.

Right to Information: Individuals have the right to be informed about the collection and use of their personal data, including the purposes of processing, the categories of data involved, and the identity of the data controller.

Right of Access: Individuals have the right to request access to their personal data held by the data controller. They can obtain information about the processing activities and a copy of their data.

Right to Rectification: Individuals have the right to request the correction or amendment of inaccurate or incomplete personal data.

Right to Erasure: Individuals have the right to request the deletion of their personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or processed.

Right to Restriction of Processing: Individuals have the right to request the limitation of processing of their personal data under certain conditions, such as when the accuracy of the data is contested or the processing is unlawful.

Right to Data Portability: Individuals have the right to receive their personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller.

Right to Object: Individuals have the right to object to the processing of their personal data in certain situations, including processing based on legitimate interests or for direct marketing purposes.

Rights in Relation to Automated Decision Making and Profiling: Individuals have the right not to be subject to a decision based solely on automated processing, including profiling, if it produces legal effects or significantly affects them.

Right to Withdraw Consent: If the processing of personal data is based on consent, individuals have the right to withdraw their consent at any time.

Right to Lodge a Complaint: Individuals have the right to lodge a complaint with a supervisory authority if they believe their rights under GDPR have been violated.

Please note that these rights may be subject to certain conditions and exceptions as provided for by the GDPR. You can find a list of all supervisory authorities for Germany here https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

8. Additional Information for California Consumers 

This Additional Information for California Consumers section applies solely to California residents.

Individual Rights. California residents have the right to request certain information about the disclosure of their personal information to third parties for direct marketing purposes.

You have the right to know and request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting and selling such information, and the categories of third parties to whom we disclose such information. You also have the right to know if we have sold or disclosed your personal information. You have the right to request the deletion of your personal information, subject to certain exceptions. You have the right to request correction of inaccurate personal information we maintain about you.

Right to opt-out. We do not “sell” personal information as defined by the CCPA. We do not “share” personal information as defined by the CCPA for cross-context behavioral advertising or other purposes.

Right to non-discrimination. We respect your right to exercise any of the rights granted to you under the CCPA without facing any discriminatory treatment. However, it’s important to note that we may provide different levels of service or apply different rates reasonably related to the value of your personal information.

Exercising Your Rights. To exercise your rights under the CCPA, please contact us using the methods provided below. We will respond to your request as required by law.

Authorized Agent. If you choose to submit a request through an authorized agent, we may need to verify the agent’s identity and may reach out to you directly to confirm that you have provided the agent with permission to act on your behalf. Please note that we may deny a request from an agent who fails to provide proof of authorization to act on your behalf.

9. Additional Information for Virginia Consumers 

This Additional Information for Virginia Consumers section applies solely to “consumers” as defined by the Consumer Data Protection Act (“CDPA”).

You have the right to confirm whether we process your personal information and request access to such personal information. You have the right to request the deletion of your personal information, subject to certain exceptions. You have the right to request correction of inaccurate personal information we maintain about you. You have the right to opt out of certain disclosures of your personal information for monetary consideration. We want to assure you that we do not sell your personal information as defined by the CDPA. We may process personal information for targeted advertising purposes, but you have the right to opt out of such processing if it relates to targeted advertising and profiling that significantly affects you legally or otherwise.

Where the processing is automated, you have the right to request a copy of your personal data you previously provided to us in a portable and, where feasible, readily usable format.

Right to non-discrimination. We are committed to not discriminating against you for exercising any of the rights mentioned above. However, we may offer different service levels or charge different rates reasonably related to the value of your personal information.

To exercise Your Rights: Please reach out to us using one of the contact methods provided below. If your request is denied, you have the option to appeal by emailing us at dpo (a) healy.world. Please include “Appeal” in the subject line of your email. We will respond to your appeal in writing within 60 days of receiving it. In case your appeal is denied, you have the right to file a complaint with the Virginia Attorney General via the following link: https://www.oag.state.va.us/consumercomplaintform/form/start

Verification. To ensure the security of your personal information, we may need to verify your identity before processing your request. Depending on our relationship and interaction with you, we may request certain data points to confirm your identity or authority to make the request. Rest assured that any personal information provided for verification purposes will be used solely for that purpose.

10. ADDITIONAL INFORMATION FOR CONSUMERS IN CANADA

In addition to the information provided in this privacy policy, we want to address the rights and considerations afforded to Canadian consumers under the Personal Information Protection and Electronic Documents Act (PIPEDA):

Consent: By using the Healy Apps, you provide us with implied consent to collect, use, and disclose your personal information as outlined in this privacy policy.

Access to Personal Information: You have the right to access your personal information held by us and request any necessary corrections.

Withdrawal of Consent: You may withdraw your consent for us to collect, use, or disclose your personal information at any time, subject to legal or contractual restrictions and reasonable notice.

Challenging Compliance: If you have concerns about our compliance with PIPEDA or our handling of your personal information, you can address them with our designated privacy contact.

Data Transfers: Please note that personal information collected through the Healy App may be stored or processed in jurisdictions outside of Canada. When personal information is transferred to these jurisdictions, it is done in compliance with applicable laws and appropriate safeguards.

Retention of Personal Information: We retain your personal information for as long as necessary to fulfill the purposes outlined in this privacy policy or as required by law. Once your personal information is no longer required, it will be securely disposed of or de-identified.

Privacy Inquiries: For any privacy-related inquiries, requests, or concerns, please contact our designated privacy contact, whose details are provided at the end of this privacy policy.

11. ADDITIONAL INFORMATION FOR CONSUMERS IN MEXICO

In addition to the information provided in this privacy policy, we want to address the rights and considerations afforded to consumers in Mexico under Mexico’s Data Protection Law (Ley Federal de Protección de Datos Personales en Posesión de los Particulares):

By using the Healy Apps, you provide us with your consent to collect, use, and disclose your personal data as described in this privacy policy, in accordance with Mexico’s Data Protection Law.

You have the right to access your personal data held by us and request any necessary corrections.

You may withdraw your consent for us to collect, use, or disclose your personal data at any time, subject to legal or contractual restrictions and reasonable notice.

If you have concerns about our compliance with Mexico’s Data Protection Law or our handling of your personal data, you may file a complaint with our designated privacy contact.

Please note that personal data collected through the Healy App may be stored or processed in jurisdictions outside of Mexico. When personal data is transferred to these jurisdictions, it is done in compliance with applicable laws and with appropriate safeguards.

Retention of Personal Information: We retain your personal data for as long as necessary to fulfill the purposes outlined in this privacy policy or as required by law. Once your personal data is no longer needed, it will be securely disposed of or anonymized.

Privacy Inquiries: For any privacy-related inquiries, requests, or concerns, please contact our designated privacy contact, whose details are provided at the end of this privacy policy.

12. ADDITIONAL INFORMATION FOR AUSTRALIA

This section provides additional information specifically for individuals in Australia:

We are committed to complying with the Australian Privacy Principles (APPs) outlined in the Privacy Act 1988 (Cth) and other relevant privacy laws and regulations.

We collect and process personal information for specific purposes that will be disclosed to you at the time of collection or as required by law. We only collect personal information that is necessary for the purposes stated and will not use it for any other unrelated purposes without your consent.

We take appropriate measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. We implement physical, technical, and administrative safeguards to ensure the security and confidentiality of your personal information.

You have the right to access the personal information we hold about you and request correction or amendment if it is inaccurate, incomplete, or out of date. To exercise this right, please contact us using the methods provided below.

In certain circumstances, we may disclose your personal information to recipients located outside of Australia. When doing so, we take steps to ensure that appropriate data protection measures are in place to safeguard your personal information.

If you have any concerns or complaints regarding the handling of your personal information, please contact us using the methods provided below. We take privacy-related matters seriously and will investigate and address any issues promptly.

For any privacy-related inquiries, requests, or concerns, please reach out to us using the contact information provided below. We will respond to your inquiries in a timely manner and in accordance with applicable privacy laws and regulations.

13. ADDITIONAL INFORMATION FOR HONG KONG

We comply with the applicable data protection laws in Hong Kong, including the Personal Data (Privacy) Ordinance (PDPO) and other relevant regulations.

We process personal information for specific purposes, which will be communicated to you at the time of collection or as required by law.

In accordance with the PDPO, we will obtain your consent before collecting and processing your personal information. You have the right to opt-out of certain data processing activities, and we respect your decision. Please contact us using the provided methods to opt-out. You have the right to request access to your personal information held by us and to request the correction, amendment, or deletion of any inaccurate or outdated information. To exercise your rights, please contact us using the provided methods.

For any inquiries, requests, or concerns regarding the handling of your personal information, please reach out to us using the contact information provided below. We will respond promptly and in accordance with applicable laws and regulations.

14. ADDITIONAL INFORMATION FOR INDIA

In India, the applicable privacy law is the Personal Data Protection Bill (PDPB). The PDPB aims to protect the privacy and personal data of individuals in India. It sets out guidelines and requirements for the collection, processing, storage, and sharing of personal information.

Under the PDPB, we are committed to ensuring the confidentiality and security of your personal information. We will obtain your consent before collecting and processing your data, and we will only use it for specific purposes disclosed to you. We take appropriate measures to safeguard your data and retain it only for as long as necessary.

You have the right to access and correct your personal information held by us. If you have any questions, concerns, or requests regarding the handling of your data, please contact us using the provided methods.

15. ADDITIONAL INFORMATION FOR KOREA

We comply with the Korean Personal Information Protection Act (PIPA). The PIPA is designed to protect the privacy and personal information of individuals in Korea. It sets out guidelines and requirements for the collection, use, disclosure, and handling of personal information.

Under the PIPA, we are committed to ensuring the confidentiality and security of your personal information. We will obtain your consent before collecting and processing your data, and we will only use it for specific purposes disclosed to you. We take appropriate measures to safeguard your data and retain it only for as long as necessary.

You have the right to access and correct your personal information held by us. If you have any questions, concerns, or requests regarding the handling of your data, please contact us using the provided methods.

16. ADDITIONAL INFORMATION FOR MALAYSIA

We are committed to protecting your privacy and complying with the Personal Data Protection Act 2010 (PDPA) of Malaysia. The PDPA sets out guidelines and requirements for the collection, use, disclosure, and handling of personal data. We collect and process personal data in a lawful and fair manner. The personal data collected will be used for specific purposes that we will disclose to you. We take necessary measures to ensure the security and confidentiality of your personal data. We obtain your consent before collecting and processing your personal data. You have the right to access, correct, and update your personal data. If you have any questions, concerns, or requests regarding the handling of your personal data, please contact us using the provided methods.

17. ADDITIONAL INFORMATION FOR NEW ZEALAND

We respect your privacy and comply with the Privacy Act 2020 of New Zealand. The Privacy Act sets out principles for the collection, use, and protection of personal information.

We collect and use personal information in a lawful and fair manner, ensuring that it is used only for the specified purposes communicated to you at the time of collection.

We take appropriate measures to safeguard your personal information against unauthorized access, loss, or alteration. We handle your personal information with care and in accordance with the requirements of the Privacy Act. You have the right to access and correct any personal information we hold about you. If you have any inquiries or requests regarding your personal information, please contact us using the provided methods.

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected. We do not disclose your personal information to third parties without your consent, unless permitted or required by law.

18. ADDITIONAL INFORMATION FOR PHILIPPINES

We are committed to protecting your privacy and complying with the applicable privacy laws of the Philippines, including the Data Privacy Act of 2012. We adhere to the principles and guidelines set forth in the Data Privacy Act to ensure the proper handling, collection, use, disclosure, and protection of personal information.

We collect and use personal information in a lawful and transparent manner, ensuring that it is used only for the purposes communicated to you and in accordance with the provisions of the Data Privacy Act.

19. ADDITIONAL INFORMATION FOR SINGAPORE

We prioritize the protection of your privacy and comply with the Personal Data Protection Act (PDPA) of Singapore. The PDPA outlines guidelines and requirements for the collection, use, disclosure, and handling of personal data. We collect and process personal data in a lawful and transparent manner, and we will inform you of the specific purposes for which your personal data will be used. Your personal data is handled with utmost security and confidentiality. Before collecting and processing your personal data, we will seek your consent. You have the right to access, correct, and update your personal data. If you have any inquiries, concerns, or requests regarding the handling of your personal data, please contact us using the provided methods.

20. ADDITIONAL INFORMATION FOR TAIWAN

We are committed to safeguarding your privacy and complying with the Personal Data Protection Act (PDPA) of Taiwan. The PDPA establishes regulations and requirements for the collection, use, processing, and protection of personal data. We collect and process personal data in a lawful and fair manner, ensuring that it is used for specific purposes that we will disclose to you. We take necessary measures to maintain the security and confidentiality of your personal data. Before collecting and processing your personal data, we will obtain your consent. You have the right to access, correct, and update your personal data in accordance with the PDPA. If you have any questions, concerns, or requests regarding the handling of your personal data, please contact us using the provided methods.

21. ADDITIONAL INFORMATION FOR THAILAND

We comply with the applicable data protection laws in Thailand, including the Personal Data Protection Act (PDPA) and other relevant regulations.

We process personal information for specific purposes, which will be clearly communicated to you at the time of collection or as required by law. In accordance with the PDPA, we will obtain your consent before collecting and processing your personal information. You have the right to withdraw your consent at any time, and we will respect your decision. To opt-out of certain data processing activities, please contact us using the provided methods. For any inquiries, requests, or concerns regarding the handling of your personal information, please reach out to us using the contact information provided below. We will respond to your inquiry promptly and in accordance with applicable laws and regulations.

22. ADDITIONAL INFORMATION FOR JAPAN

We are committed to complying with applicable data protection laws in Japan, including the Act on the Protection of Personal Information (APPI) and other relevant regulations.

We process personal information for specific purposes, which will be clearly communicated to you at the time of collection or as required by law. In accordance with the APPI, we will obtain your consent before collecting and processing your personal information. You have the right to withdraw your consent at any time, and we will respect your decision. If you wish to opt-out of certain data processing activities, please contact us using the methods provided below.

We take appropriate technical and organizational measures to safeguard your personal information against unauthorized access, loss, or alteration. Our security practices are in accordance with the requirements of the APPI.

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws and regulations.

You have the right to request access to your personal information held by us and to request the correction, amendment, or deletion of any inaccurate or outdated information. Please contact us using the methods provided below to exercise your rights.

For any inquiries, requests, or concerns regarding the handling of your personal information, please reach out to us using the contact information provided below. We will respond to your inquiry promptly and in accordance with applicable laws and regulations.

23. Changes and amendments

We reserve the right to modify this Policy or its terms related to the Apps at any time at our discretion. When we do, we will revise the updated date at the bottom of this page, post a notification in the Mobile Application. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Apps after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

24. Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Apps and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Mobile Application and Services.

25. Contacting us

If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using at privacy@healy.world

We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.

Status of the privacy policy: 15.06.2023