We are committed to protecting your personal information and your right to privacy. This Privacy Policy informs you about what personal data is processed by HEALY WORLD TURKEY MİKRO FREKANS CİHAZLARI TİCARET LİMİTED ŞİRKETİ. (hereinafter ” HEALY WORLD “, “we”, “us”) in connection with your membership as an Independent Healy World Member (hereinafter “IHWM”).
HEALY WORLD complies with the European Union’s General Data Protection Regulation (GDPR) and takes into account its underlying principles when considering how we think about member trust and privacy as core to our business.
- Data controller
Joint controllers for the processing of your personal data are:
HEALY WORLD TURKEY MİKRO FREKANS CİHAZLARI TİCARET LİMİTED ŞİRKETİ
Kozyatağı Mah. Çardak Sk.
Herti Plaza No:1/a
Kadıköy/İstanbul
34742
and
Healy World GmbH
Isaac-Fulda-Allee 1
55124 Mainz
Germany
Joint responsibility applies to all processing activities. The controllers are jointly responsible to you as the data subject for the lawfulness of the joint data processing. The respective data controllers have agreed that they will provide the data protection information required under Art. 12 et seq. GDPR among themselves and make it available to the data subjects in a transparent and easily accessible manner. Insofar as you wish to assert the rights to which you are entitled under Art. 15 to 22 GDPR with regard to the joint processing of your personal data by the data controller, the data protection officer shall act as the main contact. Notwithstanding the foregoing, you may also assert the rights to which you are entitled in connection with the joint processing of your personal data directly against each individual controller.
You can contact the data protection officer of the data controller at the postal address
Healy World GmbH
-Data Protection Officer-
Isaac-Fulda-Allee 1
55124 Mainz
Germany
or at the e-mail address dpo@healy.world
If you have any questions or comments about this Privacy Policy, how we collect and use your personal information described herein, your choices and rights regarding such use, or if you wish to exercise your rights, please contact the Data Protection Officer at the email address above.
- 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 Member. If a contract is concluded between HEALY WORLD and you, you only have to provide the personal data that is required for the initiation and execution of the contract or that we are legally obliged to collect. Without this data, we usually have to refuse the conclusion of the contract or the execution of the order or can no longer execute an existing contract and may have to terminate it.
2.1 Collection of personal data for the conclusion of your HEALY membership
In order to complete a membership as an Independent Healy World Member, we collect the following personal information from you:
- Name
- Gender
- Address, contact details
- Date of birth, marital status
- Language
- Proof of identity
- Company name
- E-mail address, password
- Tax number, social security number, registration number
- Bank details of an external e-wallet (iPayout) account.
The collection of data serves the purpose of establishing, implementing and terminating our business relationship as well as ongoing administration. The legal basis for this data processing is Art. 6 para. 1 lit. b of the General Data Protection Regulation (“GDPR”).
Specifically, your personal data will be processed for the following purposes:
- Management of their HEALY WORLD membership;
- Processing of deliveries/orders;
- Sending advertising and information material;
- Conduct training, webinars, and internal events;
- Processing of payments and charges;
- remit payments to the tax authorities and report income to the tax authorities;
The data will be stored until the contractual relationship has been completed. Insofar as commercial and tax retention periods exist, the duration of storage may be up to 10 years.
We may automatically collect certain information, such as Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referral/exit pages, operating system, date/time stamp, your website activity, and/or clickstream data for purposes such as analyzing trends, administering the websites, improving the function and content of the websites, and enforcing our Terms. We use standard Internet technologies such as cookies, web beacons, session replay/screen capture, and similar technologies to collect this data. More information about cookies can be found in our Cookie Policy in the footer of our HEALY WORLD website.
We may also collect precise information about your location, such as GPS coordinates of your mobile device, cell tower information, and/or Wi-Fi signals. HEALY WORLD may use this information to personalize
your experience in connection with your use of the Sites and BackOffice. If you do not want HEALY WORLD to collect and use your specific geolocation data, you can disable the location tracking features on your device or browser. For this purpose, check the device manufacturer’s settings.
2.2 Collection of personal data during your HEALY membership
If you have registered as an IHWM, we use the information we collect about you for a variety of purposes, including to
- Communicate with you about your account in the BackOffice or your transactions;
- new IHWM to assist in finding sponsors;
- Changes to our policies and other administrative matters to follow;
- Provide you with promotional information, relevant content, surveys and other materials regarding training, promotions, events;
- improve our products, services and processes;
- to ensure compliance with our Compensation Plan;
- ensure compliance with the Compliance Rules of Conduct, corporate guidelines and rules, and applicable laws;
- to protect, enforce or defend the rights, privacy, safety or property of HEALY WORLD and others.
HEALY WORLD or its authorized third parties may contact you directly for these purposes by telephone, email, WhatsApp, Telegram, Messenger or any other method of contact.
We may retain your data for as long as necessary for the following purposes: to provide services to you; to fulfill other legitimate business needs, such as maintaining the proper functioning of the sales and marketing plan; to fulfill our compliance and legal obligations, resolve disputes, and enforce
our agreements, including the IHWM Agreement, Art. 6 (1) lit. b GDPR and Art. 6 (1) lit. f GDPR.
2.3 Collection of personal data when using the HEALY BackOffice
We offer you the possibility to log in as IHWM via our BackOffice. When using the login option, the personal data transmitted in the process will be processed (e.g. name and surname, address, telephone number, e-mail address, password, member name, bank data eWallet/iPayout). Without the processing of these data the use of the area for IHWM is not possible.
2.4 Passing on data in genealogy
As an IHWM, your personal information (name, contact information, title, volume and sales statistics, etc. ) will be provided to your sponsors to assist in growing their HEALY WORLD business. This allows your sponsors to provide you with a more personalized experience, inform you of promotions and special offers, educate you on our HEALY WORLD training platforms. Sponsors who receive your information are bound by the terms of their IHWM agreement and the privacy policy contained therein. Some of these sponsors may be located in countries that do not provide the same or similar data protection as exists in your country. This data processing is based on Art. 6 (1) lit. f GDPR.
As IHWM, your personal data (name, first name) will be made available to your potential customers in the eShop to support the expansion of your HEALY WORLD business when they enter your referral number. This data processing is based on Art. 6 para. 1 lit. b DSGVO, for the implementation of pre-contractual measures.
Furthermore, based on your consent, your data (name, title, contact details) can be displayed to the entire genealogy in the BackOffice. This data sharing is for better communication and especially for more individual business motivation. This data may also be shared by our Customer Support in case of requests from your uplines or downlines. This data processing is based on your consent, Art. 6 para. 1 lit. a GDPR, which you can revoke at any time in the BackOffice.
2.5 Use of data for advertising purposes, newsletter
HEALY WORLD processes your personal data for the purpose of sending you business emails relating to the functionality of the Independent Member area and your membership as an Independent Member. These emails do not constitute advertising and are sent for the purpose of the ongoing management of the business relationship based on Art. 6 (1) lit. b GDPR.
If you have consented to this, we may additionally send you a customized newsletter to inform you about special promotions, actions, events, webinars, HEALY WORLD products. This may highlight your name, title and special achievements. You may revoke your consent to receive the newsletter at any time in the BackOffice and unsubscribe. You can also declare the revocation by clicking on the link contained in every newsletter e-mail.
If you have consented, we may highlight your name, likeness, title and special achievements in our newsletter or digital publications. We may also share these tributes on our official social media channels (Facebook, Instagram, etc.). You can revoke your consent at any time for the future in the BackOffice.
If you have consented, we may also ask you to participate in specific surveys regarding our products in order to share your testimonials with us. These testimonials may be published both internally and in external media (Facebook, Instagram, website, etc.). You can revoke your consent at any time in the BackOffice.
- Recipients of your personal data
HEALY WORLD will disclose your personal data only to the extent necessary to conduct our business relationship or to protect HEALY WORLD’s legitimate interests. HEALY uses external service providers, such as hosting providers, payment service providers and shipping service providers, for the execution of the contract and the provision of services. Where these service providers act as processors for HEALY WORLD, separate order processing agreements have been concluded to ensure the protection of customers’ personal data. For the operation of the Independent Member Area, we use the services of Jia, Inc, 203 Park Plaza Dr, Suite 250, Vancouver, WA 98684, United States (“Jenkon”), which acts as our processor. Jenkon provides us with the software necessary to operate.
A transfer of data to third countries (i.e. countries that do not belong to the European Union or the European Economic Area) may take place insofar as this is necessary to provide services to you, is required by law or you have given us your consent. In addition, we may also transfer your personal data to processors in third countries.
Please note that not all third countries have a level of data protection recognized as adequate by the European Commission. In the case of data transfers to third countries that do not have an adequate level of data protection, we ensure before the transfer that either an adequate level of data protection exists at the recipient (e.g. by agreeing on so-called EU standard contractual clauses of the European Union with the recipient) or that our users have given their express consent.
- Duration of storage
We will not store your personal data for longer than is necessary to achieve the respective data processing purposes stated in this Privacy Policy.
If you have concluded a contract with us or use our services, we will process your data for as long as is necessary for the performance of the respective contract or the provision of the respective service, plus the duration of any warranty or guarantee periods, if applicable.
When using some applications in your back office, we may retain usage data for internal analysis purposes and backup copies for a very limited period of time for certain inputs, e.g. to strengthen security. As soon as the related interest no longer exists (e.g. by eliminating the error), we also delete this data immediately afterwards.
- rights of the data subjects
If you are a resident of the European Union or the European Economic Area (EU/EEA), you may have certain data protection rights under certain circumstances, such as
- Right of access: you have the right to obtain information about your personal data processed by us and to receive a copy of this 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. This right is limited to specific cases and exists in particular when: (a) the data is inaccurate; (b) the processing is unlawful and you object to the erasure; (c) we no longer need the data, but you need the data to assert, exercise or defend legal claims.
- Right to erasure: You can request the erasure of your personal data, unless there is a retention obligation. The right to erasure is not a right without exception. For example, we have the right to continue processing your personal data if such processing is necessary for compliance with our legal obligations or for the establishment, exercise or defense of legal claims;
- Right to data portability: This right implies that we transfer your personal data, as far as 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. Such a revocation does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
- Right to complain: You have the right to complain to the data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the Data Protection Regulation.
Right to object: You have the right to object, on grounds relating to your personal situation, to the processing of your personal data where the processing is carried out in the public interest or on the basis of a balance of interests, including profiling. In the event of your objection, we will stop processing your personal data unless we can demonstrate compelling grounds which override your interests or the processing of your personal data is necessary for the establishment, exercise or defense of legal claims. Insofar as we process your personal data for direct marketing purposes, you have the right to object to this processing at any time; this also applies to the creation of profiles, insofar as they are covered by such direct marketing measures.
Please note that we may ask you to verify your identity before responding to such requests. We will not be able to respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm that the personal information relates to you. If we are unable to verify your identity, we reserve the right to refuse your request.
- Collection and use of information from children
The Website is not intended for children. We do not knowingly collect personal information from children, and the Website is not designed to target children. If we learn that a child under the age of 18 has provided us with personal information, we will delete or destroy that personal information as soon as possible.
- Changes to this privacy policy
We may change this Privacy Policy at any time. If we make changes to this Privacy Policy, we will post the updated notice on our back office. 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.
We hope that this information has helped you to exercise your rights. If you would like more detailed information about the privacy policy, please do not hesitate to contact us.
Privacy policy status: 1.11.2022
