Privacy Policy for Independent Healy World Members Ukraine

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 World Ukraine LCC, 20, Ioannes Paulus II Street, Kiev, 01042, Ukraine (hereinafter “HEALY”, “we”, “us”) in connection with your HEALY membership as an Independent Healy World Member (hereinafter “Independent Member”, “IHWM”). HEALY is complying with the very high standard of the European Union’s General Data Protection Regulation (GDPR) and The Law of Ukraine No. 2297 VI on Personal Data Protection (Data Protection Law) and considering its underlying principles in how we think about member trust and data privacy as a core pillar of our business.

1. Data Controller

The controller of the processing of your personal data is:

Healy World Ukraine LCC,
20, Ioannes Paulus II Street,
Kiev, 01042, Ukraine

The data protection officer of the data controller can be reached at:

Healy World GmbH
Data Protection Team
Tauentzienstraße 9 (c/o Europa Center)
10789 Berlin
Germany

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Information described here, your choices and rights regarding such use, or you wish to exercise your rights, please contact the Data Protection Officer at the e-mail: privacy@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 Member. If a contract is concluded between HEALY 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 membership
In order to conclude a membership as an Independent Healy World Member, we collect the following personal data from you:
– Name
– Gender
– Your address
– Date of birth
– country
– language
– Proof of identity
– Company name
– Company phone number
– E-mail Address
– Certifications
– Tax number
– Bank details

This data collection serves the purpose of establishing, implementing and terminating our business relationship as well as ongoing administration.

Specifically, your personal data will be processed for the following purposes:

– Administration of their HEALY membership;
– Processing of deliveries / orders;
– Sending advertising and information material;
– Conducting trainings, seminars and internal events;
– Issuing certifications;
– Processing payments and remunerations;
The data will be stored until the complete execution of the IHWM contract. Insofar as commercial and tax retention periods exist, the duration of storage may be up to 10 years.

2.2 Collection and use of personal data for contact requests
When contacting HEALY by telephone or e-mail, the data provided (your e-mail address, first and last name, if applicable) will be stored by HEALY in order to answer your inquiry. HEALY deletes the data accrued in this context after the storage is no longer necessary, e.g. when your request has been dealt with. Otherwise, processing will be restricted if there are legal obligations to retain data.

2.3 Collection of Personal Data when Using the HEALY Website
We offer you the opportunity to log in via our website after concluding a membership as an Independent 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
HEALY will only process your personal data for the purpose of sending you a newsletter if you have consented to this in advance. The only mandatory information for sending the newsletter is the e-mail address. The provision of further, separately marked data is voluntary and will be used to address you personally. After confirmation, HEALY stores your e-mail address for the purpose of sending you the newsletter.

This data processing is based on the consent given by you. You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You can declare the revocation by clicking on the link provided in each newsletter e-mail.

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.

3. Recipients of your personal data

HEALY will only disclose your personal data to the extent necessary to conduct our business relationship 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 execution of the contract and the provision of the services. Where such service providers act as processors for HEALY, 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 service 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 it.

A transfer of data to third countries (i.e., countries that are neither members of the European Union nor the European Economic Area) may take place to the extent necessary to perform services for you, is required by law, or you have given us your consent. In addition, there is the possibility that 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. For 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.
You can obtain a copy of the specifically applicable or agreed regulations to ensure the appropriate level of data protection from us. Please use the information in section 1 for this purpose.

4. Storage period

We store your data for as long as specified in the respective processing activities under section 2 and for as long as this is necessary to provide our services to you or we have a legitimate interest in the continued storage.

In addition, we are subject to various storage and documentation obligations, which result, among other things, from the local Commercial Code and Fiscal Code. The retention and documentation periods specified there are up to ten years. Finally, the storage period is also assessed according to the statutory limitation periods, which can be up to thirty years, for example, according local Civil Code, whereby the regular limitation period is three years.

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.
If you have concluded a contract with us or use our services, we process your data as long as it is necessary for the execution of the respective contract or the provision of the respective service, possibly plus the duration of any warranty or guarantee periods.
When using some applications on your backoffice, we may retain usage data for internal analysis purposes and backup copies for a very limited period of time for specific input, to strengthen the security for example. As soon as the related interest no longer exists (e.g. by eliminating the error), we also erase this data immediately afterwards.

5. Rights of the data subjects

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. 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 erasure; (c) we no longer need the data, but you need the data to assert, exercise or defend legal claims.
• Right to erasure: You may 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 to process your personal data if such processing is necessary to comply with our legal obligations or to assert, exercise or defend legal claims;
• 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. Such a revocation does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
• Right of complaint: You have the right to file a complaint with the data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement you consider that the processing of personal data relating you infringes the Data Protection Regulation.

Right to object: you have the right to object to the processing of your personal data on grounds relating to your personal situation, provided that 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 that 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 it is covered by such direct marketing measures.

Please note that we may ask you to verify your identity before responding to such requests. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. If we are unable to verify your identity, we reserve the right to deny the request.

6. 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 attract children. In the event that we learn that a child under the age of 16 has provided personal information to us, we will delete or destroy such personal information as soon as possible.

7. Changes to this Privacy Policy
We may amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on our backoffice and update the notice’s “Status” date. Where permitted by applicable law, your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

We hope that this information has helped you to exercise your rights. If you would like more detailed information on the data protection provisions, please do not hesitate to contact us.

Status of the Privacy Policy: 15.07.2021