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Privacy Policy

FEELINHEALTHY 

PRIVACY POLICY


The party responsible within the meaning of the General Data Protection Regulation (GDPR) is:

Barimus Creative Technology Solutions OÜ (“We”)

Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 15551
Estonia

Email:[email protected] 

Data protection officer:

Barimus Creative Technology Solutions OÜ (“We”)
Chief Officer Corporate Data Protection

Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 15551
Estonia

Email:[email protected] 

This privacy policy will explain how our organization uses the personal data we collect from you when you use our website including but not limited to “www.feelinhealthy.com”.

Privacy Policy Contents

This Privacy Policy describes how we handle and protect your personal data and the choices available to you regarding collection, process, access, and how to update, correct and delete your personal data. Additional information on our personal data practices may be provided in product settings, contractual terms, or notices provided prior to or at the time of data collection.


This Privacy Policy is intended for you if you are a user of our products and services.

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Personal Data We Process

Personal data refers to any information relating to an identified or identifiable natural person (“Personal Data”). 

We may collect data or ask you to provide certain data when you visit and use our websites, products and services. The sources from which we collect Personal Data include: 

  • Data collected directly from you or your device relating to an identified or identifiable natural person (“Data Subject”), and may include direct identifiers such as name, address, email address, phone number, and online or indirect identifiers such as login
  • account number, login password, marketing preferences, social media account, or IP address;
  • If we link other data relating to you with your Personal Data, we will treat that linked data as Personal Data; and
  • We may also collect Personal Data from trusted third-party sources such as distributors, resellers, app stores, contact centers, and engage third parties such as marketing, survey, analytics or software suppliers to collect Personal Data to assist us.

We do not process special categories of personal data or deduce in any way this type of information from data we collect within our products. 


Why We Process Your Personal DataWe use your Personal Data for the following purposes and on the following grounds:

On the basis of fulfilling our contract with you or entering into a contract with you on your request, in order to:

  • Process purchase of our products or services from us, our partners or our trusted third- party service providers’ online stores;
  • Provision the download, activation, and performance of the product or service;
  • Keep our products or services up-to-date, safe and free of errors, including implementation of new product features and versions;
  • Verify your identity and entitlement to paid products or services, when you contact us for support or access our services;
  • Process your purchase transactions;
  • Update you on the status of your orders and licences;
  • Manage your subscriptions and user accounts; and
  • Provide you with technical and customer support.

On the basis of your consent, in order to:

  • Subscribe you to a newsletter;
  • Enable the provision of third-party ads in product messages;
  • Enable the provision of personalized ads in support of certain products; and
  • Allow us to record our phone conversation when you contact our tech support by phone.

We will always ask for your consent before any processing that requires it and provide you with necessary information as applicable. 


On the basis of legal obligations, we process your Personal Data when it is necessary for compliance with a legal tax, accounting, anti-money laundering, legal order, sanction checks or other obligation to which we are subject.

On the basis of our legitimate interest we will use your Personal Data to:

  • Communicate about possible security, privacy and performance improvements and products that supplement or improve our purchased products and to optimize the content and delivery of this type of communication;
  • Evaluate and improve the performance and quality of our products, services and websites, develop new products, train our employees and to understand usage trends, and analyze user acquisitions, conversions and campaigns;
  • Allow interoperability within our applications;
  • Secure our systems and applications;
  • Allow effective performance of our business by ensuring necessary internal administrative and commercial processes (e.g. finances, controlling, business intelligence, legal & compliance, information security etc.); and
  • Establish, exercise or defend our legal rights.

For the above mentioned processing operations, we have balanced your interests against our interests. In any case, you have the right to object, on grounds relating to our particular situation, to those processing operations. 


Balancing Legitimate Interests

Before relying on our legitimate interests, we balanced them against your interests and made sure they are compelling enough and will not cause any unwarranted harm. With respect to the purposes below we consider necessary to explain what our interests are in detail.

Systems, Apps and Network Security

We process Personal Data for network and information security purposes. In line with EU data protection law, organizations have a recognized legitimate interest in collecting and processing Personal Data to the extent strictly necessary and proportionate for the purposes of ensuring network and information security. This primarily covers the ability of a network or of an information system to resist events, attacks or unlawful or malicious actions that could compromise the availability, authenticity, integrity and confidentiality of stored or transmitted data, or the security of the related services offered by, or accessible via those networks and systems.

Both as an organization in our own right, and as a provider of information technologies and services which may include hosted and managed interconnected technology services, it is necessary for the functionality of our systems, products and services and in our legitimate interests as well as in our users’, to collect and process Personal Data to the extent strictly necessary and proportionate for the purposes of ensuring the security of our own, and of our users’ networks, devices, and information systems. This includes the development of threat intelligence resources aimed at maintaining and improving on an ongoing basis the ability of our networks and systems, and those of certain partners, to resist unlawful or malicious actions and other harmful events (“cyber-threats”).

The Personal Data we process for said purposes includes, without limitation, network traffic data related to cyber-threats such as:

  • Sender email addresses (e.g., of sources of SPAM);
  • Recipient email addresses (e.g., of victims of targeted email cyberattacks including phishing);
  • Reply-to email addresses (e.g., as configured by cybercriminals sending malicious email);
  • Filenames and execution paths (e.g., of malicious or otherwise harmful executable files attached to emails);
  • URLs and associated page titles (e.g., of web pages broadcasting or hosting malicious or otherwise harmful contents); and/or
  • IP addresses (e.g., of web servers and connected devices involved in the generation, distribution, conveyance, hosting, caching or other storage of cyber-threats such as malicious or otherwise harmful contents).

Depending on the context in which such data is collected, it may contain Personal Data concerning you or any other Data Subjects. However, in such cases, we will process the data concerned only to the extent strictly necessary and proportionate to the purposes of detecting, blocking, reporting (by removing any personally identifiable elements) and mitigating the cyber-threats of concern to you, and to secure your network, device and systems. When processing Personal Data in this context, we do not seek to identify a Data Subject.

In-product and Email Messages

We have a legitimate interest for messaging our users about possible security, privacy and performance improvements and products that supplement or improve purchased products.

If you are our customer, we feel a responsibility to inform you about security and utility improvements and possible problems to your device and software that go beyond our product that is installed and provide you with effective solutions relevant to these problems. We thus have legitimate interest to optimize the content and delivery of this type of communication to you so that you will be most likely to find them relevant and non-intrusive at the same time.

Product and business improvement

We have a legitimate interest to use necessary Personal Data to understand user conversions, acquisitions and campaign performance through various distribution channels, and users’ download, activation and interactions with our products because these analytics help us improve functionality, effectiveness, security and reliability of our products and business activities and develop new products. 




How We Process Your Personal Data

We do our best to disconnect or remove all direct identifiers from the Personal Data that we use during the normal performance of the products and services.

Processing of IP Addresses

Your IP address is collected at the time at which your product or service is being provided, for the purpose of facilitating our billing process. Specifically, our third-party billing partner will collect your IP address for its billing process; we do not store the IP address from this process.

Your IP address is also processed for the purpose of downloading certain products, product authorization, fraud and malware detection.

Personalization

We use your answers from surveys, in which you can participate, and relevant Product Data to personalize communication and recommend our relevant products for you.

We do not take any decisions solely based on algorithms, including profiling, that would significantly affect you.


How We Disclose Your Personal Data

We only disclose your Personal Data as described below, within our group, with our partners, with service providers that process data on our behalf and with public authorities, as required by applicable law. Processing is only undertaken for the purposes described in this Privacy Policy. If we disclose your Personal Data, we require its recipients to comply with adequate privacy and confidentiality requirements, and security standards.


Service Providers

We may use contractors and service providers to process your Personal Data for the purposes described in this Privacy Policy. We contractually require service providers to keep data secure and confidential.


Such service providers may include in particular contact centers, professional consultants (including for defence or exercise of our rights), and marketing/survey/analytics/software suppliers.

Sometimes these service providers, for example, our distributors, resellers, and app store partners, will be independent controllers of your data and their terms and conditions, end user license agreements (“EULA”) and privacy statements will apply to such relationships.


Advertising Companies

To be able to offer our products and services for free, we serve third-party ads of advertising companies in our products for mobile devices. To enable the ad, we embed a software development kit (“SDK”) provided by an advertising company into the product, which then collects Personal Data in order to personalize ads for you. 

Please note that only few of our products serve third-party ads. You will be asked for consent during the installation process of such product. 


Distributors, Resellers

We may provide your Personal Data to our partners for the purpose of distribution, sale or management of our products. Our partners may use your Personal Data to communicate with you and others about Our products or services. In addition, you purchase our products directly from our distributor, a reseller, or an app store. Because your relationship in these cases is with that distributor, reseller or an app store, such third party will also process your Personal Data.

Cookies Providers

Our websites use cookies to personalize your experience on our sites, tell us which parts of our websites people have visited, help us measure the effectiveness of campaigns, and give us insights into user interactions and user base as a whole so we can improve our communications and products.. While using our websites, you will be asked to authorize the collection and use of data by cookies.


Analytics Tool Providers

We use analytical tools, including third-party analytical tools, which allow us to, among other things, identify potential performance or security issues with our products, improve their stability and function, understand how you use our products, and websites, so that we can optimize and improve your user experience, as well as evaluate and improve our campaigns. We use Service and Device data for analytics.

While we generally prefer using our own analytical tools, we sometimes need to partner with other parties, which have developed and provide us with their own tools and expertise. Below, we list these partners and tools and their privacy policies.


Please note that not all of our products use all of these third-party analytics tools. Analytics tools that we use for diagnosing your product are necessary for service provision. 


Public Authorities

In certain instances, it may be necessary for us to disclose your Personal Data to public authorities or as otherwise required by applicable law. No Personal Data will be disclosed to any public authority except in response to:

  • A subpoena, warrant or other process issued by a court or other public authority of competent jurisdiction;
  • A legal process having the same consequence as a court-issued request for data, in that if we were to refuse to provide such data, it would be in breach of local law, and it or its officers, executives or employees would be subject to liability for failing to honor such legal process;
  • Where such disclosure is necessary for us to enforce its legal rights pursuant to applicable law; or
  • A request for data with the purpose of identifying and/or preventing credit card fraud.


How We Protect Your Personal Data

We maintain administrative, technical, and physical safeguards for the protection of your Personal Data.

Administrative Safeguards

Access to the Personal Data of our users is limited to authorized personnel who have a legitimate need to know based on their job descriptions, for example, employees who provide technical support to end users, or who service user accounts. In the case of third-party contractors who process personal information on our behalf, similar requirements are imposed. These third parties are contractually bound by confidentiality clauses, even when they leave. Where an individual employee no longer requires access, that individual's credentials are revoked.


Technical Safeguards

We store your personal information in our database using the protections described above. In addition, we utilize up-to-date firewall protection for an additional layer of security. We use high-quality antivirus and anti-malware software, and regularly update our virus definitions. Third parties who we hire to provide services and who have access to our users' data are required to implement privacy and security practices that we deem adequate.



Proportionality

We strive to collect no more Personal Data from you than is required by the purpose for which we collect it. This, in turn, helps reduce the total risk of harm should data loss or a breach in security occur: the less data we collect, the smaller the overall risk.


Storage of Your Personal Data

The data we collect from you may be stored, with risk-appropriate technical and organizational security measures applied to it, on in-house as well as third-party servers anywhere we or our trusted service providers and partners operate. 

In all cases, we follow generally accepted standards and security measures to protect the personal data submitted to us, both during transmission and once we receive it. 


Your Privacy Rights

You have the following rights regarding the processing of your Personal Data:

  • Right to information - Right to receive information about the processing of your Personal Data, prior to processing as well as during the processing, upon request.
  • Right of access - Aside from the information about the processing of your Personal Data, you have the right to receive a copy of your Personal Data undergoing processing.
  • Right to rectification - We should process accurate Personal Data; if you discover inaccuracy, you have the right to seek rectification of inaccurate Personal Data.
  • Right to erasure ("right to be forgotten") - You have the right to erasure of your Personal Data, but only in specific cases stipulated by law, e.g., if there is no legally recognized title on our part for further processing of your Personal Data 
  • Right to data portability - The right to receive Personal Data which you have provided and is being processed on the basis of consent or where it is necessary for the purpose of conclusion and performance of a contract, in machine-readable format. This right applies exclusively to Personal Data which processing is carried out by automated means.
  • Right to object - Applies to cases of processing carried out in legitimate interest. You have the right to object to such processing, on grounds relating to your particular situation, and we are required to assess the processing in order to ensure compliance with all legally binding rules and applicable regulations. In case of direct marketing, we shall cease processing Personal Data for such purposes after the objection.
  • Right to withdraw consent - In the case of processing based on your consent, you can withdraw your consent at any time, by using the same method (if technically possible) you used to provide it to us (the exact method will be described in more detail with each consent when you provide it). The withdrawal of consent shall not affect the lawfulness of processing based on your consent before its withdrawal.


  • Right to restriction of processing - You have the right to restriction of processing of your Personal Data if: You are contesting the accuracy of your Personal Data, for a period enabling us to verify the accuracy of your Personal Data; the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead; we no longer need the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; or you have objected to processing of your Personal Data, and there is a pending verification whether our legitimate grounds override your interests. 


  • Right to contact supervisory authority, court - You may contact and lodge a complaint with the supervisory authority –
  • The fulfillment of data subject rights listed above will depend on the category of Personal Data and the processing activity. In all cases, we strive to fulfill your request.

We will action your request within one month of receiving a request from you concerning any one of your rights as a Data Subject. Should we be inundated with requests or particularly complicated requests, the time limit may be extended to a maximum of another two months. If we fail to meet these deadlines, we would, of course, prefer that you contact us to resolve the situation informally.

Where requests we receive are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or (b) refuse to act on the request.

Your Choices in products

You can make certain choices about how your data is used by us by adjusting the privacy settings of the relevant product. Please check your product settings to set your privacy preferences there.


Categories of collected personal information 

You can see all categories of collected personal information listed in the section Personal Data We Process.

Sources from which the personal information is collected

You can find information about the sources of data in the section Personal Data We Process.

Business or commercial purpose for collecting or selling personal information

You can find all purposes of processing your personal information listed in the section Why We Process Your Personal Data.

Categories of third parties with whom the business shares personal information

You can find all categories of recipients of personal information listed in the section How We Diclose Your Personal Data. ACT does not and will not sell (as such term is defined in the EU General Data Protection Regulation (GDPR)) your personal information we collect without providing a right to opt out or your direct permission. See more about your right to opt out of sale below.

Our products are not targeted at minors under 16 years of age. We therefore have no knowledge of any sale of data concerning them.

Your Rights

You have the right to:

  • know what personal information is being collected about you; 
  • know whether your personal information is sold or disclosed and to whom; 
  • say no to the sale of personal information (right to opt out);
  • request deletion of your personal information; information will be deleted if no exception applies (including our right to defend our lawful interests);
  • access your personal information; specific information shall be provided in a portable and, to the extent technically feasible, in a readily useable format but not more than twice in a 12-month period; 
  • equal service and price, even if you exercise your privacy rights (right to non-discrimination).



Right To Opt Out Of Sale

If your personal information is subject to a sale you have the right to opt out from that sale. 


We will respect your decision to opt out for at least 12 months before asking you again to authorize the sale of your personal information.


Request Submission

You can submit your requests using contacts indicated below in the Contact Us section. If you are a Turkish resident under the age of 18, you may be permitted to request the removal of certain content that you have posted on our websites. We will verify your request by matching your email address and, if necessary, other information you provide in your request against the email address and other information we have in our system. You can also designate an authorized agent to exercise these rights on your behalf. We may require that you provide the authorized agent with written permission to act on your behalf and that the authorized agent verify their identity directly with us.


Contact Us

To exercise any of your rights, or if you have any other questions or complaints about our use of your Personal Data and its privacy, write our Privacy Team through the most convenient channel below: [email protected]


Data Protection Officer

As required under the GDPR, we have a data protection officer (DPO) to monitor our compliance with the GDPR, provide advice where requested and cooperate with supervisory authorities. You can contact our data protection officer via; [email protected]


Changes to this Privacy Policy

We reserve the right to revise or modify this Privacy Policy. In addition, we may update this Privacy Policy to reflect changes to our data practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.



FEELINHEALTHY

RIGHT TO ERASURE  REQUEST FORM


You are entitled to request us to erase any personal data we hold about you under EU General Data Protection Regulation (GDPR).

We will do our best to respond promptly and in any event within one month of the following:

  • Our receipt of your written request; or
  • Our receipt of any further information we may ask you to provide to enable us to comply with your request, whichever happens to be later.

The information you supply in this form will only be used for the purposes of identifying the personal data you are requesting that we erase and responding to your request. You are not obliged to complete this form to make a request, but doing so will make it easier for us to process your request quickly.

SECTION 1: Details of the person requesting information

Full name:

Address:
Contact telephone number:

Email address:

SECTION 2: Are you the data subject?

Please tick the appropriate box and read the instructions which follow it.

YES: I am the data subject. I enclose proof of my identity (see below). (Please go to Section 4)
 NO: I am acting on behalf of the data subject. I have enclosed the data subject’s written authority and proof of the data subject’s identity and my own identity (see below). (Please go to Section 3)

To ensure we are erasing data of the right person we require you to provide us with proof of your identity and of your address. Please supply us with a photocopy or scanned image (do not send the originals) of one or both of the following:

1) Proof of Identity

Passport, photo driver’s license, national identity card, birth certificate.

2) Proof of Address

Utility bill, bank statement, credit card statement (no more than 3 months old); current driver’s license;

If we are not satisfied you are who you claim to be, we reserve the right to refuse to grant your request.

SECTION 3: Details of the data subject (if different from section 1)

Full name:

Address:
Contact telephone number:

Email address:

SECTION 4: Reason for erasure request

Given the sensitive nature of erasing personal data, GDPR Article 17(1) requires certain conditions to be met before a request may be considered. Please supply us with the reason you wish your data to be erased and please attach any justifying documents to this one.

Please tick the appropriate box:

You feel your personal data is no longer necessary for the purposes for which we originally collected it.
 You no longer consent to our processing of your personal data.
 You object to our processing of your personal data as is your right under Article 21 of the GDPR.
 You feel your personal data has been unlawfully processed.
 You feel we are subject to a legal obligation of the EU or Member State that requires the erasure of your personal data.


 You are a child, you represent a child, or you were a child at the time of the data processing and you feel your personal data was used to offer you information society services.

SECTION 5: What information do you wish to erase?

Please describe the information you wish to erase. Please provide any relevant details you think will help us to identify the information. Providing the URL for each link you wish to be removed would be helpful.

Also, please explain, if it is not abundantly clear, why the linked page is about you or the person you are representing on this form.

Please note that. In certain circumstances, where erasure would adversely affect the freedom of expression, contradict a legal obligation, act against the public interest in the area of public health, act against the public interest in the area of scientific or historical research, or prohibit the establishment of a legal defense or exercise of other legal claims, we may not be able to erase the information you requested in accordance with article 17(3) of the GDPR. In such cases you will be informed promptly and given full reasons for that decision.

While in most cases we will be happy to erase the personal data you request, we nevertheless reserve the right, in accordance with Article 12(5) of the GDPR, to charge a fee or refuse the request if it is considered to be “manifestly unfounded or excessive.” However we will make every effort to provide you with the erasure of your personal data if suitable.

SECTION 6: Declaration

Please note that any attempt to mislead may result in prosecution.

I confirm that I have read and understood the terms of this subject access form and certify that the information given in this application to ______________ is true. I understand that it is necessary for ________________ to confirm my/the data subject’s identity and it may be necessary to obtain more detailed information in order to locate the correct personal data.

Signed: ………………………………………… Date: ……………..

Documents which must accompany this application:

  • Evidence of your identity (see section 2)
  • Evidence of the data subject’s identity (if different from above)
  • Authorization from the data subject to act on their behalf (if applicable)

Justification for erasure of data (see section 4)

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