INLIVO PRIVACY POLICY
Last Updated: 5/16/2018
This Privacy Policy explains how Inlivo BG JSC (“Inlivo”, “we” or “us”) processes personal data about you when you browse our website (www.inlivo.com), use our mobile application and/or otherwise provide your personal data to us (hereinafter collectively, the “Services”).
Please read this Privacy Policy, our Terms and Conditions and Cookie Policy (together referred to as “Terms”) carefully before accessing or using the Services.
Inlivo is committed to protecting your privacy. By installing our mobile application or accessing our Services, you accept the terms and conditions of this Privacy Policy and the processing of your personal data. If you do not wish to be bound by these terms and conditions, you may not access or use the Services and you should immediately end such use.
Personal data controller
Responsible for the processing of your personal data is:
COMPANY NAME: Inlivo BG AD
CORPORATE IDENTITY NO: 202 621 591
ADDRESS
13A Ivan Drasov Strreet,
Varna, Bulgaria
E-MAIL: contact@inlivo.com
Scope
This Privacy Policy is effective with respect to any data that we have collected, or collect, about and/or from you, according to our Terms.
Collection of Your Information
Among the personal data we may collect from you: first and last name, date of birth and gender, country of residence, weight, height, device identifier, IP address you use to access and use our Services. We automatically store information related to your use of the Services. We also log the products you view and other actions you perform while using the Services. We use this type of information to administer the Services and provide the highest possible level of service to you. We also use this information in the aggregate to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the Services. We may also, depending on your use of the Services, collect personal data about your diet, health condition requirements and nutritional intake and overall lifestyle. In an ongoing effort to improve our Services, additional personal data may be collected from you. In such case, we will notify you when the personal data collection takes place.
If you connect to the Services using a Third-Party Application (e.g., Apple HealthKit, Facebook) Inlivo will collect and use your personal information from such Third Party Applications such as your username, name, profile picture, country, hometown, email address, date of birth, gender as well as such health data that you choose to synchronize with Inlivo’s Services.
Some of the data mentioned above, collected from you and processed by Inlivo for certain features of the Services, is possible for us to delete and cease processing for the future if you so require, without you having to terminate your use of the entire Services, i.e., not all data (submitted over time by you to us either directly or through third-party services) is required for you to still be able to use the Services. If you want us to cease processing certain data about you under this category, we will inform about the consequences of such cease, i.e., how it will affect your use of the features of the Services.
Email: If you register to the Services or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply. When you post messages or comments on our blog or forum of our Services, the information contained in your posting will be stored on our or our service provider’s servers.
Collection by Third Parties: If you post content (“Public Content”) for public view on the Services, we may distribute such Public Content to a wider audience by sharing it (or portions of it) with third parties so that they can publish it on their own websites and media platforms.
Social Media (Features) and Widgets: Our Services includes Social Media Features (“Social Media Features”), such as the Facebook Like button, the Twitter Follow button and the Pinterest Pin button. The Social Media Features may collect your IP address, which page you are visiting on our Site and Services, and may set a cookie to enable the Social Media Features to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.
Web beacons: We use web beacons on our website and in our emails. When we send emails to users, we may track behavior such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our features for specific segments of users. To do this, we include single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details.
Our Use of Your Personal Data
Your privacy is important to us and we will only process your personal data in accordance with this Privacy Policy. We may use your personal data for the purposes of providing, improving and to further develop the Services, analyzing usage of the Services, providing customer support, marketing by Inlivo or our selected business partners that help us to provide these services. In case you do not want Inlivo to use your personal data for the purpose of direct marketing, you may at any time opt-out from receiving any further messages by clicking the "unsubscribe" link at the bottom of such a message.
Inlivo analyzes the usage of the Services, in order to provide you as a user with the most relevant features of the Services as possible with regard to your personal goals. In analyzing the usage of the Services, Inlivo will process certain data for so-called personalizing. Personalizing means processing of your and other users’ personal data to analyze or predict aspects of your use of the Services, nutrition & physical status, behavior and, standing in reaching your health goal. The purposes of the Personalizing is to find out ways to make the Service more effective by better matching your individual objectives, usage patterns, preferences and goals.
The personalizing of your data can also be used as the basis for marketing towards other new potential customers on other platforms than the Inlivo Services, such as other social media platforms. Please note that this so called look-a-like-process of recruiting new customers does not mean that you will receive any marketing. Nor does it mean that any other third parties will gain access to your data for any other purpose than for Inlivo to reach new customers, i.e. third party providers (for example social media) will only process your data on behalf of Inlivo as processors, see further under transfer of data below.
Inlivo’s processing of your personal data for personalizing purposes as described above, does not require any consent as a legal ground to be processed. If this should be the case, i.e. if, under relevant personal data regulation, consent is required for the use as described above, you hereby give your consent to Inlivo using your personal data as defined above for personalizing, for the purpose of improving the Services and for providing better customer support.
Marketing - Data processing based on consent as the legal ground
You hereby consent to Inlivo using all your personal data for personalizing and marketing purposes via emails, notifications, or other messages, by Inlivo or Inlivo’s selected business partners. Personalizing will be used for marketing purposes to enable personalized and relevant offers to you, based on your preferences, see more above under Personalizing.
Marketing will only be sent to you by Inlivo; no personal data will be transferred to third parties for marketing purposes (other than possibly to service providers on assignment by Inlivo, however these providers do not have any rights to use the data for any other purposes than to what they have been assigned to, on behalf of Inlivo).
Opt-out from marketing
In case you do not want Inlivo to use your personal data for the purpose of marketing, you may at any time opt-out from receiving any further messages by clicking the "unsubscribe" link at the bottom of such a message, or by using such opt-out features as are available in the app settings in the Services.
Cookies
Please note that our website www.Inlivo.com uses cookies in order to function properly. If your internet browser is set and configured to accept cookies, you consent to the use of cookies. A cookie is a small text file that is stored on a user's computer for record-keeping purposes such as site visitation. We send cookies to your computer in order to uniquely identify your browser and improve the quality of our service. If you do not accept cookies, you can prevent cookies from being saved on your computer by changing the settings of your web browser. You can also delete cookies which have been previously stored. In such cases, please refer to the help section of your internet browser. If you choose not to accept cookies, you can still use our Services but their functionality may be somewhat limited. Our cookies are linked to your information, such as your nickname, email address and password. We enable some of our business partners to use cookies in conjunction with your use of the Site (for example Google Analytics). We have no access to or control over the use of these cookies. These cookies collect information about your use of the Site, such as which web site you came from, which pages you visited within the Site, and possibly other sites you visit if those sites cooperate with the same third party.
Data Retention
We will retain your information for as long as your account is active or as long as needed to provide you with our Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Terms.
Rectification of personal data
You have the right to request access to and rectification or erasure of your personal data processed by Inlivo. If a request for rectification concerns data that is necessary for Inlivo to offer the Services, such requests will have the effect that your account will be terminated at Inlivo. If you wish to exercise this right, please contact us at contact@inlivo.com. An application shall be made in writing and must be signed by you. Alternatively, you can also rectify your personal data by deleting your account via the Services.
Transfer of data
Personal data collected from you may be shared with third-party providers of Inlivo that process personal data on behalf of Inlivo; such as server hosting providers, data storage providers, companies carrying out system and sales performance monitoring, customer support systems- and payment service providers. These service providers will be considered processors of your personal data.
At times, some of your personal data by may be transferred and processed to processors, as described above, that are established in the United States or other countries (some of which will be outside the EEA). Inlivo will always apply safeguards to protect your personal data from unauthorized disclosure. We may also transfer your personal data in the event that our business (or part of it) is sold, for instance as part of a merger or acquisition. In case of transfer of data to third parties that are outside of the EU or EEA and that do not offer an adequate level of data protection, Inlivo will apply the EU Commission’s model clauses and/or binding corporate rules, or similar instruments/mechanism, for the safeguarding of integrity and security.
In no event does Inlivo transfer personal data to third parties with the right for such parties to use the data other than on behalf of Inlivo.
Inlivo may further disclose your personal data in order to comply with a legal or regulatory obligation, if we reasonably believe that this is required by law, regulation or other legislation, or in order to protect and defend Inlivo, our business partners or users’ rights and interests, subject always to relevant applicable personal data regulation.
Portability
You have the right to receive your personal data which you have provided to Inlivo, in accordance with relevant personal data regulation, provided that such request does not adversely affect the rights and freedoms of others.
Security
The security and integrity of your personal data is important to us. Therefore, we use generally accepted industry standards, technologies and procedures, such as firewalls, security software etc., in order to protect the integrity of your personal data and to prevent any unauthorized access. However, no system can be 100% secure and despite our efforts, there is always a risk of unauthorized access to your personal data. By using our Services, you assume this risk. We also urge you to use a unique and strong password to your user account on the Inlivo services as well as to protect such password. You should further limit access to your computer and browser and log out after having used the Inlivo Services.
Individuals Under the Age of 18
We do not knowingly collect any personal data from individuals under the age of 18 and our Services do not target children and anyone under 18. If you are under 18, please do not submit any personal data through our Services. Further, we encourage parents and legal guardians to monitor their children's Internet use and to help us in enforcing our Privacy Policy by instructing their children to never provide any personal data through our Service without their permission. If you become aware that a child under the age of 18 has submitted personal data to us, please contact us and we will do our best to delete that account from our database.
Modifications
From time to time, it may become necessary to make changes to this Privacy Policy. Therefore, we reserve the right to update and/or modify this Privacy Policy at any time by giving notice to you. Please review this Privacy Policy frequently, and especially before you register an account with us. The date of the last modification is listed at the top of this Privacy Policy.
Healthkit
Inlivo has Apple’s Healthkit integration to track the following PHR (Personal Health Record) Data; heart rate, steps taken, calories and distance. For clarification PHR data is web-based Personal Health Record information. This data is passed through to Healthkit for the purpose of providing real time metric feedback to the user about their workouts, general wellbeing and training program. The data that we collect is classified as Personal Data and Statistical Data.
For Clarification purposes;
- Personal Data is any PHR Data that connects to you as an individual such as names, health conditions, and other identifiers.
- Statistical Data is PHR Data that is 1) grouped so it does not connect to you as an individual and 2) has names and other identifiers removed or altered.
We DO NOT release this data to any person, company or other entity for any reason, including but not limited to;
- Marketing and Advertising
- Medical and pharmaceutical research
- Reporting about our company and or customer activity
- Your insurer and employer
- Developing software applications
Your Personal Data is only collected by us from your direct use with the Inlivo app, and if you granted both our app and Apple’s HealthKit permission. If you close or transfer your profile with us, we no longer collect any PHR data.
We have security measures that are reasonable and appropriate to protect personal information, such as PHR Data, in any form, from unauthorized access, disclosure, or use of the Healthkit.
For any clarification around our use, collection, or storage of this data, or if you wish to stop sharing your data, please email us at contact@inlivo.com
Who is Inlivo’s Data Protection Officer?
Pressian Dochev is Inlivo’s Chief Privacy Officer, and has been designated as Inlivo’s Data Protection Officer for GDPR purposes. As Inlivo’s Chief Privacy Officer, Mr. Dochev is responsible for implementing the company’s “privacy by design” program, and ensuring that the company maintains state-of-the-art privacy and data security to protect customer and consumer information.
Complaints
If you have any questions or complaints about our processing of your personal data, you are welcome to contact us at contact@inlivo.com. You also have the right to lodge a complaint with a supervisory authority.
Contact
We will communicate with you by email and notices posted in your mobile device. If you do not wish to receive notices in your mobile device, you can always turn off this service. Please be aware that if you unsubscribe from our mailing list you will still be receiving answers to your questions sent to our support but you will not be receiving promotional emails.
We welcome your feedback regarding our Services. If you would like to: access, correct, amend or delete any personal information we have about you or want more information simply contact our Privacy Compliance Officer at contact@inlivo.com.
