Privacy policy
This Privacy Notice is to inform you, as a user of the Femia app and/or related website https://femia.health (further the “App” and the “Website” respectively, together “we/us“, the “Product“), on the processing of your personal data in connection with the use of the Product.
When we say “personal data” or “personal information”, we are referring to information related to you. Such information is not limited to what directly identifies you, such as your name. In fact, you own and have legal rights to anything that speaks of you: the data you enter about your menstruation, sex life, pregnancy journey, your aim for using the Product, even the way you use the Product itself. To avoid legalese, we can also use “your data” or “your information” in the same meaning.
This notice is meant to provide you with all relevant information to make an informed choice to use the Product. It also serves to inform you of your rights and how you can exercise them. Contact us if you have any questions or concerns.
Please note that the Product is intended for users who have reached the minimum legal age. Therefore, we expect you will not use the Product unless you are at least 16 or older, or if you are a U.S. citizen, at least 13 or older.
This Notice was written in English. to the extent a translated version of the Notice conflicts with the English version, the English version prevails.
1. Who We Are
In order to provide you with our Product, we have launched it as a Website and as an App.
While we aim to make the transition between the two as seamless as possible, you should know that the Website and the App are operated by two different legal entities. This Privacy Notice describes how each of these legal entities handles the data received from you or received from the other entity, in the event that you switch from the Website to the App or vice versa, or use only the App or only the Website.
You can read further below if you wish to learn which entity handles your data and when.
- If you choose to use only the App, the data controller for your data is Magicfit Limited, with its registered address at Karaiskaki 13, 3032, Limassol, Cyprus.
- For the Website, the controller responsible for processing is Actitech Limited, with its registered address at Karaiskaki 13, 3032, Limassol, Cyprus.
- For instances where you go to the Website, access to the App via the Website, and further continue using the App, i.e. where you basically use both the App and the Website, Magicfit Limited and Actitech Limited act as joint controllers. Joint controllership is a legal term describing a relationship between companies where both companies coordinate and jointly decide and share responsibility with respect to your data, to ensure smooth interplay between the App and the Website and that your privacy rights are complied with at all times.
You may contact either Magicfit Limited or Actitech Limited interchangeably should you wish to assert your privacy rights, obtain any additional information with regard to your data, or for formal arrangements between the joint controllers via these contact points.
2. Contact Us
Should you have any general questions about this Privacy Notice, the use of your data by us, or if you want to assert your data protection rights, please use the following interchangeable contact options:
- if relating to your use of the App: [email protected]
- if relating to your use of the Website: [email protected]
You may also contact our Data Protection Officer – at [email protected].
Please note that in some cases, for your safety and when we have reasonable concerns about the authenticity of a request, we may need to authenticate you before proceeding with your request.
3. Your Privacy Rights and How to Exercise Them
You are entitled to data-related rights as described below. You may assert them directly via the Product (to the extent possible) or via the contact options.
Please note that these rights are based on European laws, namely the General Data Protection Regulation (the “GDPR“). Depending on your country of residence, those rights may have different interpretations. Should you wish to assert your country-specific rights, kindly let us know, and we will review your case individually.
Right to access
You may ask to confirm whether we process your data and if so, to provide you with the scope of such processing and a copy of the data concerning you stored by us.
Right to rectification
You have the right to request correction of inaccurate personal data concerning you and the completion of incomplete data. We try to allow you to correct/add data through the Product’s settings to the extent possible, e.g. you can log in to your user profile and correct, amend, or delete information about yourself. We will also inform third parties to whom we transferred your data in the event of rectification of your data.
Right to erasure (Right to be forgotten)
You may request the erasure of your personal data stored by us. Please note, however, that the right to erasure is not absolute and shall be fulfilled by us only provided specific legal requirements are met. You may request data erasure only if:
- your personal data is no longer necessary for the purposes for which it was initially collected,
- you have withdrawn your consent to personal data processing, and the consent was the sole legal basis for the processing,
- you have successfully objected to the processing based on a balancing of interests relating to your particular situation,
- your personal data has been unlawfully processed,
- your personal data has to be erased for compliance with a legal obligation, or
- you are an underage person and used our Product by mistake.
Further, your right to erasure is subject to restrictions. For example, we are not under obligation or even allowed to delete data that we are still obligated to retain due to statutory retention periods. Similarly, data that we need for the establishment, exercise, or defense of legal claims is excluded from your right to erasure.
If we have transferred personal data to third parties, we will either initiate the deletion of your data from such third parties or inform them about the erasure, insofar as required by applicable law.
In order to avoid any unnecessary legalese and keeping in mind the general use of such words, we will interpret all user requests asking us to “delete my data” as requests for erasure of data under Article 17 GDPR.
Right to restriction of processing
You have the right to request, under certain conditions, restriction of processing (i.e. the marking of stored personal data to restrict its future use). The requirements for restriction of processing are as follows:
- The accuracy of your personal data is contested, and we must verify the accuracy of your data;
- The processing is unlawful but you do not want your personal data to be erased, and instead you request restriction of use of your personal data;
- We no longer need your personal data for the purposes of processing, but you need the data for the establishment, exercise, or defense of legal claims;
- You have objected to data processing, and we are verifying whether our legitimate interests override yours.
Right to objection
You have the right to object to the processing of your personal data in whole or in part at any time, and in any form, in the event that our processing is based on a legitimate interest (balancing of interests). In order to process your objection, we kindly request you to refer to your particular situation as to why you believe that your rights and freedoms are at a particular risk (see Article 21 of GDPR for more details).
Please note that the right to objection is not absolute, and we will stop the processing of your data only provided we cannot demonstrate compelling legitimate grounds for processing.
Where the processing you object against concerns direct marketing purposes, we will stop any processing once we receive an objection from you. A common example of how you can exercise an objection to marketing communications is pressing the “unsubscribe” button in emails.
Right to data portability
You have the right to receive the data you provided to us in a commonly used and machine-readable format to transfer that data to another controller without our interference.
To the extent possible, we will allow you to export data for further use directly via the App. You may also ask us to assist you with moving your data where it is technically feasible. Please note that this option relates only to data processed based on the performance of our contract with you or based on your consent. For more information about the contract and consent, please refer to Section 5 below.
Right to withdraw consent
Right to lodge a complaint
You can lodge a complaint with the data protection authority at any time if you believe that your data has been processed unlawfully. Here is the contact information for the supervisory data protection authority:
Data Protection Commissioner, 1 Iasonos Street, 1082 Nicosia, Cyprus, tel: +357 22818456, fax: +357 22304565, email: [email protected]
3.1. California Privacy Rights
In this Section, you can find a description of your privacy rights as a California resident, which are established under California laws, such as the California Consumer Privacy Act (the “CCPA“).
Please note that in this Section 3.1, we describe California-specific rights that substantially differ from those established under the GDPR. These rights are in addition to those established under the GDPR described above in Section 3 for California residents.
You may assert these rights directly via the Product (to the extent possible) or via the contact options.
Access to specific information and data portability rights
Generally, your right to request data access and data portability are described above in Section 3 under the titles “Right to access” and “Right to rectification“, respectively. The scopes of these rights differ slightly under the CCPA.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months only. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
If we sold or disclosed your personal information for a business purpose, we will disclose such facts separately.
Please note that you may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of such person.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Right to request deletion of data
Generally, your right to request erasure is described above in Section 3 under the name “Right to erasure (Right to be forgotten)“.
Despite the fact that the right to request deletion of data under the CCPA and the right to erasure under the GDPR are essentially the same, please note that under the CCPA we are under no obligation to comply with your request if we need to maintain your information for certain reasons. For your convenience, you may find below an abridged version of such exceptions. To learn more, please refer to the full text of the CCPA or the additional clarifications from the California Attorney General.
Under the CCPA, we may retain your personal information if we need it to, among other things:
- Complete the transaction for which the personal information was collected, or fulfill the terms of a written warranty or product recall.
- Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Comply with the California Electronic Communications Privacy Act.
- Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
- Comply with a legal obligation.
- Otherwise use the personal information internally in a lawful manner that is compatible with the context in which the consumer provided the information, etc.
Right to non-discrimination
Right to request information on data transfer for third party’s direct marketing purposes
Right to prohibit sale of information
4. Personal Data We Collect
Your user journey may vary depending on whether it is the App or the Website (or both) you have chosen to use. Similarly, the scope and peculiarities of data processing will vary:
- if you access the Product through the Website, both Website Data Collection and App Data Collection will apply;
- if you access the Website only, Website Data Collection will apply;
- if you accessed the App via an application store, only App Data Collection will apply.
Data you provide
| Data Category | Website Data Collection | App Data Collection |
|---|---|---|
| GENERAL INFORMATION | When you start using the Website, or in the course of Website use, we collect the following personal data:
| When you start using the App, or in the course of App use, we collect the following personal data:
If you accessed the App from the Website, we may use the information already collected on the Website for the App. |
| HEALTH & WELLNESS ONBOARDING INFORMATION | To tailor your Product experience to your needs, we may ask you to answer some questions about your health and wellness experience. Such Health & Wellness Onboarding Information may include your goal for Product use (i.e. intention to get pregnant or to track your menstruation), menstrual cycle regularity, period and cycle duration, health issues, pregnancy-related details etc. If you do not provide us with Health & Wellness Onboarding Information, we will not be able to create a personalized experience for you. | |
| HEALTH & WELLNESS IN-APP INFORMATION | N/A | During your use of the App or its certain features, you may insert information in relation to your health and wellness, such as menstrual cycle dates, symptoms; contraception; sex life; pregnancy. Should you wish not to provide us with Health & Wellness in-App Information, please do not use respective in-App features. |
| PAYMENT DATA | To make a purchase via the Website, you need to enter your payment information, such as bank card credentials, payment service (e.g. PayPal) credentials, etc. We may or may not have access to such payment information depending on the service provider processing your payment. Payment providers, such as PayPal, Stripe, and Braintree, act independently; we receive limited information from them allowing us to recognize and record your subscription status, such as the date, time, and amount of the transaction, the type of payment method used, the payment transaction identification number, and the last four digits of the bank card. Our one-stop shop payment provider acts on our behalf; it collects and otherwise processes your payment data, including bank card credentials, IP address, email, and name, on our behalf. In practice, it shares with us only limited details regarding your payment, such as the date, time, and amount of the transaction, so our employees/contractors cannot view your payment credentials. | N/A |
| CUSTOMER SUPPORT AND OTHER COMMUNICATIONS INFORMATION | When you contact us for customer support or otherwise communicate with us, you may provide us with information related to your use of the Product, additional contact information, payment information, identification documents, or other information you may find helpful to resolve your query. We also collect information on the feedback you provide on the customer support experience. | |
| YOUR USER CHOICES | We collect:
| We collect:
|
| FEEDBACK INFORMATION | We will collect and process your feedback should you communicate it to us. | Our App contains a feature via which you can provide us with feedback, rate our application, and/or engage in deeper discussions. We will collect and analyze the data you submit to make our Product better. We will also collect and process feedback should you communicate it to us in any other way. |
Automatically collected data
| Data Category | Website Data Collection | App Data Collection |
|---|---|---|
| USAGE INFORMATION | We collect information about your activity on our Website, like frequency of use, areas and features that you access, visit, or use. | We collect information about your activity on our App, such as:
|
| DEVICE-RELATED INFORMATION | When you install, access, or use the Website, we collect device-related information. This includes IP address, user agent, hardware model, operating system information, browser information, language and time zone, etc. Device-related information also includes approximate location information. | When you install, access, or use the App, we collect device-related information. This includes IP address, user agent, hardware model, operating system information, App version, browser information, mobile network, language and time zone, device identifiers, including Android Advertising Identifier (GAID)/Apple ID for Advertisers (IDFA), etc. Device-related information also includes approximate location information. |
| SUBSCRIPTION STATUS | N/A | By exchanging information with your application store, we understand and record your subscription status. |
| LOG AND TROUBLESHOOTING INFORMATION | We collect some troubleshooting, bug, and crash reporting information from you to help determine problems with the Product. We also collect and write logs to be able to access historical data for internal and external investigations. | |
Information third parties provide about you
| Data Category | Website Data Collection | App Data Collection |
|---|---|---|
| ADVERTISING NETWORKS INFORMATION | Advertising networks provide us with insights on which channels (e.g. social networks) and which particular ad campaigns helped you reach the Product. | |
| SOCIAL LOGIN INFORMATION | N/A | We provide you with the option to register using a social media account, like your Facebook or Google social media account or to log in via Apple. If you allow access to such data, we receive information about your respective accounts, such as your name and email address. The exact scope of information provided is always displayed on the social login screen presented to you by the relevant provider during the login process. We do not use your Facebook, Google, or Apple login details in any way other than allowing you to access the App and we cannot post anything to your Facebook or Google profile and/or affect your Apple account. |
Cookies and Similar Technologies
Please refer to Section 6 for more information on cookies and similar technologies.
5. How and Why We Use Your Data. Legal Bases for Processing
All processing of your data must be lawful, i.e. reliant upon one of the lawful bases referenced under applicable law, namely:
- Performance of a contract with you, i.e. provision of the Product as described in our Terms of Use,
- Your consent, i.e. when you provide consent to the processing of particular personal information,
- Our legitimate interests, i.e. when we believe that we can use and/or share your data since we have a legitimate balanced reason to do so,
- Performance of our obligations under the applicable law.
Below you can see described the purposes of our processing (why we process your information) for each lawful basis and the corresponding data categories used in each case.
As mentioned earlier, your user journey may vary depending on whether it is the App or the Website (or both) you have chosen to use. However, the purposes and legal bases for data processing in relation to the Website and the App coincide.
Performance of a contract with you
| Why and how we process your information | Data Used |
|---|---|
| To ensure the intended operation of the Product, namely, to maintain your profile in the Product, ensure you have easy access to it, and provide you with the functionality of the Product provided for in the Product descriptions as well as included materials. | |
| For billing purposes, account management, and feature accessibility. |
Your consent
| Why and how we process your information | Data Used |
|---|---|
| For Product functionality, i.e. to provide health and wellness Product functionality to you, e.g. keep the information you insert available to you; calculate and provide periods, ovulation, and fertility predictions; accompany you in your pregnancy journey. | |
| For Product improvement, i.e. to deliver a better user experience concerning health and wellness, including developing new health and wellness features and implementing more efficient algorithms/recommendation mechanisms. For example, we try to understand what features are most important for you and why to add more relevant content or change recommendations. | |
| To use your device identifiers, such as Android Advertising Identifier (GAID)/Apple ID for Advertisers (IDFA), IP address, or email in course of assessing our advertising campaigns effectiveness (e.g. which advertisements led you to the Product and whether you finally used the Product or purchased it/some of its features). | General Information(in a limited scope – email address) |
Our legitimate interest
| Why and how we process your information | Substantiation of Legitimate Interest | Data used |
|---|---|---|
To analyze the performance of our Product, improve it, and further deliver a better user experience based on analysis of your interaction with the Product. For example:
| Our interest is to measure the use of our Product and count the people who interact with it. Such actions are aimed at improving Product development and enabling the provision of accurate and reliable internal reporting. | Log and Troubleshooting Information Payment Data (the fact of purchase)/Subscription Status |
| To assess the effectiveness of our advertising campaigns by understanding which advertisements led you to the Product and whether you finally used the Product or purchased it/some of its features. | It is our interest to understand who may be interested in our Product and to offer our Product to new potentially interested audiences as well as remind old users about it. | General Information (in a limited scope – country) Payment Data (the fact of purchase)/Subscription Status |
To communicate with you in various ways, e.g.:
You can opt out of any of our promotional communications anytime as described in your privacy rights section. | We believe the provision of presumably relevant information will be a plus in addition to the provision of the Product functionality. | |
To provide customer support/ request processing to the customer support team. This includes, for example:
| It is in our interest to assist our users with any inquiries or requests. | |
To defend ourselves from prospective legal claims, litigation, or other disputes, including in relation to violations of the Terms of Use, Privacy Notice, Subscription Policy, and/or Refund Policy. To ensure the safety, security, and integrity of the Product. To provide information to the authorities upon request. | It is in our interest to respond to complaints and prevent and address fraud, unauthorized use of the Product, violations of our Terms of Use and/or other policies, or other harmful or illegal activity. It is in our interest to seek legal advice and protect ourselves (including our rights, personnel, property, or products), and our users or others, including as part of investigations or regulatory inquiries and litigation or other disputes. | |
| To identify disruptions and maintain Product security, including the detection and tracking of inadmissible access attempts and access to our servers. | It is in our interest to eliminate disruptions, maintain system security, and detect and track inadmissible access and access attempts. |
Performance of our obligations under the law
| Why and how we process your information | Data used |
|---|---|
According to applicable tax and accounting laws, we may need to report your payments to conduct any necessary statutory reports/withdrawals. Further, sometimes in order to comply with applicable laws, we need to authenticate you, i.e. collect your identification information. Finally, according to applicable law, we need to understand whether you allow the processing of your data, push notifications, marketing communications, and similar activities. To provide information to authorities upon request. |
Automated processing of your data
6. Cookies and Similar Technologies, Your Choices
Cookies (“Cookies” or “Cookie”) are small text files that are placed on your device while you browse our Website. They help us remember/recognize some of your actions or choices during Website use for various purposes. Sometimes, they help us track you through websites and devices to understand the effectiveness of our ads.
We use similar technologies (“Similar Technologies”) which are technically different but serve the same purpose of remembering/recognizing your actions during App or Website use. Similar Technologies include:
- Pixels/Web beacons/Tags – code snippets added to our Website, for example, to create a tiny graphic. We usually use pixels that are dependent on cookies so your Cookie choices may limit the performance of pixels.
- Local storage – a property that allows us to save information in your web browser with no expiration date (even after the browser window is closed).
Who sets Cookies or Similar Technologies on our Website
There are two main types of Cookies and Similar Technologies that we can set:
- First-party Cookies and Similar Technologies: these Cookies and Similar Technologies are placed and read by us directly;
- Third-party Cookies: these Cookies are not set by us, but by our partners, like payment service providers (e.g., PayPal or Braintree) or advertising networks.
We recommend checking Section 7 of this Privacy Notice to understand with whom we cooperate while using Cookies and Similar Technologies.
Why and how we use Cookies and Similar Technologies
We use Cookies and Similar Technologies for a number of reasons, such as:
- protecting your account,
- saving your onboarding experience so that you can return to exactly where you left off,
- analyzing Website performance,
- advertising our Products,
- assessing advertising campaign effectiveness, and
- generally trying to make your experience with us better.
The Cookies and Similar Technologies we use generally fall into one of the following categories, whereas each category description allows us to understand why those Cookies and Similar Technologies are necessary.
Strictly Necessary Cookies and Similar Technologies
These Cookies and Similar Technologies are necessary for the Website to function and cannot be switched off in our systems.
They are set out in response to actions you make, mainly in order to remember your choices, including cookie preferences, onboarding completion status and values, and login data.
If you block strictly necessary Cookies, some parts of the Website will not work.
Show the Strictly Necessary Cookies list/Hide the Strictly Necessary Cookies list ↓
| Cookie | Purpose | Domain | Type | Duration |
|---|---|---|---|---|
| OptanonAlertBoxClosed | This Cookie is set by the Cookie compliance solution from OneTrust. It allows for the remembering of your Cookie preferences. | femia.io | First-party | 365 days |
| OptanonConsent | This Cookie is set by the Cookie compliance solution from OneTrust. It stores information about the categories of Cookies the site uses and whether the user has given or withdrawn consent for the use of each category. | femia.io | First-party | 365 days |
| sc_f | This Cookie is set via the PayPal payment widget which is embedded on the checkout page on our Website. | .c.paypal.com | Third-party | 1825 days |
| ts_c | This Cookie is set via PayPal payment widget to prevent fraud. | .c.paypal.com | Third-party | 3 years |
| l7_az | This Cookie is necessary for the PayPal login function on the website. | .c.paypal.com | Third-party | 20 days |
| LANG | This Cookie is set by PayPal to save language preferences. | .c.paypal.com | Third-party | 365 days |
| ts | This Cookie is set by PayPal to support general payment functionality. | .c.paypal.com | Third-party | 3 years |
| KHcl0EuY7AKSMgfvHl7J5E7hPtK | This Cookie is set by PayPal to support general payment functionality. | .c.paypal.com | Third-party | 20 years |
| tsrce | This Cookie is set by PayPal to support general payment functionality. | .c.paypal.com | Third-party | 3 days |
| x-pp-s | This Cookie is set by PayPal to support general payment functionality. | .c.paypal.com | Third-party | Session (deleted once browser closed) |
Performance (Analytics) Cookies
These Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us know which pages are the most and least popular and see how the user moves across the Website.
Show the Performance (Analytics) Cookies list/Hide the Performance (Analytics) Cookies list ↓
| Cookie | Purpose | Domain | Type | Duration |
|---|---|---|---|---|
| _ga | Google Analytics Cookie used to identify unique users. | femia.io | First-party | 2 years |
| _gid | Used by Google Analytics to distinguish users. | femia.io | First-party | 90 days |
Targeting (Tracking) Cookies and Similar Technologies
We and our service providers (advertising networks) use Cookies and Similar Technologies to direct our ads to you through targeted advertisements for our Product on other sites you visit and to measure your engagement with those ads.
These Cookies and Similar Technologies may be used by those advertising networks to build a profile of your interests and show you relevant ads on other sites.
Show the Targeting (Tracking) Cookies list/Hide the Targeting (Tracking) Cookies list ↓
| Cookie | Purpose | Domain | Type | Duration |
|---|---|---|---|---|
| _pinterest_ct_ | Cookie placed by Pinterest when it is unable to match the user. | .ct.pinterest.com | Third-party | 365 days |
| _pin_unauth | Cookie placed by the Pinterest tag when Pinterest is unable to match the user. | femia.io | First-party | 364 Days |
| _scid | Snapchat Cookie that sets a unique ID for the Website user. | femia.io | First-party | 365 Days |
| X-AB | This Cookie is used by us along with Snapchat in the context of multi-variable testing. | sc-static.net | Third-party | 1 day |
| _fbp | Used by Facebook to deliver a series of advertisement products such as real-time bidding from third-party advertisers. | femia.io | First-party | 3 month |
| _gat_gtag_xxxxxxxxxxxxxxxxxxxxxxxxxxx | Used by Google Analytics to store a unique user ID. | femia.io | First-party | <24 hours |
| _tt_enable_cookie, _ttp | TikTok Cookies that collect data about behavior and purchases on our Website to measure the effect of our advertising. | femia.io | First-party | 13 month |
| _ttp | TikTok uses this Cookie to measure and improve the performance of our advertising campaigns and to personalize the user’s experience (including ads) on TikTok. | .tiktok.com | Third-party | 13 month |
| sc_at | Used by Snapchat to identify a visitor across multiple domains. | snapchat.com | Third-party | 1 hour |
| muc_ads | Twitter Cookie that сollects data on user behavior and interaction in order to make advertisements on the website more relevant. | .t.co | Third-party | 2 years |
| personalization_id | This Cookie is set by Twitter for advertising and to identify and track the website visitor. | .twitter.com | Third-party | 2 years |
Your Cookie choices
Most browsers allow you to manage how Cookies are set and used as you’re browsing, and to clear Cookies and browsing data. Typically, such information can be found under the browser’s ‘Help’, ‘Preferences’, or ‘Options’ menus. Also, your browser may have settings allowing you to manage Cookies on a site-by-site basis as well as provide for incognito mode.
- Cookie settings in Chrome
- Cookie settings in Firefox
- Cookie settings in Safari – iOS
- Cookie settings in Safari – macOS
- Cookie settings in Opera
Should you wish to change your previously provided to us Cookie-related choices, please use the button below.
[Cookie choices button]
Your Similar Technologies choices
Opt out of Personalized Advertising
You can visit the below sites to opt out of personalized advertising in general, including regarding our Website:
- Digital Advertising Alliance (DAA);
- European Interactive Digital Advertising Alliance (EDAA)
- Australian Digital Advertising Alliance (ADAA)
- Network Advertising Initiative (NAI)
You can also opt out of advertising provided by particular networks both in the App and on the Website:
- Google Ad Settings/Ad Personalisation
- Facebook Ad Settings
- Instagram Opt-Out Instruction
- Tik-Tok Opt-Out Instruction
- Twitter Opt-Out Instruction
- Pinterest Opt-Out Instruction
- Outbrain opt out on desktop and mobile web (Section 3 -> Outbrain User Types, including Opt Out Options)
- Taboola Access to Data and Opt-Out Tool.
Please note that if you opt out of personalized advertising, you will still see advertisements – they will just not be tailored to your interests. Also note that deleting browser Cookies may remove the Cookie preferences you already made, so you may need to opt out again in the future.
Finally, you can exercise your preferences and opt out of personalized advertisements with regard to your mobile devices (smartphones, tablets) by:
- updating your mobile device settings:
- IOS devices: Settings -> Privacy -> Tracking -> Allow Apps to Request to Track (uncheck);
- Android Devices -> Settings -> Google -> Ads -> Opt Out of Ads Personalization;
- downloading the Digital Advertising Alliance’s AppChoices app and configuring it to opt out of particular advertising solutions.
Do Not Track
7. Personal Data Transfers
7.1. Data Transfers by Both the Website and the App
A number of Product functions rely upon services from third parties, so-called ‘processors’. Processors act based on and in accordance with our requests and shall not use your data for their own purposes.
The main service providers the Product shares your data with are as follows:
- Amazon Web Services
We use Amazon Web Services, which is a hosting and backend service provided by Amazon, for personal data hosting and enabling our Product to operate and be distributed to its users.
- AppsFlyer
Appsflyer helps us understand, in particular, how users find our Product (for example, which advertiser delivered an ad that led you to our Product). Appsflyer also provides us with different analytics tools that enable us to research, analyze, and make your use of the Product better.
- Front
In order to provide you with swift and smooth customer support, we use Front – software that allows us to optimize conversations between users and customer support agents. In this regard, Front receives and stores copies of all data related to your customer support requests, such as emails, purchase details, feedback, etc.
- Customer support agents
- People and companies providing us with professional app development and maintenance services
7.2. Merchants of Record and Agents
While Welltech Apps Limited is the data controller responsible for your data during your use of the Product, it’s important to note that in some locations we engage our authorized third-party merchants of record or agents to distribute a Product via a Website. This is done to make the Product available to customers worldwide smoothly and seamlessly.
Below is a list of our authorized merchants of record and agents and their roles with regard to your data:
- Solidgate LLC (3753 Howard Hughes Parkway, Suite 200-778, Las Vegas, NV, 89169-0300).
Solidgate resells the Website, meaning it enters into a contract and accepts payments, for a part of our US users. Solidgate is a separate entity bearing individual responsibility for handling your data and acting as a controller within the meaning of data protection law. For more information on how Solidgate handles your data, please refer to their privacy policy at https://solidgate.com/privacy-policy/.
- Welltika Content Provider DMCC (Detached Retail I5, Jumeirah Lakes Towers, Dubai, United Arab Emirates)
Welltika is one of our agents acting exclusively on our behalf to present the Website to you and accept payments. Welltika is a data processor acting upon our instructions.
- Actitech Limited (Karaiskaki 13, 3032, Limassol, Cyprus)
Actitech Limited is one of our agents acting exclusively on our behalf to present the Website to you and accept payments. Actitech Limited is a data processor acting upon our instructions.
Advertising networks
We use the services of third-party advertising platforms, for example, Instagram, Facebook, and Snapchat, which allows us to show targeted campaigns and messages to users within their platforms based on the user’s behaviour. To put it plainly, we provide information about you that will allow advertising platforms to locate you in their database and information that you performed a desirable action, such as making a purchase.
This allows an advertising network to understand which people are interested in our Product as well as to display advertisements of the Product to users who will most likely want it.
Please note that most advertising networks act as separate controllers or co-controllers of your data in full or in part, which means that such controllers decide whether to use the transferred data for their own purposes, e.g. providing you with advertisements of other providers similar to our Product. You can learn more about the data processing practices of such companies in their respective privacy policies:
- Facebook https://www.facebook.com/privacy/policy
- Instagram https://help.instagram.com/155833707900388
- Snapchat https://snap.com/en-US/privacy/privacy-policy
We do not share any health & wellness information with advertising networks.
Opt out of Personalized Advertising
Should you wish to opt out of personalized advertising, please explore the options described in Section 6 above.
Also, you can visit the below sites to opt out of personalized advertising in general:
- Digital Advertising Alliance (DAA);
- DEuropean Interactive Digital Advertising Alliance (EDAA)
- DAustralian Digital Advertising Alliance (ADAA)
- DNetwork Advertising Initiative (NAI)
Some advertising networks also allow direct opt-out:
- Google Ad Settings/Ad Personalisation
- Facebook Ad Settings
- Instagram Opt-Out Instruction
- Tik-Tok Opt-Out Instruction
- Twitter Opt-Out Instruction
- Pinterest Opt-Out Instruction
- Outbrain opt out on desktop and mobile web (Section 3 -> Outbrain User Types, including Opt Out Options)
- Taboola Access to Data and Opt-Out Tool
Please note that if you opt out of personalized advertising, you will still see advertisements – they will just not be tailored to your interests. Also note that deleting browser Cookies may remove the Cookie preferences you already made, so you may need to opt out again in the future.
Finally, you can exercise your preferences and opt out of personalized advertisements with regard to your mobile devices (smartphones, tablets) by:
- updating your mobile device settings:
– IOS devices: Settings -> Privacy -> Tracking -> Allow Apps to Request to Track (uncheck);
– Android Devices -> Settings -> Google -> Ads -> Opt Out of Ads Personalization; - downloading the Digital Advertising Alliance’s DAppChoices app and configuring it to opt out of particular advertising solutions.
Related companies
Public authorities and bodies
International data transfers
Please note that in the course of doing business, we transfer your personal data outside of EU/EEA countries. For example, some of our service providers are located in the United States of America.
We shall implement measures as established under applicable law to ensure data transfers are protected as required. When a recipient is located in one of the jurisdictions listed on the official website of the European Commission here, the appropriate safeguard is the corresponding adequacy decision of the Commission. Where no such adequacy decision is present, we rely on the so-called Standard Contractual Clauses (see more about them here), along with a thorough analysis of the law of the destination country to safeguard your data and your rights.
8. Retention of Your Personal Data
We keep your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless further retention is required under applicable law.
You can request to terminate your account and delete your data at any time. We treat such requests as a termination of your contract with us and as a revocation of your consent(s). We will accommodate such requests and terminate any data processing under respective legal bases.
Please note that certain data can be retained even after your deletion request. That may be the case where processing is based upon our legitimate interest. For example, we may keep information on purchases in order to protect our rights in a legal action. Such storage is not indefinite and is limited to such data’s usefulness and achieving our legitimate goals. As described in the Your Privacy Rights and How to Exercise Them section, you may object to our legitimate interests. If you wish to do so, please indicate this specifically in your message to us.
We may also keep data if deletion is not technically possible (for example, because your personal information has been stored in backup archives). We will securely store your personal information and isolate it from any further processing until deletion is possible.
The same applies to cases where we are obliged to retain your data under applicable law (e.g. accounting and tax laws). In the event of such retention, we will ensure via technical and organizational means that such data is not used for conflicting purposes, for example, advertising to you.
