Type of platform: Digital health tracking app and website
Effective date: 15th day of December, 2021
www.EmbraceHealthTracking.com and the Embrace Health Tracking app (the "Platform") are owned and operated by Embrace Health Tracking Inc. Embrace Health Tracking Inc is the data controller and can be contacted at: email@example.com.
The personal data we will collect;
Use of collected data;
Who has access to the data collected;
The rights of Site users; and
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.
We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.
By using our Platform users agree that they consent to:
When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.
You can withdraw your consent by: Deleting the application and discontinuing your membership.
Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.
We rely on the following legal basis to collect and process the personal data of users in the EU:
Users have provided their consent to the processing of their data for one or more specific purposes.
Personal Data We Collect
Data Collected Automatically
When you visit and use our Platform, we may automatically collect and store the following information:
Hardware and software details;
Content viewed; and
Other as deemed necessary to provide services.
Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Site:
First and last name;
Date of birth;
Auto fill data; and
This data may be collected using the following methods:
Creating or updating an account.
How We Use Personal Data
The data we collect automatically is used for the following purposes:
Statistics and improvements.
Provision of service
The data we collect when the user performs certain functions may be used for the following purposes:
Personalization of the app.
Who We Share Personal Data With
We will not sell or share your data with other third parties, except in the following cases:
If the law requires it;
If it is required for any legal proceeding;
To prove or protect our legal rights; and
To buyers or potential buyers of this company in the event that we seek to sell the company.
If you follow hyperlinks from our Platform to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.
How Long We Store Personal Data
User data will be stored for as long as deemed necessary.
How We Protect Your Personal Data
Unless users opt for enhanced levels of service requiring cloud storage, we do not store any health information whatsoever. Health information that users enter is stored on their personal devices unless they take intentional action. Any information that gets stored in the could through the intentional actions of members is encrypted and secured, if stored by Embrace Health Tracking.
While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.
International Data Transfers
We transfer user personal data to the following countries:
If you are located in the United Kingdom or the European Union, we will only transfer your personal data if:
The country your personal data is being transferred to has been deemed to have adequate data protection by the European Commission or, if you are in the United Kingdom, by the United Kingdom adequacy regulations; or
We have implemented appropriate safeguards in respect of the transfer. For example, the recipient is a party to binding corporate rules, or we have entered into standard EU or United Kingdom data protection contractual clauses with the recipient..
Your Rights as a User
Under the GDPR, you have the following rights:
Right to be informed;
Right of access;
Right to rectification;
Right to erasure;
Right to restrict processing;
Right to data portability; and
Right to object.
The minimum age to use our website is 16 years of age. We do not knowingly collect or use personal data submitted from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our privacy officer.
How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our privacy officer here:
Chief Executive Officer
Do Not Track Notice
Do Not Track ("DNT") is a privacy preference that you can set in certain web browsers. We do not track the users of our Platform over time and across third party websites and therefore do not respond to browser-initiated DNT signals.
A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.
We use the following types of cookies on our Site:
Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;
Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc;
Targeting cookies collect data on how you use the Site and your preferences. This allows us to personalize the information you see on our Site for you; and
Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:
Monitor user preferences to tailor advertisements around their interests.
Since, for most users, data is stored on their devices, deletion of the Embrace Health Tracking app will also cause deletion of all entered information. This information is not able to be retrieved because it is not stored on any server; only on the user's device.
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting firstname.lastname@example.org.
If you have any questions, concerns or complaints, you can contact our privacy officer, Chief Executive Officer, at:
www.EmbraceHealthTracking.com and the Embrace Health Tracking app (the "Platform")
Children's Data We Collect
We collect the following personal information about children:
health and personal information entered by the member (typically the parent).
We collect personal information from children using the following methods:
member enters the information (typically a parent).
Use of Children's Personal Information
We use the children's personal information we collect in the following ways:
to allow the member to record health information.
Children are not able to make their personal information publicly available on our Platform.
Disclosure to Third Parties
We do not disclose personal information we collect from children to third parties.
Third Party Operators
Third parties do not use our Platform to collect personal information about children who use our Platform.
A child's parent or guardian can review their child's personal information, direct us to delete their child's personal information, and refuse any further collection or use of their child's personal information. A parent or guardian can also agree to the collection and use of their child's personal information but not allow us to disclose that personal information to third parties, unless disclosure is part of the service provided by our Platform. A parent or guardian can exercise these rights via the following method(s):
Parents can access and delete their child's personal information by opening our app on their smartphone and by deleting records or the entire account.
We will not require a child to disclose more information than is reasonably necessary to participate in an activity on our Platform.