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Privacy Policy

Privacy Policy for embracehealthtracking.com and the Embrace Health Tracking app

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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: info@embracehealthtracking.com.
 

Purpose


The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Platform of the following:

  1. The personal data we will collect;

  2. Use of collected data;

  3. Who has access to the data collected;

  4. The rights of Site users; and

  5. The Site's cookie policy.

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This Privacy Policy applies in addition to the terms and conditions of our Platform.

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GDPR


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.

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Consent


By using our Platform users agree that they consent to:

  1. The conditions set out in this Privacy Policy.

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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.

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You can withdraw your consent by: Deleting the application and discontinuing your membership.

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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:

  1. Users have provided their consent to the processing of their data for one or more specific purposes.

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Personal Data We Collect


We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

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Data Collected Automatically


When you visit and use our Platform, we may automatically collect and store the following information:

  1. IP address;

  2. Location;

  3. Hardware and software details;

  4. Clicked links;

  5. Content viewed; and

  6. Other as deemed necessary to provide services.

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Data Collected in a Non-Automatic Way


We may also collect the following data when you perform certain functions on our Site:

  1. First and last name;

  2. Age;

  3. Date of birth;

  4. Sex;

  5. Email address;

  6. Phone number;

  7. Address;

  8. Payment information;

  9. Auto fill data; and

  10. Picture.

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This data may be collected using the following methods:

  1. Creating or updating an account.

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How We Use Personal Data


Data collected on our Platform will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Platform. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect automatically is used for the following purposes:

  1. Statistics and improvements.

  2. Provision of service

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The data we collect when the user performs certain functions may be used for the following purposes:

  1. Communication; and

  2. Personalization of the app.

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Who We Share Personal Data With


Employees
We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

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Other Disclosures


We will not sell or share your data with other third parties, except in the following cases:

  1. If the law requires it;

  2. If it is required for any legal proceeding;

  3. To prove or protect our legal rights; and

  4. To buyers or potential buyers of this company in the event that we seek to sell the company.

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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.

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How Long We Store Personal Data


User data will be stored for as long as deemed necessary.

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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.

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International Data Transfers


We transfer user personal data to the following countries:

  1. Canada

  2. United States of America

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When we transfer user personal data we will protect that data as described in this Privacy Policy and comply with applicable legal requirements for transferring personal data internationally.

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If you are located in the United Kingdom or the European Union, we will only transfer your personal data if:

  1. 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

  2. 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..

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Your Rights as a User


Under the GDPR, you have the following rights:

  1. Right to be informed;

  2. Right of access;

  3. Right to rectification;

  4. Right to erasure;

  5. Right to restrict processing;

  6. Right to data portability; and

  7. Right to object.

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Children


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.

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Please see our Children's Privacy Policy for additional information on how we deal with children's personal data.

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
info@embracehealthtracking.com

 

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.

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Cookie Policy


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.

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We use the following types of cookies on our Site:

  1. Functional cookies
    Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;

  2. Analytical cookies
    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;

  3. Targeting cookies
    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

  4. Third-Party Cookies
    Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:

    1. Monitor user preferences to tailor advertisements around their interests.

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Additional Clauses


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.
 

Modifications


This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates.

Complaints


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 info@embracehealthtracking.com.

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Contact Information


If you have any questions, concerns or complaints, you can contact our privacy officer, Chief Executive Officer, at:

info@embracehealthtracking.com

 

Children's Privacy Policy


www.EmbraceHealthTracking.com and the Embrace Health Tracking app (the "Platform")

This Children's Privacy Policy supplements the Platform’s Privacy Policy and applies to the personal information of children in the United States who are under the age of thirteen (13) ("child" or "children"). This Children's Privacy Policy is made in accordance with the United States Children's Online Privacy Protection Act ("COPPA"). Any terms defined in COPPA have the same meaning when used in this Children's Privacy Policy.

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Children's Data We Collect


We collect the following personal information about children:

  1. health and personal information entered by the member (typically the parent).

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Collection Methods


We collect personal information from children using the following methods:

  1. member enters the information (typically a parent).

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Use of Children's Personal Information


We use the children's personal information we collect in the following ways:

  1. to allow the member to record health information.

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Public Availability


Children are not able to make their personal information publicly available on our Platform.

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Disclosure to Third Parties


We do not disclose personal information we collect from children to third parties.

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Third Party Operators


Third parties do not use our Platform to collect personal information about children who use our Platform.

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Parental Rights


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):

  1. 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.

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We will not require a child to disclose more information than is reasonably necessary to participate in an activity on our Platform.

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Contact Information


Questions and concerns about this Children's Privacy Policy or about our collection and use of children's personal information, can be sent to Chief Executive Officer: info@embracehealthtracking.com
 

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