HEALEVATE BV
PRIVACY POLICY
Last Updated: October 2, 2024
1) INTRODUCTION AND SCOPE
We at Healevate BV, (“HEALEVATE”) understand that your privacy is important to you, and are committed to being transparent about the information we collect and process upon your use of our Site. This Privacy Policy describes our practices concerning the personal information collected, processed, and stored by HEALEVATE when you visit and use this website.
Florida Based Business. HEALEVATE operates the Site from The Netherlands and, regardless of your place of residence or access location, your use of the Site is governed by the laws of the Netherlands. Users who access or use the Site from other locations consent to the transfer and processing of their data in the Netherlands and any other jurisdiction throughout the world. This Privacy Policy is provided in English. Translations to certain other languages may be available and can be requested by contacting us at the address below.
User Consent and Age Requirement. By using the Site, you consent to our collection and use of your information as described in this Privacy Policy. Our Site is intended for general audiences over the age of 16 years old. We do not knowingly collect information from children under the age of 16 years old. IF YOU ARE NOT AT LEAST 13 YEARS OLD IN THE UNITED STATES OR 16 YEARS OLD IN OTHER COUNTRIES, DO NOT USE THE SERVICES.
2) Information We Collect, How We Use It, and How and Why We Share It
This section will serve as the notice at collection as provided in Section 1798.100(b) of the California Consumer Privacy Act.
Access to content on our Site does not require you to create an account. You can visit and use our Site without providing us any identification (e.g., name, date of birth), contact (e.g., email address, phone number) and/or account (username and password) information.
The list below describes what data we collect that qualifies as “Personal Information” in California or “Personal Data” in the European Economic Area, how we collect or access it, how we use it, with which third parties we share it, and the purpose for sharing. In addition, we may collect, use, and disclose your personal information as required or permitted by applicable law, as directed by you, or in accordance with this Privacy Policy.
We only permit third parties to process your personal data for specified purposes and in accordance with our agreements with them. Our service providers with whom we share your data may also engage vendors to help them process user data, so they can provide their services to us.
(a) Your IP address
(i) How we collect it
We automatically collect the IP address you use each time you visit our Site. We get this information from your browser when it interacts with our servers. We log these IP addresses in our user visit logs.
(ii) How we use it
This is to determine what country or state or province you are in to show you relevant content and ads. This is also to analyze fraudulent traffic patterns. We also analyze which regions of the world our users come from so we can develop content offerings for these regions.
(iii) Who we share it with
We share IP address, and your Site activities tied to your Unique ID with vendors who help us operate our Site by providing the following services:
- Site hosting and database warehousing;
- Content delivery from our servers to your device;
- Advertising inventory management and operations;
- Service features and functionalities such as video players, browser notifications, social media sharing, subscribing to email newsletters, or posting comments;
- Business and technical performance analytics;
- Security; and
Your data may also incidentally be shared with vendors for IT support, data backup and recovery service, and office software.
(iv) Purpose for sharing
- These vendors process our user's personal information to:
- Provide their services to us and determine what amounts are owed to them based on traffic volumes or other metrics;
- Logging page impressions and user actions for their business analytics;
- Detecting and addressing fraudulent behavior or illegal activity on their service;
- Monitoring the proper functioning of their services, quality assurance, finding errors, and fixing them;
- Internal research; and
- Improving their products and services.
(b) A unique ID assigned to your browser
(i) How we collect it
We attribute a unique ID to your browser. We store this information in a cookie set on your browser.
Every time you visit the Site with the same browser, we recognize you as the same visitor through your Browser ID. If you use a different device or a different browser, you will be identified as a different user with a different Browser ID.
(ii) How we use it
This is only so we can count unique users and repeat users for our Site. We can determine the type of content that encourages users to come back to the Site.
We do not use your unique ID to assign you to an “interest segment” for marketing or advertising, nor to target ads to you based on the content you viewed or pages that you clicked on and visited.
(c) Your activities on our Site
All of your actions on our Site with the same browser (your visits, URL of the webpage you were last visiting before clicking on our Site, pages viewed, duration of visit) are tied to the Browser ID of that browser for the Site.
This is to count clicks, page views, repeat visits, time on site, and other metrics so we can determine the content, web page layouts, or user interfaces that are the most popular, or that generate the most revenue.
This is also to determine payments owed to content and advertising partners, as well as to marketing agencies.
(d) Other technical information
As you interact with the Site, we may collect additional technical information via automated means:
1. Information about your computer or mobile device such as type of device, mobile device ID number, screen resolution, web browser information, and operating system or platform
2. Your browser preferences and settings (time zone, language, etc.)
This information is also tied to your Browser ID. This is to present you with content in your preferred language and present our Site pages in a format that best fits your device screen and format.
The list below describes what data may be automatically collected by third parties when you visit our Site via code that we implement to our Site to allow them to access your browser. In certain cases these third parties are co-controllers of personal data with us. We only permit such third parties to collect and process your personal data in accordance with our agreements with them.
(a) IP address and cookie data collected by social media platforms
(i) How third parties collect it
Social media features that we implement in the Site (like the Facebook “Like” or “Share” button) may allow the social media providers to collect your IP address and the URL of the page of the Site you are on when you use the feature. The sharing features may also set a social media service cookie to your browser.
(ii) Which Partners collect it
Social Media Platforms
(iii) How they use it
Your interactions with these features are governed by the privacy policy of the social sharing platform that you agreed to upon creating your account with them.
(b) IP address collected by third parties and third-party cookies
(i) How third parties collect it
We implement on our Site certain code provided by our advertising partners that enable them to:
1. Collect the IP address that you use when you visit our Site
2. Place or recognize a cookie on your browser or other tracking device (for example, tied to your mobile device ID).
3. This happens when we implement software code on our Site pages that allows our partners to interact with your browser, such as a pixel or beacon.
(ii) Which Partners collect it
1. Content partners who provide content or search-targeted or contextually targeted ads on our Site.
2. Agencies who place ads on third-party Site to promote our Site.
3. Publisher networks (such as Facebook or Google) on which we or our agencies place advertisements to promote our Site
(iii) How they use it
This is so they can:
1. Provide their services to us
2. Determine payments owed to them
3. Analyze fraudulent traffic patterns
4. Detect and fix errors in their service
5. Internal research and improving their service, including to increase their revenues
(c) Internet usage data collected via cookies
(i) How third parties collect it
Certain partners use cookies or tracking devices that enable them to:
1. Recognize your browser or mobile device when you visit our Site and other Site
2. Collect information about your internet usage, including your visits to and actions on our Site
Such information collection and use by third parties via cookies and tracking devices only occurs with your consent where required (such as in the European Economic Area). It may qualify as a “sale” of personal information under the California Consumer Privacy Act.
(ii) Which Partners collect it
Advertisers and digital advertising technology intermediaries who place interest-based advertisements on our Site.
(iii) How they use it
They use tracking devices to place ads on our Site targeted to you based on your past actions on our Site or on other sites (interest-based targeting)
We, along with third parties who provide us with products and services, may also place cookies, ad tags, and/or beacons that collect the information outlined above in order to provide us with products and services including analytics tools (e.g., Google Analytics) allowing us to analyze the performance of our Services and advertisers and ad networks allowing the delivery of targeted advertisements. These third parties may also collect information about you from other sources and combine it with other information collected about you from third-party sites not affiliated with us. For example, advertiser and advertising networks, as well as data analytics companies who service them, may participate in interest-based advertising and track your activity across various sites and/or devices where they display ads and record your activities, so they can show ads that they consider relevant to you. Where necessary, we will obtain your consent for these activities.
When you visit or enter your email address (either to log in, to sign up for a newsletter, or otherwise) on our website, we may share personal data or other information that we collect from you, such as your email (in hashed, pseudonymous form), IP address, and/or information about your browser or operating system with ID5 and its group companies, acting as controllers. ID5 uses this information to create an ID for the purpose of recognising you on your devices. This ID does not contain any of your identifiable personal data. We may place this ID in our first-party cookie or use an ID5 cookie and allow it to be used for online and cross-channel advertising. This ID may be shared by us or on our behalf with our advertising partners and other third-party advertising companies globally for the purpose of enabling interest-based content and/or targeted advertising throughout your online experience (e.g. web, email, connected devices, in-app, etc). Detailed information on ID5's data processing activities in connection with this ID and ID5’s opt-out is available in ID5’s platform privacy policy here: https://id5.io/platform-privacy-policy.You have the right to withdraw your consent or opt-out to the processing of your personal data at any time.
To prevent your data from being used by Google Analytics, you can download and install the Google Analytics opt-out browser add-on. The Google Analytics opt-out add-on is designed to be compatible with Chrome, Internet Explorer 11, Safari, Firefox, and Opera. In order to function, the opt-out add-on must be able to load and execute properly on your browser. For Internet Explorer, 3rd-party cookies must be enabled. Learn more about the opt-out and how to properly install the browser add-on here.
3) More Details On Information Collected, Purpose of and Basis for Collection
Technical information. As you interact with the Site, we may collect additional technical information via automated means:
1. Information about your computer or mobile device such as type of device, mobile device ID number, screen resolution, web browser information, and operating system or platform
2. Your browser preferences and settings (time zone, language, etc.)
3. Internet provider or mobile service provider name
This information is also tied to your Browser ID.
Aggregated user information. We routinely aggregate the personal information of all of our users into user usage statistics for our Site. With this aggregation, your personal data is mixed with other user data and becomes de-identified. We are not able to identify or re-identify you or any particular user. We do not treat de-identified data or aggregate consumer information as personal information and we reserve the right to convert, or permit others to convert, your personal information into de-identified data or aggregate consumer information. Sharing de-identified aggregate data with third parties does not constitute a sale or transfer of personal information.
Legal basis for collection. We collect and use your personal information on the grounds of the legal basis described below:
1. Provide our services: we process your personal information to provide our content services. This is so we can comply with our contractual obligations to you.
2. Improving our services: we analyze information about how you use our Site to provide an improved experience for our users, including product testing and site analytics. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with our Site and improve them.
3. Compensating our partners: we process your personal information for purposes of calculating compensation to be paid to our third-party product/service providers and distributors and to analyze usage across products, services, and distribution partners/channels. It is in our legitimate interest to appropriately determine amounts to be paid to our partners and inform our product roadmap and distribution strategy.
4. Communicating with you: we may use your personal information when we communicate with you, for example, if we are providing information about changes to the terms and conditions or if you contact us with questions. It is in our legitimate interests that we are able to provide you with appropriate responses and provide you with notices about our Site and services.
5. Marketing: we may use your personal information to deliver relevant advertisements to you to promote our Site, and measure the effectiveness of our marketing campaigns. It is in our legitimate interest to analyze the interests of our users to craft more relevant advertising messages and inform our marketing strategy. We may use automated decision-making to deliver tailored advertisements based on your personal information. In most cases, we use cookies and trackers placed on your browsers by our marketing network partners.
6. Exercising our rights: we may use your personal information to exercise our legal rights where it is necessary to do so; for example, to detect, prevent, and respond to fraud claims, intellectual property infringement claims, or violations of law or our Terms of Service.
7. Complying with our obligations: we may process your personal information to, for example, carry out fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law, such as responding to your request for data access or deletion.
8. Customizing your experience, including ads: when you use the Site, we may use information about your use of the Site (queries you submitted, content you viewed) to customize your experience, such as by providing personalized elements and showing you content based on your recent interests. We may use automated decision-making for these activities. Upon your affirmative consent or request, we may use your browser information to send you notifications about content on our site via your browser. As required by applicable data protection and privacy laws, we will obtain your consent for these activities or enable you to opt out of these activities.
Third-party links. The Site includes many links to third-party sites, services, widgets, ads, and other services. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party sites and are not responsible for their privacy practices.
4) Additional information about Sharing with Third Parties
In addition to the sharing described in the chart above, we share your information with third parties for the purposes described below:
Fraud prevention: we may disclose your information to third parties when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.
Law enforcement purposes and public safety: if requested or required by government authorities, such as law enforcement authorities, courts, or regulators, or otherwise to comply with the law, we may disclose any information we have about our users. We may disclose information collected about you in order to exercise or protect legal rights or defend against legal claims. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Sale or merger of our business: we may transfer your information to a third party if we or any of our affiliates are involved in a corporate restructuring (e.g., a sale, merger, or other transfer of assets).
5) Your Opt-Out Rights and Choices
You have rights and choices regarding our collection and use of your personal information, as well as the collection and use of some of our third-party partners.
Removing our cookie. If you remove our Browser ID cookie from your browser cache, we will no longer recognize your browser and activities until a new cookie is placed. Any future site activities you perform, after you delete this cookie, will not be tied to your previous activities that were associated with the removed cookie.
Removing Interest-based advertising cookies. You can opt out of third-party interest-based, advertising-related cookies, pixel tags, and web beacons, to prevent our advertising partners from delivering targeted interest-based ads to you. You can choose to opt out through these (and other) resources:
- Network Advertising Initiative (http://www.networkadvertising.org/)
- Digital Advertising Alliance (http://www.aboutads.info/consumers)
- Your Online Choices (http://www.youronlinechoices.com/)
You will continue to see advertisements on our Site, but they will not be tailored to you based on any past behavior on our Site or other sites. You may, however, still receive customized content and/or ads based on the content of the pages you are visiting.
Removing Interest-based advertising from Mobile Tracking Devices. You may opt out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at https://youradchoices.com/appchoices
Other Privacy Tools. In addition, third-party tools enable you to search for and opt out of some of these devices, such as the Ghostery browser plug-in available at https://www.ghostery.com/.
Do Not Track. Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
For California users: Opt out of sharing for interest-based Advertising (“Do Not Sell”).
There is no industry consensus on whether enabling third parties to collect personal data via cookies for interest-based targeting is a “sale” under the California Consumer Privacy Act. We however want to give you choices regarding third parties using cookies or tracking devices to collect information about your internet usage while you visit our Site, as we did in section 2 of the above chart.
Some browsers have signals that may be characterized as Do Not Sell signals, but we do not understand them to operate in that manner or to indicate a Do Not Sell expression by you, so we currently do not recognize these as a Do Not Sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.
If you do not wish for our advertising partners to collect your personal information for interest-based advertising purposes, exercise your Opt-Out right by contacting us at the address given at the bottom of this page. We manage Opt Out requests on a per-browser basis, using your Browser ID cookie. This means that we need access to your browser, and therefore cannot process any Opt Out request from a third party acting as your agent.
6) Your Access, Revision & Deletion Rights
Right to know/right of access
If you are located in the European Economic Area (EEA) or in California, or in certain other states, you have specific rights to know and have access to the personal information that has been collected and stored by the web properties that you visit (and in the EEA, right to correct such information). Your rights can only be exercised if such web properties can adequately verify that you are the same person as the user whose data is being requested. We do not collect sufficient data to authenticate any particular user. As indicated in section 2 above, we only recognize a unique browser based on the Browser ID we assign to that browser. A Browser ID could therefore correspond to multiple individuals. Since the personal information we collect related to a Browser ID is not sufficient to verify that the corresponding browser belongs to the person making the request, we are not able to provide any information in response to any request to know or access specific personal information about a user. This is to prevent anyone from using your browser to obtain your search or browsing history. We want to make sure your search and browsing history does not fall into the wrong hands.
However, upon your request, and provided you are able to provide to us your Browser ID, then we may provide you with the following information collected within the last 12 months:
- Which categories of personal information we have collected about you (based on your Browser ID or other information you have provided to us), and how we collected that information, as well as the business or commercial purposes for our collecting such personal information.
- A list of the categories of personal information shared with third parties for a business purpose and the categories of third parties to whom we have shared your personal information.
- A list of categories of personal information that may have been collected by third parties when you visited our Site, and the categories of third parties who may have collected such information.
Information relating to your Browser ID is retained by us for various time periods, so we may not be able to provide information for the full 12 months preceding your request.
Right to delete
If you are located in the European Economic Area (EEA) or in California, or in certain other states, you have specific rights to request us to delete any personal information we have stored about you. In the EEA, you also have the right to withdraw any consent that you have previously provided to us to store or use your personal information. As indicated above, since all personal information we have is tied to your Browser ID, we are only able to delete your personal information from our databases if you can provide to us that Browser ID. You can also request deletion of certain other information that is not tied to your Browser ID as further described below.
Process to submit a right to know/right of access or right to delete request
To request us to access personal information categories or delete personal information we have collected with respect to your Browser ID, please contact us at the address at the bottom of this page, and provide us with the following necessary information:
1. Click on the Browser ID button below to get your Browser ID and copy your Browser ID to a safe place so you can later send it to us. Remember that this Browser ID is unique to this website.
2. Provide your Browser ID number
3. Provide a written and signed statement confirming that:
- You are a resident of California, or a country in the EEA (please indicate which country), or another state where the laws provide you similar rights (please indicate which state)
- You are the rightful owner of the browser that corresponds to the Browser ID you are providing; and
- You are the sole user of that browser and no other individual has used the browser
4. Clarify whether you are requesting us to (a) delete all of the personal information tied to your Browser ID, or (b) send you information on the categories of personal data we have collected and shared that are tied to your Browser ID.
5. To assist us in processing your request in a timely manner, please make your request in English if you are able to do so.
We manage requests to delete or access personal information on a per Browser ID basis, which is the only way we have of recognizing or authenticating a user. This means that we need access to your browser when you click on the Browser ID button above and will process your request based on that Browser ID. We therefore cannot process any request from a third party acting as your agent.
All requests for access or deletion will be reviewed by our legal and compliance team and we reserve the right, in compliance with applicable laws, to accept or reject, or make further inquiries regarding, any requests. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request if it is excessive, repetitive, unfounded, or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we charge you for responding to your request.
7) International Transfers
If you are visiting our Site from the European Economic Area (the “EEA”) your information may be transferred to, stored, and processed in a country that is not regarded as providing the same level of protection for personal information as the laws of your home country, and may be available to the government of those countries under a lawful order made in those countries. Whenever we transfer your personal data out of the EEA, we ensure it receives a similar degree of protection.
8) Non Discrimination, Complaints and Disputes
All content and services offered on the Site are free of charge and we will not discriminate against any user who has exercised their rights as set forth in this privacy policy. We strive to resolve complaints about your privacy and our collection or use of your personal information, and are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your state of residence. Healevate LLC is further subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
9) Data Retention and Security
We have designed our Browser ID system so that we can manage our Site while collecting as little information about our users as possible. We retain the information tied to your Browser ID for as long as necessary to fulfill the purpose we collected it for and for the purpose of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information we process, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, accounting, or reporting requirements.
We take the security of your information seriously and use appropriate technical and organizational measures to protect your information against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also limit access to information about you to employees who reasonably need access to it to provide products or services to you, or in order to do their jobs. However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we may have collected from or about you.
10) Updates to this Privacy Policy and Contact Information
We will continue to evaluate this Privacy Policy against new technologies, applicable laws, business practices, and our user’s needs, and may make changes accordingly. Please check this page periodically for updates. If we make any material changes, we will post the updated Privacy Policy on this page, along with its effective date, and notify you by means of a notice on the Site. Except in connection with updates that materially change the ways in which we process your information, your continued use of the Services after this Privacy Policy has been updated means that you agree to be bound by such updates. We will provide notice in advance of the effective date with regard to any updates that materially change the ways in which we process your personal information.
If you have any questions or concerns about this Privacy Policy or the manner in which your information is processed (or if you are an EEA resident, how your data is transferred outside of the EEA), or if you would like to submit a request to us, please contact us via mail at:
Healevate BV