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Privacy Policy

Last updated: April 25, 2024 Effective date: November 19, 2021

Privacy Policy For Data Controller and Mobile Application

Applicable To The Following Data Controller: Digital Health SRL Applicable To The Following Mobile Application: INTVL, Healthenly, Elysian Horizons Applicable To The Following Mobile Application: digitalhealth.ro, healthenly.com, elysianhorizons.com

Article 1 - Definitions

For the purposes of this Privacy Policy:

a) Applicable mobile application: This Privacy Policy will refer to and be applicable to the Mobile App listed above, which shall hereafter be referred to as “Mobile App”. b) Effective Date: “Effective Date” means the date the Privacy Policy comes into force and effect. c) Cookies: Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses. d) Parties: The parties of this privacy policy are the following data controller: Digital Health SRL (“Data Controller”) and you, as the user of this Mobile App. Hereinafter, the parties will individually be referred to as “Party” and collectively as “Parties”. e) Data Controller: Data Controller is the publisher, owner, and operator of the Mobile App and is the Partv responsible for the collertion of information described herein. Data Controler shall be referrer to either by Data Controller’s name or “Data Controller,” as listed above. If Data Controller or Data Controller’s property shall be referred to through first-person pronouns, it shall be through the use of the following: us, we, our, ours, etc. f) You: Should you agree to this privacy policy and continue to use the Mobile App, you will be referred to herein as either you, the user, or if any second-person pronouns are required and applicable, such pronouns as “your”, “yours”, etc. g) Personal Data: “Personal Data” means personal data and information that we obtain from you in connection with your use of the Mobile App that is capable of identifying you in any manner.

Article 2 - General Information

This privacy policy (hereinafter “Privacy Policy”) describes how we collect and use the Personal Data that we receive about you, as well as your rights in relation to that Personal Data, when you visit our Mobile App and interact with it in any way, including passively.

This Privacy Policy does not cover any information that we may receive about you through sources other than the use of our Mobile App. The Mobile App may link out to other websites or mobile applications, but this Privacy Policy does not and will not apply to any of those linked websites or applications.

We are committed to the protection of your privacy while you use our Mobile App.

By continuing to use our Mobile App, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your information and the method of disclosure as described in this Privacy Policy. If you do not understand the Privacy Policy or do not agree to it, then you agree to immediately cease your use of our Mobile App.

Article 3 - Contact and Data Protection Officer

The Party responsible for the processing of your personal data is as follows: Digital Health SRL. The Data Controller may be contacted as follows:

The Data Controller and operator of the Mobile App are one and the same.

The Data Protection Officer is as follows: Dinu Mihai. The Data Protection Officer may be contacted as follows:

Article 4 - Location

The location where the data processing activities take place is as follows:

  • Voluntari, Ilfov, Romania

Article 5 - Modifications and Revisions

We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner. If we do so, however, we will notify you and obtain your consent to the change in processing. Unless we specifically obtain your consent, any changes to the Privacy Policy will only impact the information collected on or after the date of the change. It is also your responsibility to periodically check this page for any such modification, revision or amendment.

Article 6 - The Personal Data We Receive From You

Depending on how you use our Mobile App, you will be subject to different types of Personal Data collected and different manners of collection:

a) Unregistered users: If you are a passive user of the Mobile App and do not register at all, you may still be subject to certain passive data collection (“Passive Data Collection”). Such Passive Data Collection may include through cookies, as described below, IP address information, location information, and certain browser data, such as history and/or session information. b) All users: The Passive Data Collection that applies to Unregistered users shall also apply to all other users and/or visitors of our Mobile App. c) Related Entities: We may share your Personal Data, including Personal Data that identifies you personally, with any of our parent companies, subsidiary companies, affiliates or other trusted related entities. However, we only share your Personal Data with a trusted related entity if that entity agrees to our privacy standards as set out in this Privacy Policy and to treat your Personal Data in the same manner that we do. d) Email Marketing: You may be asked to provide certain Personal Data, such as your name and email address, for the purpose of receiving email marketing communications. This information will only be obtained through your voluntary disclosure and you will be asked to affirmatively opt-in to email marketing communications. e) User Experience: From time to time we may request information from you to assist us in improving our Mobile App, such as demographic information or your particular preferences. f) Content Interaction: Our Mobile App may allow you to comment on the content that we provide or the content that other users provide, such as blogs, multimedia, or forum posts. If so, we may collect some Personal Data from you at that time, such as, but not limited to, username or email address. g) Combined or Aggregated Information: We may combine or aggregate some of your Personal Data in order to better serve you and to better enhance and update our Mobile App for your and other consumers’ use. We may also share such aggregated information with others, but only if that aggregated information does not contain any Personal Data. h) Other Information: In addition to collecting the Personal Data as already described herein, we may also collect the following Personal Data:

  • many other possible identifiers, device signals, network and connections information, data from device settings, or cookies may be collected.

Article 7 - The Personal Data We Receive Automatically:

Cookies: We may collect information from you through automatic tracking systems (such as information about your browsing preferences) as well as through information that you volunteer to us (such as information that you provide during a registration process or at other times while using the Mobile App, as described above).

For example, we use cookies to make your browsing experience easier and more intuitive: cookies are small strings of text used to store some information that may concern the user, his or her preferences or the device they are using to access the internet (such as a computer, tablet, or mobile phone). Cookies are mainly used to adapt the operation of the site to your expectations, offering a more personalized browsing experience and memorizing the choices you made previously.

A cookie consists of a reduced set of data transferred to your browser from a web server and it can only be read by the server that made the transfer. This is not executable code and does not transmit viruses.

Cookies do not record or store any Personal Data. If you want, you can prevent the use of cookies, but then you may not be able to use our Mobile App as we intend. To proceed without changing the options related to cookies, simply continue to use our Mobile App.

    Technical cookies: Technical cookies, which can also sometimes be called HTML cookies, are used for navigation and to facilitate your access to and use of the site. They are necessary for the transmission of communications on the network or to supply services requested by you. The use of technical cookies allows the safe and efficient use of the site.     You can manage or request the general deactivation or cancelation of cookies through your browser. If you do this though, please be advised this action might slow down or prevent access to some parts of the site.     Cookies may also be retransmitted by an analytics or statistics provider to collect aggregated information on the number of users and how they visit the Mobile App. These are also considered technical cookies when they operate as described.     Temporary session cookies are deleted automatically at the end of the browsing session - these are mostly used to identify you and ensure that you don’t have to log in each time - whereas permanent cookies remain active longer than just one particular session.     Third-party cookies: We may also utilize third-party cookies, which are cookies sent by a third-party to your computer. Permanent cookies are often third-party cookies. The majority of third-party cookies consist of tracking cookies used to identify online behavior, understand interests and then customize advertising for users.     Third-party analytical cookies may also be installed. They are sent from the domains of the aforementioned third parties external to the site. Third-party analytical cookies are used to detect information on user behavior on our Mobile App. This place anonymously, in order to monitor the performance and improve the usability of the site. Third-party profiling cookies are used to create profiles relating to users, in order to propose advertising in line with the choices expressed by the users themselves.     Profiling cookies: We may also use profiling cookies, which are those that create profiles related to the user and are used in order to send advertising to the user’s browser.     When these types of cookies are used, we will receive your explicit consent.     Support in configuring your browser: You can manage cookies through the settings of your browser on your device. However, deleting cookies from your browser may remove the preferences you have set for this Mobile App.     For further information and support, you can also visit the specific help page of the web browser you are using:

    Log Data: Like all websites and mobile applications, this Mobile App also makes use of log files that store automatic information collected during user visits. The different types of log data could be as follows:

  • internet protocol (IP) address;
  • type of browser and device parameters used to connect to the Mobile App;
  • name of the Internet Service Provider (ISP);
  • date and time of visit;
  • web page of origin of the user (referral) and exit;
  • possibly the number of clicks.

The aforementioned information is processed in an automated form and collected in an exclusively aggregated manner in order to verify the correct functioning of the site, and for security reasons. This information will be processed according to the legitimate interests of the Data Controller.

For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also possibly include Personal Data such as IP address, which could be used, in accordance with applicable laws, in order to block attempts at damage to the Mobile App or damage to other users, or in the case of harmful activities or crime. Such data are never used for the identification or profiling of the user, but only for the protection of the Mobile App and our users. Such information will be treated according to the legitimate interests of the Data Controller.

Article 8 - Third Parties:

We may utilize third-party service providers (“Third-Party Service Providers”), from time to time or all the time, to help us with our Mobile App, and to help serve you.     We may use Third-Party Service Providers to assist with information storage (such as cloud storage).     We may provide some of your Personal Data to Third-Party Service Providers in order to help us track usage data, such as referral websites, dates and times of page requests, etc. We use this information to understand patterns of usage of, and to improve, the Mobile App.     We may use Third-Party Service Providers to host the Mobile App. In this instance, the Third-Party Service Provider will have access to your Personal Data.     We may allow third parties to advertise on the Mobile App. These third parties may use cookies in connection with their advertisements (see the “Cookies” clause in this Privacy Policy).     We may use Third-Party Service Providers for the following services in relation to the Mobile App:

  • The Mobile App requests consent from users in the EU to display ads from Google or other Ad network providers.

    Some of our Third-Party Service Providers may be located outside of the United States and may not be subject to U.S. privacy laws. The countries or regions in which our Third-Party Service Providers may be located include:

  • EU, UK, Australia

We only share your Personal Data with a Third-Party Service Provider if that provider agrees to our privacy standards as set out in this Privacy Policy.

Your Personal Data will not be sold or otherwise transferred to other third parties without your approval.

Notwithstanding the other provisions of this Privacy Policy, we may provide your Personal Data to a third party or to third parties in order to protect the rights, property or safety, of us, our customers or third parties, or as otherwise required by law.

We will not knowingly share your Personal Data with any third parties other than in accordance with this Privacy Policy.

If your Personal Data might be provided to a third party in a manner that is other than as explained in this Privacy Policy, you will be notified. You will also have the opportunity to request that we not share that information.

In general, you may request that we do not share your Personal Data with third parties. Please contact us via email, if so. Please be advised that you may lose access to certain services that we rely on third-party providers for.

Article 9 - How Personal Data Is Stored:

We use secure physical and digital systems to store your Personal Data when appropriate. We ensure that your Personal Data is protected against unauthorized access, disclosure, or destruction.

Please note, however, that no system involving the transmission of information via the internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your Personal Data very seriously. We take all reasonable steps to protect your Personal Data.

The systems that we use to store your information include but are not limited to:

  • Any personal information is treated with the highest seriousness and any economically feasible digital and physical systems are implemented to secure personal information.

Personal Data is stored throughout your relationship with us. We delete your Personal Data upon request for cancelation of your account or other general request for the deletion of data.

In the event of a breach of your Personal Data, you will be notified in a reasonable time frame, but in no event later than two weeks, and we will follow all applicable laws regarding such breach.

Article 10 - Purposes Of Processing Of Personal Data:

We primarily use your Personal Data to help us provide a better experience for you on our Mobile App and to provide you the services and/or information you may have requested, such as use of our Mobile App.

Information that does not identify you personally, but that may assist in providing us broad overviews of our customer base, will be used for market research or marketing efforts. Such information may include, but is not limited to, interests based on your cookies.

Personal Data that may be considering identifying may be used for the following:     a) Improving your personal user experience     b) Marketing and advertising to you, including via email     c) Providing customer service to you     d) Advising you about updates to the Mobile App or related Items     e) The following other purposes:         1. Administer sweepstakes, promotions, and contests.         2. Assist law enforcement and respond to subpoena.         3. Compile anonymous statistical data and analysis for use internally or with third parties.         4. Create and manage your account.         5. Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Application to you.         6. Email you regarding your account or order.         7. Enable user-to-user communications.         8. Fulfill and manage purchases, orders, payments, and other transactions related to the Application.         9. Generate a personal profile about you to make future visits to the Application more personalized.         10. Increase the efficiency and operation of the Application.         11. Monitor and analyze usage and trends to improve your experience with the Application.         12. Notify you of updates to the Application.         13. Offer new products, services, mobile applications, and/or recommendations to you.         14. Perform other business activities as needed.         15. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.         16. Process payments and refunds.         17. Request feedback and contact you about your use of the Application.         18. Resolve disputes and troubleshoot problems.         19. Respond to product and customer service requests.         20. Send you a newsletter.         21. Solicit support for the Application.         22. [Other]

Article 11 - Disclosure OF PERSONAL DATA:

Although our policy is to maintain the privacy of your Personal Data as described herein, we may disclose your Personal Data if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion. Such cases may include, but are not limited to:     a) To satisfy any local, state, or Federal laws or regulations     b) To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies     c) To bring legal action against a user who has violated the law or violated the terms of use of our Mobile App     d) As may be necessary for the operation of our Mobile App     e) To generally cooperate with any lawful investigation about our users     f) If we suspect any fraudulent activity on our Mobile App or if we have noticed any activity which may violate our terms or other applicable rules

Article 12 - Opting Out of Transmittals From Us:

From time to time, we may send you informational or marketing communications related to our Mobile App such as announcements or other information. If you wish to opt-out of such communications, you may contact the following email: intvl@digitalhealth.ro. You may also click the opt-out link which will be provided at the bottom of any and all such communications.

Please be advised that even though you may opt-out of such communications, you may still receive information from us that is specifically about your use of our Mobile App or about your account with us.

By providing any Personal Data to us, or by using our Mobile App in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from us or third-party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is legally defined.

Article 13 - Modifying, Deleting, and Accessing Your Information:

If you wish to modify or delete any information we may have about you, or you wish to simply access any information we have about you, you may reach out to us at the following email address: intvl@digitalhealth.ro.

Article 14 - Acceptance Of Risk:

By continuing to our Mobile App in any manner, use the Product, you manifest your continuing asset to this Privacy Policy. You further acknowledge, agree and accept that no transmission of information or data via the internet is not always completely secure, no matter what steps are taken. You acknowledge, agree and accept that we do not guarantee or warrant the security of any information that you provide to us, and that you transmit such information at your own risk.

Article 15 - Your Rights:

You have many rights in relation to your Personal Data. Specifically, your rights are as follows:

  • the right to be informed about the processing of your Personal Data
  • the right to have access to your Personal Data
  • the right to update and/or correct your Personal Data
  • the right to portability of your Personal Data
  • the right to oppose or limit the processing of your Personal Data
  • the right to request that we stop processing and delete your Personal Data
  • the right to block any Personal Data processing in violation of any applicable law
  • the right to launch a complaint with the Federal Trade Commission (FTC) in the United States or applicable data protection authority in another jurisdiction Such rights can all be exercised by contacting us at the relevant contact information listed in this Privacy Policy.

Article 16 - Contact Information:

If you have any questions about this Privacy Policy or the way we collect information from you, or if you would like to launch a complaint about anything related to this Privacy Policy, you may contact us at the following email address:

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

    Type: Session Cookies

    Administered by: Us

    Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

  • Cookies Policy / Notice Acceptance Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

  • Functionality Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: