Last updated: February 2023
BACKGROUND AND PURPOSE OF THIS POLICY
GENERAL GUIDANCE PROVISIONS
- We set forth how we collect your personal data, how and for what purposes we may use your personal data, to whom your personal data may be disclosed by us, how long we shall keep your data and how we protect your personal data.
Note: this does not constitute your ‘consent’ to the processing of your personal data. We do not process your personal data on the basis of your consent, unless specifically indicated.
YOUR PRIVACY IS IMPORTANT TO LIFESTEN LIMITED
- In the context of our activities and to operate efficiently, we collect, hold, disclose and/ or otherwise process personal data about people with whom we work and people that use our platforms. This may
- include members of the general public, current, former and prospective employees, contractors, agents, collaborators, customers, clients, suppliers and users of our website and other platforms.
- In addition, we may be required by law to collect and use information in order to comply with regulatory
- We value your right to privacy and strive to protect your personal data in accordance with applicable data protection legislations in the Republic of Rwanda.
- Lifesten Limited consider that the correct treatment of your personal data is integral to our successful operations and to maintaining your trust. We fully appreciate the underlying principles of this policy and support and adhere to its provisions.
We will comply with the data protection principles by making sure that all your personal data is:
- Fairly and lawfully processed in a transparent manner;
- Processed for specific and limited purposes;
- Adequate, relevant and not excessive and limited to purpose for which we use your personal data;
- Accurate and kept up to date;
- Not kept longer than necessary;
- Processed in accordance with your rights to information, correction or deletion;
- Protected by technical and organisational safeguards to ensure the security of your personal data;
- Not transferred to countries outside the European Economic area unless the country to which your personal data is to be transferred has adequate protection for you.
WHOSE PERSONAL DATA DO WE COLLECT?
In the context of our services or by simply using our website, we may collect personal data relating to members of the public, current, former past and prospective employees, contractors, agents, collaborators, customers, clients, suppliers, visitors to our website and other persons dealing with Improve International.
INTERPRETATION AND DEFINITIONS
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
- Account means a unique account created for You to access our Service or parts of our Service.
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Application means the software program provided by the Company downloaded by You on any electronic device, named Lifesten Health
- Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Lifesten Health LLC, KN 78 St, Kigali, Rwanda. For the purpose of the GDPR, the Company is the Data Controller.
- Country refers to: the Republic of Rwanda
- Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
- Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
- Personal Data is any information that relates to an identified or identifiable individual.For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
- Service refers to the Application.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
For the purpose of the GDPR, Service Providers are considered Data Processors.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
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 yourn person. That identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Physical address
- 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.
- Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
- Information regarding your location
- Information from your Device’s phone book (contacts list)
We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on Your device.
You can enable or disable access to this information at any time, through Your Device settings.
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, for payment processing, 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 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 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.
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.
- 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 under the following ways;
- Court order and;
- Order of the government agency
- Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such an 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
LIMITATION OF SECURITY FOR 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.
DETAILED INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
We may use third-party Service providers to monitor and analyze the use of our Service.
- Google Analytics
- Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
- For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Firebase is an analytics service provided by Google Inc.
- We also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245
- For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners’ sites or apps webpage: https://policies.google.com/technologies/partner-sites
- Nuralogix AI
- At Lifesten, we take the privacy and security of our users’ data seriously. As part of our service, we utilize Nuralogix AI services to conduct remote diagnostics and screening.
- To ensure the protection of our users’ personal information, all data processed through Nuralogix’s artificial intelligence is done so on their secure servers, which comply with various data protection and privacy regulations such as the General Data Protection Regulation (GDPR) and Health Insurance Portability and Accountability Act (HIPAA).
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
- Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.
- We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
- These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover.
- PCI-DSS requirements help ensure the secure handling of payment information.
LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GDPR
We may process Personal Data under the following conditions:
- Consent:You have given Your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract:Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
- Legal obligations:Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests:Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
- Public interests:Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests:Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
NOTE; In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
YOUR RIGHTS UNDER THE GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
- Request access to Your Personal Data.The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You.You have the right to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data.This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data.You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data.We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent.You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
EXERCISING OF YOUR GDPR DATA PROTECTION RIGHTS
- You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
- You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the republic of Rwanda, please contact Your local data protection authority.
- 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.
LINKS TO OTHER WEBSITES
- We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
- By email: [email protected]
- By visiting this page on our website: https://lifesten.health/privacy-policy