Effective date: November 23, 2019

Stayhealthy, Inc. (“us”, “we”, or “our”) operates the OWL Cancer Survivor Platform App mobile application (hereinafter referred to as the “Service”). We created this Privacy Policy (this “Policy”) to give you confidence as you visit and use the Service, and to demonstrate our commitment to fair information practices and the protection of privacy. This Policy is only applicable to the Service, and not to any other websites that you may be able to access from the Service, each of which may have data collection and use practices and policies that differ materially from this Policy.

NOTICE CONCERNING CHILDREN

We are a general audience service, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. The Service is primarily intended for adult cancer survivors, cancer patients and their care givers and support groups.

INFORMATION COLLECTION PRACTICES

This page informs you of our policies regarding the collection, use and disclosure of de-identified personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Use.

WHAT BASIC INFORMATION DO WE COLLECT?
In operating the Service, we may include payment processing services, online surveys, and other online forms that ask users to provide their name, age, gender, address, e-mail addresses, and other contact information.

WHAT ADDITIONAL INFORMATION DO WE COLLECT?
(a) AUTOMATIC COLLECTION. Our analytics system recognizes user actions and events. No personal information about you is revealed in this process. The Service may also gather anonymous “traffic data” that does not personally identify you, but that may be helpful for marketing purposes or for improving the services we offer.
(b) From time to time, we may use the standard “cookies” feature of major browser applications that allows us to store a small piece of data on your computer about your visit to our Service. We do not set any personally identifiable information in cookies.

Definitions

Service

Service is the OWL Cancer Survivor Platform mobile application operated by Stayhealthy, Inc.

De-identified Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). De-identified data means we strip out form personnel data any way to identify who you are. The remaining data can be sued for demographic and other purposes but cannot identify who you are.

Usage Data

Usage Data is 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).

Cookies

Cookies are small files stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

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 (“Personal Data”). Personally identifiable information may include, but is not limited to: email address, first name, last name, and Usage Data. Personal identifiable health information may include, but is not limited to: health-related information, height, weight, age, gender, waist circumference, race, and activity levels.

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.

Usage Data

When you access the Service with 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 (“Usage Data”).

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service (such as activity tracking), to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data

We may use cookies and similar tracking technologies to track activity on our Service and acquire certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies may also be used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

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 portions of our Service.

Use of Data

Stayhealthy, Inc. uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • 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

USE AND SHARING OF INFORMATION

3.1. WHAT DO WE DO WITH COLLECTED INFORMATION?

(a) PERSONAL INFORMATION. We will not share your personal information with any third parties without your consent, except as necessary to provide you with the services offered by us or to comply with the law. We may use your personal information to verify your identity, to check your qualifications, or to follow up with transactions initiated on the Service. We may also use your contact information to inform you of any changes to the Service, or to send you additional information about us.

(b) ANONYMOUS INFORMATION. We use anonymous information to analyze Service traffic, but we do not examine this information for individually identifying information. In addition, we may use anonymous IP addresses to help diagnose problems with our server, to administer our site, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis.

(c) DISCLOSURE OF PERSONAL INFORMATION. We may disclose personal information if required to do so by law or in the good faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on Company or its parent company, subsidiaries or affiliates, (2) protect and defend the rights or property of Company or the users of the Service, or (3) act under exigent circumstances to protect the safety of the public or users of the Service.

(d) SALE OF INFORMATION. In order to accommodate changes in our business, we may sell or buy portions of our company or other companies or assets, including the information collected through this Service. If Company or substantially all of its assets are acquired, customer information will be one of the assets transferred to the acquirer

(e) DO NOT TRACK DISCLOSURE. The Service does not track your use of the Service over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, your browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.

SECURITY

The Service has security measures in place to prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Stayhealthy, Inc. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Stayhealthy, Inc. may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • For payment processing purposes
  • To comply with the law

Retention of Data

Stayhealthy, Inc. 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.

Stayhealthy, Inc. 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 periods.

Transfer of Data

Your information, including Personal Data, 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 from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Stayhealthy, Inc. will take all the 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.

Disclosure of Data

Business Transaction

If Stayhealthy, Inc. 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.

Disclosure for Law Enforcement

Under certain circumstances, Stayhealthy, Inc. 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).

Legal Requirements

Stayhealthy, Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Stayhealthy, Inc.
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data

The security of your 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 adhere to current industry best practices and standards to protect your Personal Data, we cannot guarantee its absolute security.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Stayhealthy, Inc. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

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.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where Stayhealthy, Inc. relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

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.

You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. 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.

The payment processors we work with are:

Apple Store In-App Payments

Their Privacy Policy can be viewed at: https://www.apple.com/legal/privacy/en-ww/

Google Play In-App Payments

Their Privacy Policy can be viewed at: https://www.google.com/policies/privacy/

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click 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.

Children’s Privacy

Our Services are not intended for users under the age of 18. Our Service asks for a full date of birth to ensure that we are not collecting information from individuals under 18 years of age. We do not knowingly collect personally identifiable information from anyone under the age of 18. 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 children without verification of parental consent, we take steps to remove that information from our servers.

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 “effective 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. We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the Service and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Service. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its term

Contact Us

If you have any questions about this Policy, our practices related to this Service, or if you would like to have us remove your information from our database please feel contact us at the following: www.stayhealthy.com