This privacy statement explains Our practices for gathering, using, and disclosing Your information when you use the Service. It also provides information about Your legal protections and privacy rights.
Interpretation and Definitions
The words with capitalized initial letters have specific meanings as shown in the following conditions. These definitions maintain their significance irrespective of whether they are in singular or plural form.The following requirements determine the meanings of the words whose first letter is capitalized. Whether they are written in the singular or plural, the following definitions will always imply the same thing.
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 refers to HeartFit, the software program provided by the Company.
Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Westwey Technologies Limited.
For the purpose of the GDPR, the Company is the Data Controller.
Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
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 cellphone or a digital tablet.
GDPR refers to EU General Data Protection Regulation.
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.
For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
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, 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
We could ask You to give Us specific personally identifiable information when using Our Service so that We can get in touch with or identify You. Names, addresses, and other contact details that may be linked to a specific individual.
When utilizing the Service, usage data is automatically gathered.
Usage Data may contain information such the Internet Protocol address (IP address) of Your Device, the type and version of your browser, the pages of our service that You visit, the time and date of your visits, the amount of time you spend on those pages, device identifiers, and other diagnostic data.
When You use a mobile device to access the Service, We may automatically gather some information about it. This information may include, but is not limited to, the kind of device you use, its unique ID, its IP address, its operating system, the kind of mobile browser you use, and other diagnostic information.
If You visit our service or use a mobile device to access it, we could also gather information that your browser transmits to us.
Information Collected while Using the Application
With Your prior consent, We may gather the following information when you use Our Application in order to deliver features of Our Application:
To deliver features of Our Service, enhance and personalize Our Service, We utilize this information. You have the option to save the information on Your device or upload it to the servers of the Company, a Service Provider, or both.
Anytime you choose, you can use Your Device's settings to allow or prohibit access to this data.
Use of Your Personal Data
The Company processes Personal Data for diverse purposes, encompassing:
Service Maintenance: Ensuring the provision and upkeep of our Service, including the monitoring of its usage.
Contractual Obligations: Fulfilling contractual obligations, encompassing the development, compliance, and execution of contracts initiated through the Service.
Communication: Contacting you through email or other electronic means for updates, security notifications, and relevant informative communications.
Marketing Initiatives: Providing news, special offers, and general information regarding goods, services, and events similar to your prior engagements, unless you choose not to receive such information.
Request Management: Attending to and managing your requests effectively.
Targeted Advertising: Developing and displaying tailored content and advertisements based on your interests and location, often in collaboration with third-party vendors for effectiveness assessment.
Business Transitions: Evaluating, conducting, or facilitating business transitions like mergers, divestitures, restructurings, or asset transfers, involving the transfer of Personal Data.
Additional Functions: Conducting data analysis, identifying usage trends, and assessing ways to enhance our Service, products, services, and overall user experience.
The sharing of personal information may occur in the following circumstances:
Service Providers: Sharing with Service Providers for tasks such as monitoring Service usage, displaying advertisements, supporting and maintaining the Service, and processing payments.
Business Transfers: Sharing or transferring personal information in connection with, or during negotiations of, various business transactions such as mergers, asset sales, financing, or acquisitions.
Business Partnerships: Sharing with business partners to offer specific products, services, or promotions.
User Interaction: Acknowledging that personal information shared in public areas may be viewed and publicly distributed by other users.
Consent-Based Disclosure: Disclosing personal information for any other purpose with your explicit consent.
Retention of Your Personal Data
Usage Data will also be retained for internal analysis but typically for a shorter duration. Exceptions include instances where this data contributes to enhancing security, improving Service functionality, or when legal obligations necessitate a more extended retention period.
Transfer of Your Personal Data
Your information, including Personal Data, is processed in the Company's operational offices and other locations where involved parties in the processing are situated. This implies that the information may be transferred to, and maintained on, computers located outside Your state, province, country, or other governmental jurisdiction, potentially subject to different data protection laws than those in Your jurisdiction.
Delete Your Personal Data
You possess the right to delete or request assistance in deleting the Personal Data collected about You. Our Service provides the option to delete certain information from within the platform.
You retain the ability to update, amend, or delete Your information at any time through the settings section for managing personal information. Alternatively, contacting Us allows You to request access, correction, or deletion of any personal information provided to Us.
It's important to note that certain information may need retention based on legal obligations or lawful justifications even when a deletion request is made.
Disclosure of Your Personal Data
In some cases, the Company might have to provide Your Personal Data in response to legal requirements or legitimate requests from public authorities (such a court or government agency).
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Fulfill a legal requirement
Safeguard and uphold the rights or assets of the Company
Prevent or probe potential misconduct related to the Service
Ensure the safety of Service Users or the general public
Safeguard against legal responsibility
Security of Your Personal Data
We take the security of Your Personal Data very seriously, but keep in mind that no method of electronic data transfer over the Internet or technique of electronic data storage is 100% safe. We can't guarantee the complete security of Your Personal Data, even though we do our best to secure it using commercially reasonable methods.
Detailed Information on the Processing of Your Personal Data
Complete Details on How Your Personal Data Is Processed
We may share Your Personal Data with the Service Providers we utilize. Regarding Your behavior on Our Service, these third-party vendors gather, store, utilize, process, and transmit information in compliance with their privacy policies.
Third-party service providers could be used by us to track and examine how our service is being used.
Google Analytics：Google provides website traffic tracking and reporting through its web analytics service, Google Analytics. Google tracks and keeps an eye on how our service is being used. Google shares this information with its other services. Google may utilize the information gathered to contextualize and tailor its own advertising network's advertisements.
Please visit the Google Privacy & Terms website at https://policies.google.com/privacy to learn more about the company's privacy policies.
Reviewing Google's data security policy at https://support.google.com/analytics/answer/6004245 is another recommendation from us.
Please read the How Google uses data homepage at https://policies.google.com/technologies/partner-sites for further details on the kinds of data that Firebase gathers when you use their websites or applications.
We engage Service Providers to display advertisements as part of our efforts to sustain and uphold the functionality of Our Service.
We could provide premium goods and/or services through the Service. Then, we may handle payments using services provided by third parties (like payment processors).
Your payment card information won't be kept or gathered by us. Your personal information is used by Our third-party payment processors in accordance with their Privacy Policies, and they get that information directly from Us. The PCI Security Standards Council, an alliance of major credit card companies including Visa, Mastercard, American Express, and Discover, oversees the PCI-DSS standards, which these payment processors follow. The safe processing of payment information is aided by PCI-DSS regulations.
Paying in-app on the Apple Store Visit https://www.apple.com/legal/privacy/en-ww/ to check their privacy statement.
Remarketing services are used by the Company to show You ads after you have accessed or visited our service. In order to improve our service to better reflect your interests and show you ads that are likely to be of greater interest to you, We and Our third-party suppliers employ both cookies and non-cookie technologies to help Us identify Your Device and understand how You use our Service.
These outside vendors gather, save, utilize, process, and transmit data on Your activities on Our Service in compliance with their privacy policies, allowing Us to:
Track and evaluate user traffic and browsing behavior on Our Service
Display promotional content for our goods and/or services on external websites or applications.
Evaluate and assess our advertising initiatives' effectiveness.
Certain third-party suppliers could employ non-cookie technology, which might not be affected by browser settings that exclude cookies. It's possible that your browser won't let you block these technologies. To refuse information gathering and usage for the aim of providing you with interest-based advertising, you can make use of the following third-party tools:
By turning on privacy options like Limit Ad Tracking (iOS) and Opt Out of adverts Personalization (Android), you may also choose not to receive customized adverts on mobile devices. Check out the Help system on your mobile device for further details.
Among the outside vendors we collaborate with are:
Google Ads (AdWords):
Legal Basis for Processing Personal Data under GDPR
We may handle Personal Data based on the following conditions:
Consent: You have provided explicit consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Providing Personal Data is essential for fulfilling an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary to comply with a legal obligation to which the Company is bound.
Vital interests: Processing Personal Data is necessary to safeguard Your vital interests or those of another natural person.
Public interests: Processing Personal Data is related to a task 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 pursuing the legitimate interests of the Company.
In any circumstance, the Company is ready to provide clarification on the specific legal basis applicable to the processing, particularly whether the provision of Personal Data is a statutory or contractual requirement or a necessity to enter into a contract.
Your Rights under the GDPR
The Company is committed to preserving the confidentiality of Your Personal Data and ensuring that You can exercise Your rights.
Access Your Personal Data: You have the right to access, update, or delete the information We hold about You. Whenever possible, You can perform these actions directly within Your account settings section. If You are unable to do so, please contact Us for assistance. This also allows You to receive a copy of the Personal Data We possess about You.
Correct Your Personal Data: 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 when We rely on a legitimate interest as the legal basis for Our processing, and there is something about Your particular situation that makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object when We process Your Personal Data for direct marketing purposes.
Request Erasure of Your Personal Data: You can ask Us to delete or remove Personal Data when there is no valid reason for Us to continue processing it.
Request the Transfer of Your Personal Data: We will provide You, or a third-party of Your choice, with Your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information 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 for the use of 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
By getting in touch with Us, You can use Your rights of access, rectification, cancellation, and objection. Please be aware that before answering such inquiries, we can require You to confirm Your identity. We shall make every effort to reply to You as quickly as we can if You make a request.
You can file a complaint regarding Our acquisition and use of Your Personal Data with a Data Protection Authority. If you live in the European Economic Area (EEA), please get in touch with your local EEA data protection authority for additional details.
CCPA/CPRA Privacy Notice (California Privacy Rights)
Categories of Personal Information Collected
We gather information that identifies, relates to, describes, or is capable of being associated with a particular Consumer or Device. The following outlines the categories of personal information we may collect from California residents in the last twelve (12) months. Please note that the categories and examples provided are defined by the CCPA/CPRA. While not all examples may have been collected, they represent our good-faith belief that some information from each category may have been collected, particularly if provided directly by You.
Examples: Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, driver's license number, passport number.
Examples: Name, signature, Social Security number, physical characteristics, address, telephone number, passport number, driver's license or state identification card number, education, employment, bank account number, credit card number.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information.
Examples: Records and history of products or services purchased or considered.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns.
Examples: Interaction with our Service or advertisement.
Examples: Approximate physical location.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Examples: Current or past job history or performance evaluations.
Examples: Education records directly related to a student.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends.
Examples: Account login and password information, geolocation data.
Under CCPA/CPRA, personal information excludes publicly available information from government records, deidentified or aggregated consumer information, and information excluded from the CCPA/CPRA's scope.
Sources of Personal Information:
Directly from You: Forms completed on our Service, preferences expressed or provided through our Service, or purchases made.
Indirectly from You: Observing Your activity on our Service.
Automatically from You: Through cookies set on Your Device.
From Service Providers: Third-party vendors for monitoring and analyzing Service usage, providing advertising, delivering targeted advertising, payment processing, or other services used to provide the Service to You.
Use of Personal Information
We may utilize or disclose the personal information we collect for "business purposes" or "commercial purposes," as defined under the CCPA/CPRA. Examples of such purposes include:
To operate our Service and provide you with the services we offer.
To provide support and respond to your inquiries, addressing concerns, and monitoring and improving our Service.
To fulfill or meet the reason you provided the information, such as responding to inquiries or processing payments.
To respond to law enforcement requests and comply with applicable laws, court orders, or governmental regulations.
As described to you when collecting your personal information or as otherwise outlined in the CCPA/CPRA.
For internal administrative and auditing purposes to ensure proper functioning and compliance.
To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activities, including necessary actions for prosecution.
Other one-time uses deemed necessary for the overall functioning and improvement of our Service.
Disclosure of Personal Information
For business or commercial objectives, we may use or disclose the following kinds of personal information, as we may have done over the past twelve (12) months:
Be aware that the CCPA/CPRA defines the categories that are mentioned above. To the best of our knowledge, we believe that some of the personal information falling under the applicable category may have been published. However, this does not imply that all instances of that type of information were really made public.
A contract that specifies the objective and obliges the receiver to maintain the confidentiality of the personal information and not use it for any other reason than carrying out the contract is executed whenever We reveal personal information for business or commercial purposes.
Share of Personal Information
The following categories of third parties may receive Your personal information that is listed in the above categories, as we have in the last twelve (12) months:
Sale of Personal Information
"Sell" and "sale" as used in the CCPA/CPRA refer to the business's selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer's personal information to a third party for valuable consideration, whether orally, in writing, electronically, or through another method. This indicates that while We might not have benefited monetarily, We might have benefited in some other way for disclosing personal information.
We might sell, and we might have sold in the previous twelve (12) months the following categories of personal information:
Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity
Please be aware that the categories above are those that are defined by the CCPA/CPRA. This does not imply that all instances of that particular category of personal information were actually sold; rather, it represents our sincere belief, to the best of our knowledge, that some of the information from the relevant category may have been shared for compensation in the past.
Sale of Personal Information of Minors Under 16 Years of Age
In the event that We do not get affirmative authorization (the "right to opt-in") from a consumer who is between the ages of 13 and 16 or from a consumer who is under the age of 13, we will not sell the personal information of consumers that We really know to be under the age of 16. Customers may withdraw from further sales at any moment if they choose not to have their personal information sold in the future. You (or Your designated representative) may make a request to Us by getting in touch with Us in order to use the opt-out option.
Should You suspect that a child under the age of 13 (or 16) has given Us personal information, kindly get in touch with Us so that We can remove the information.
Your Rights under the CCPA/CPRA
The CCPA/CPRA grants specific rights to California residents regarding their personal information. If you are a California resident, you are entitled to the following rights:
Right to Notification: You are entitled to know which kinds of personal information are being gathered as well as why the information is being utilized.
Right to Know/Access: You have the right, under CCPA/CPRA, to obtain information from Us on the personal data We collect, use, sell, disclose for commercial purposes, and share. As soon as We acknowledge receipt of Your request, We shall tell You of:
The types of private data that we have obtained about you
The types of sources from which We gathered Your personal information
For our business or commercial objectives, we may gather and sell that personal data.
Which third parties are those that We share such personal information with
The particular details of your personal information that We have obtained
Should we sell Your personal data or make a business-related disclosure of Your personal data, We shall notify You of:
The right to say no to the sale or sharing of Personal Data (opt-out). You can instruct us not to sell your personal information. To exercise this right, refer to the "Do Not Sell My Personal Information" section or contact us directly.
The right to correct Personal Data. If any personal information we collected about you is inaccurate, you have the right to correct or rectify it. Upon receiving and verifying your request, we will make commercially reasonable efforts to correct the information, including instructing our Service Providers to do the same.
The right to limit use and disclosure of sensitive Personal Data. You can request limitations on the use or disclosure of specific sensitive personal information we have collected about you, unless exceptions apply. To initiate this process, consult the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact us.
The right to delete Personal Data. You have the right to request the deletion of your Personal Data under certain circumstances, subject to exceptions. Once we confirm your request, we will delete your personal information from our records, and we will instruct our Service Providers to do the same unless exceptions apply.
Complete the Transaction or Provide Requested Goods/Services: We may retain your personal information to fulfill the transaction or provide the goods/services you requested. This includes actions anticipated within the scope of our ongoing business relationship with you or to fulfill our contractual obligations.
Security Measures: Your information may be retained to detect, protect against, or prosecute those involved in security incidents, malicious activities, deceptive practices, fraud, or illegal conduct.
Product Debugging: We may retain data to debug products, identifying and rectifying errors that impact their intended functionality.
Exercise Free Speech and Legal Rights: Information may be retained to exercise free speech, uphold the rights of other consumers, or comply with other legal obligations.
Compliance with Applicable Laws: We may retain information to comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.) and other relevant laws.
Scientific or Research Purposes: In cases where your informed consent was provided, information may be retained for public or peer-reviewed scientific, historical, or statistical research that aligns with ethical and privacy standards.
Internal Uses Aligned with Consumer Expectations: Information may be used internally for purposes reasonably aligned with your expectations based on our relationship.
Compliance with Legal Obligations: Your information may be retained to comply with legal obligations imposed on us.
Internal and Lawful Uses: Other internal and lawful uses of information that align with the context in which it was provided may also warrant retention.
These scenarios outline the various situations in which we may retain your information, ensuring transparency and adherence to applicable laws and ethical standards.
Exercising Your CCPA/CPRA Data Protection Rights
For further details on how to opt out and restrict the use of sensitive information acquired, please refer to the sections labeled "Do Not Sell My Personal Information" and "Limited the Use or Disclosure of My Sensitive Personal Information."
Furthermore, should You choose to utilize any of Your CCPA/CPRA rights, and should You reside in California, You may get in touch with Us at:
Only you or a person authorized by the California Secretary of State, whom you have given permission to act on your behalf, can submit a verifiable request concerning your personal information.
To ensure a proper response to your request, please:
Provide adequate information enabling us to reasonably verify that you are the individual for whom we collected personal information or an authorized representative.
Clearly describe your request, offering enough detail for us to comprehend, evaluate, and address it.
If we cannot:
We won't be able to respond to your request or provide the necessary information.
Upon receiving your verifiable request, we will disclose and deliver the required information at no cost within 45 days. If necessary, and with prior notice, this period may be extended by an additional 45 days.
Any information disclosed will pertain to the 12-month period leading up to the receipt of the verifiable request.
For data portability requests, we will choose a format for providing your personal information that is easily usable and allows you to transmit the information from one entity to another without impediment.
Do Not Sell My Personal Information
As outlined in the CCPA/CPRA, the terms "sell" and "sale" encompass activities such as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer's personal information to a third party for valuable consideration. The term "valuable consideration" implies that there may be some form of benefit received in exchange for sharing personal information, not limited to monetary gains.
You possess the right to opt-out of the sale of your personal information. Upon receiving and verifying a consumer request from you, we will cease the sale of your personal information. To exercise this opt-out right, please contact us.
It's important to note that the service providers we collaborate with, such as analytics or advertising partners, may employ technology on the service that constitutes selling personal information under the CCPA/CPRA. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales under CCPA/CPRA, please follow the instructions below.
Please be aware that any opt-out is specific to the browser you are using, and you may need to opt out on each browser you utilize.
If applicable, select the "Privacy Preferences," "Update Privacy Preferences," or "Do Not Sell My Personal Information" buttons provided on the Service to examine your privacy preferences and opt-out of cookies and other technologies that we may employ. It's essential to be aware that you must opt out separately for each browser you utilize to access the Service.
Moreover, you have the option to decline personalized ads delivered by our Service Providers by adhering to the guidelines outlined on the Service:
Choosing to opt out will result in the placement of a unique cookie on your computer, specific to the browser you utilize for the opt-out process. If you switch browsers or delete the cookies stored by your browser, you will be required to perform the opt-out procedure once more.
Your mobile device may provide you with the option to decline the utilization of information regarding the apps you use for delivering targeted ads based on your interests:
On Android devices, you can select "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization."
On iOS devices, you can enable "Limit Ad Tracking."
Moreover, you can prevent the gathering of location information from your mobile device by adjusting the preferences on your device.
Limit the Use or Disclosure of My Sensitive Personal Information
If You reside in California, You have the right to restrict how Your sensitive personal information is used and disclosed to the extent required to fulfill your request for services or goods and to ensure that the services or goods are delivered in a way that normal consumers would expect.
Only as required to deliver the Service will we gather, utilize, and disclose sensitive personal data. See "Use of Your Personal Data" or get in touch with us for further details on how We use Your personal information.
No one under the age of thirteen is addressed by our service. We do not intentionally ask anyone younger than 13 for personally identifying information. Please get in touch with Us if you are a parent or guardian and You know that Your child has given Us Personal Data. We take action to delete Personal Data from Our systems if We learn that We have obtained it from anybody under the age of 13 without first obtaining parental consent.
Before We collect and use Your information, We may need Your parent's approval if Your nation requires agreement from parents and We must rely on consent as a legal basis for processing such information.
Links to Other Websites
There may be connections within Our Service to external websites that are not run by Us. A third party's website will be displayed if you click on one of their links. We strongly suggest that you go over each website's privacy statement.
The content, privacy practices, and policies of any third-party websites or services are beyond our control and responsibility.
If you have any questions about this Disclaimer, You can contact Us: