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Welcome to reallifehealing.eu’s Privacy Notice relating to the provision of our services namely, halth products and related information) on reallifehealing.eu and/or any sub-website and/or associated domains (and/or sub-domains) and any related software applications (“Site”, “Website”), where Personal Data is processed by reallifehealing.com relating to You.
We respect your privacy and we are committed to protecting your personal data. This commitment exists throughout the lifecycle of the personal data which you provide to us, from the provision of data you may give to us to provide You with a service to the deletion of that data. We process your personal data in compliance with applicable data protection laws, including but not limited to Chapter 586 of the Laws of Malta being the Data Protection Act 2018 (as amended);
Please note that other data protection laws, such as the EU’s General Data Protection Regulation, known as the GDPR (Regulation (EU) 2016/679), may apply to you.
This Privacy Notice will inform you as to how we use and look after your personal data. This Notice covers, among other topics:
- Information about who we are and how to contact us;
- Transparency about how we collect and use your personal data, including when and how it is shared and the categories of recipients;
- Information on how we protect your personal data;
- Information about your rights, the choices available to you, and how we will facilitate your rights and respond to your questions.
This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE MAY COLLECT ABOUT YOU
- HOW IS YOUR DATA COLLECTED
- HOW WE USE YOUR PERSONAL INFORMATION
- SHARING OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFER
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHT
- AUTOMATED PROCESSING – PROFILING
- CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
- IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice (the “Privacy Notice” or the “Notice”) aims to give you information on how reallifehealing.eu collects and processes your personal data, including any data you may provide through the website reallifehealing.eu (the “Website”) when you sign up to our marketing newsletter, send us an email, and any data we may collect on you to provide you with our healing products and services.
It is important that you read this Privacy Notice together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them. By using our Website, providing personal information to us and/or using any of our Services, you consent to the terms and conditions of this Privacy Notice (as updated from time to time).
This Website and our Services are not designed or directed to persons under the age of 16. If you are younger than this please do not use this Website without overriding parent or guardian consent, including use of the products or of any payment methods.
[insert name of the company/Real Life Healing] Limited is the controller responsible for your personal data (“Controller”).
Where we use the terms the “Company”, “we”, “us” or “our” in this Privacy Notice, this refers to the Controller.
. If you have any questions relating to this Privacy Notice, including any requests to exercise your rights, please contact us using the details given below.
CONTROLLER CONTACT DETAILS
Our full details are:
Full name of legal entity Real Life Healing
Company registration number: MT28937016
Email address: email@example.com
Postal address: 52, TRIQ GUISEPPE STIVALA NAXXAR
- THE DATA WE MAY COLLECT ABOUT YOU
“Personal data”, or personal information, means any information about an individual from which that person can be identified, directly or indirectly. It does not include data where the identity of that individual has been removed such that he or she cannot be identified (anonymous data).
We may collect personal data from you because of a legal reason or because you have consented us to do so for a specific purpose. We may collect, use, store and transfer different categories of personal data about you, which we have grouped together as follows:
- Contact Data may include first and last name, username or similar identifier, phone number, an email address and/or a delivery address.
- Marketing Communications Data includes your preferences in receiving marketing from us (opt in/opt out).
- Financial Data includes payment card details and bank account details, first and last name, permanent address and proof of address, date of birth, nationality, which GooglePay may share with us for the purposes of processing and delivering the orders associated with your account.
- Log in Data includes internet protocol (IP) address, your logins (first log in last login, last failed login), duration of log ins, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
- Other Communication Data provided by you in communication with us (via emails, instant messaging chats or SMS) which may include various data such as your intentions, interests, complaints, preferences, as well as internal communication and notes.
- Analytics Data include various data provided by your observed with respect to your use of our Website and Services such as language, location, channels used, device, payment provider, and in case of online acquisition analytics also pages visited, postcards clicked, scroll depth. Certain information is collected using cookies and/or similar tracking technology.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, there may be times when you may voluntarily choose to disclose information like this to us, especially regarding your medical health conditions, however we will not store this data.
- HOW IS YOUR PERSONAL DATA COLLECTED?
We collect your personal data through different methods, including:
- Direct interactions - you may give us your Contact, Marketing and Communications and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise when you engage with us to provide you with our Services.
- Third parties and publicly available sources - We may combine the information we collect from you with information that we receive about you from other sources, such as public databases, or GooglePay. Such information is collected only when it is reasonably necessary for the organization’s activities or to deliver the Services to you.
- Automated technologies or interactions - We and our third-party service providers may collect information automatically from your device in a variety of ways, including through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your IP, device type, language and the Internet browser type you are using.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data to perform the Services and the contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with information related to your query or to deliver the products to you at your address).
- HOW WE USE YOUR PERSONAL INFORMATION
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- To provide and operate the Services (to deliver goods and services you may purchase through the Website);
- To communicate with you and to keep you informed of our latest updates to our Services and special offers;
- Providing, maintaining, enhancing and personalizing the Services and analysing how customers use the Services and the Website;
- To know your preferences and to try to ensure that the content on our Website is presented in the most effective manner for you and your computer or mobile device;
- To market our Services (see more below under “Marketing”), as well as to serve you advertisements;
- To communicate with your and to process any of your requests to exercise your Legal Rights; and
- To investigate and resolve disputes in connection with your use of the Services.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by unsubscribing from our mailing list.
PURPOSE FOR PROCESSING YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To process and manage orders/transactions
(a) Financial Data
(b)Delivery details and address/phone number
Performance of a contract with you
To manage our relationship with you, to provide you with access to our Services.
(a) Contact Data
(b)Other Communication Data
(a) Performance of a contract with you
(b) Compliance with legal obligations
Direct marketing of our own Services including offers, news, and promotions.
a) Contact Data
b) Marketing and Communication Data
Social Media Marketing
To administer and protect our business and this portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(b) Analytics data
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
We may use your personal data, such as your email address and telephone number, ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials (including news and offers), concerning our Services.
We will use your personal data for the purpose of providing you with promotional materials solely where we have a legitimate interest in doing so, or where we have obtained your affirmative consent.
When relying on legitimate interest, we will give you the opportunity to oppose to such direct marketing with each communication sent.
If you do not wish to receive direct marketing any longer, you may opt out, easily, at any time, either by:
- unsubscribing or activating the relevant link at the end of an electronic message, or
- contacting us.
In case of social media marketing, you can control the delivery of certain advertising or social campaigns through the settings offered by the respective third-party platforms (e.g. Facebook).
THIRD PARTY TRACKING TECHNOLOGIES
When you visit or access our Services (for example when you visit our Website), we use (and authorise third parties to use) cookies, pixels other technologies ("Tracking Technologies").
The Tracking Technologies allow us to automatically collect information about you and your online behaviour, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our users and customers/readers
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- SHARING OF YOUR PERSONAL DATA
We do not rent, sell, or share your personal data with third parties (“Recipients”) except as described in this Privacy Notice. The personal information will be disclosed to Recipients only to the extent required for the specific purpose(s), as stipulated in this Privacy Notice.
We may have to share your personal data with the following categories of Recipients:
- Professional advisers including lawyers, bankers, auditors and insurers based in Europe who provide consultancy, banking, legal, insurance and accounting services.
- Any service providers that may have access to your personal data in rendering us with their support services, for example, IT service providers, payment service providers, analytic services providers, service providers that technically enable communication with you (via email, chat, SMS, phone), marketing service providers, data hosting service providers, Website performance and security systems service providers.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
We require all third parties that are acting as processers to RealLifeHealing to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where required by law, your personal information may be disclosed to an applicable governmental or enforcement authority. Those bodies may then use your personal information to investigate and act on any such breaches in accordance with their procedures.
- INTERNATIONAL TRANSFERS
It may be necessary for the provision of our Services and to the extent required for specific purposes, as stipulated in this Privacy Notice to transfer your personal information outside of the European Economic Area (“EEA”) where necessary (such as where we use service providers outside the EEA).
Certain restrictions may apply where personal data is being transferred by us to a ‘third country’ outside the EEA or the United Kingdom with such transfers referred to as “restricted transfers”. The data protection and other laws of these third countries may not be as comprehensive as those in Malta or the EEA.
Generally, we will only perform restricted transfers where the transfer will be adequately protected by measures such as the following:
- where the transfer is to a territory which has been deemed ‘adequate’ under applicable data protection legislation via applicable adequacy regulations; or
- where ‘appropriate safeguards’ are provided.
In the absence of adequacy regulations or appropriate safeguards as outlined above, we may also rely on derogations for specific situations as contained within the Malta GDPR. In particular, we may collect and transfer your personal data outside the EEA in any of the following circumstances:
- with your explicit consent;
- to perform a contract we may have with you (or for taking pre-contractual steps);
- to perform a contract we may have with a third party which has been concluded in your interest;
- for important reasons of public interest;
- for the establishment, exercise or defence of legal claims; or
- to protect your vital interests or those of a third party (where you are physically or legally incapable of giving consent).
We may also perform restricted transfers in ‘one-off’ cases where a transfer is not repetitive, concerns a limited number of data subjects, and is necessary for the purposes of compelling legitimate interests pursued by us, which are not overridden by your interests or rights and freedoms, and only after we have assessed all relevant circumstances.
- DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so and in accordance with the requirements of applicable law.
- DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where your personal data is no longer required by us, we will either securely delete or anonymise the personal data in question.
- YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under different data protection laws in relation to your personal data and depending on your individual circumstances. For example, you may have additional rights under the EU GDPR if you are based in the EEA. You have a right to:
Be informed about how we use your personal data. This information is contained in this Privacy Notice.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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 consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within two months. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
RIGHT TO MAKE A COMPLAINT
We try to follow the highest standards in order to protect your privacy and rights. However, should you have any concerns in connection with this Privacy Notice, we encourage that you get in contact with us in the first instance on the contact details contained in this Privacy Notice. We will deal with your queries as soon as we can and keep you informed of progress.
You have the right to make a complaint at any time to the Information and Data Protection Commissioner Office (IDPC), the Maltese supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance.
For your information, the IDPC’s contact details are as follows,
Address: Level 2, Airways House, High Street, Sliema
Landline: (+356) 2328 7100
- AUTOMATED PROCESSING
No automated processing is currently used. Decisions, on the basis of prediction, are not taken automatically without human intervention.
- CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We may amend this Privacy Notice in our sole discretion from time to time. If we make changes to this Privacy Notice, we will provide notice of such changes, such as, (where appropriate) by sending an email notification; or publishing the revised Privacy Notice on our Website; and/or updating the ‘Last updated’ date applicable to this Privacy Notice.
Any modified or updated Privacy Notice will be effective immediately after the date it is notified or posted on the Website (as the case may be). By continuing to access or use our Services or Website after such an effective date, you confirm your acceptance of the revised Privacy Notice and all of the terms incorporated therein by reference.
You are encouraged to regularly check our Privacy Notice whenever you access or use either our Website or Services in order to consider any updates or changes. If you do not agree to our revised Privacy Notice, you should not access or use either our Website or Services.
It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This Privacy Notice was last updated on: Version 0.1 updated February 17, 2022