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PRIVACY POLICY

Healthiest Humans Privacy Policy

 

Last Updated: Last Modified: January 28, 2024

 

Since Healthiest Humans is a self-paced program providing wellness services, we do not provide medical treatment, nor do we render advice. As such, our model does not depend on disclosure of your health history or any information about your medical diagnoses or treatments. Our coaches will not solicit from you your private medical information. In the event that you share such information with a coach or other Healthiest Humans personnel, however, we will take all reasonable steps to protect its confidentiality.

 

Additionally, your status as a Pioneer will remain confidential unless you expressly authorize us to disclose that information. Healthiest Humans will neither request nor accept any medical records or documentation relating to any past or present medical condition, treatment, or services. When you decide to become a Pioneer, you will select your area of focus based on your unique needs. Coaches may provide more information about the advantages of particular areas of concentration, but they will tailor any information they provide to your expressed desires and goals, not to your confidential medical records or medical information.

 

To facilitate your wellness journey, Healthiest Humans uses Profi as its operating platform. Please review Profi’s Privacy Policy below. Note that, as Profi makes clear, when it uses pronouns such as “we” or “us” or “our” it is referring to itself, and not to Healthiest Humans. When it refers to “our clients,” Profi refers to Healthiest Humans, among others. When Profi refers to “our customer’s clients” or “Clients,” it means Pioneers, among others.

 

                                              

Profi Privacy Policy

                        

Last Updated: September 1, 2023

                        

This Privacy Policy describes how Profi, Inc. (“Profi” or “we” or “us” or “our”) uses and discloses the Personal Information you provide to us or that we collect when you use our websites, including, without limitation, https://www.profi.io/, https://app.profi.io/, mobile applications, software, platforms and services (“Services”). Before using the Services or otherwise providing Personal Information to us, please review this Privacy Policy carefully.

                        

 

1. Note to Profi Customers and their Clients                    

This Privacy Policy applies to the Personal Information we may collect about our customer’s clients (“Clients”) in the context of providing the Services. Our treatment of Client Personal Information is governed by our agreements with our customers, including our Terms of Use, found here https://app.profi.io/page/terms (our “Agreement”). If any provision in our Agreement conflicts with any provision in this Privacy Policy, the provision in our Agreement will control to the extent of such conflict.

                        

If you are a Client of one of our customers (e.g., a therapist or group practice providing you services), we may retain your Personal Information on behalf of that customer. If you have questions about how we process your Personal Information, we encourage you to reach out to the appropriate customer. We may send any inquiries that we receive directly from you about our use of your Personal Information to that customer.

                        

 

2. How We Collect and Use Your Personal Data                        

“Personal Data” means any information relating to an identified or identifiable natural person (‘Data Subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identify of that natural person.

                        

In the course of our business and in providing our Services to you and with your consent, we may collect Personal Data directly from you and through our use of cookies. We may also collect your Personal Information from third-party sources, such as our business partners, affiliates and social media platforms (if you interact with us through your social media account). We will treat Personal Information collected from third-party sources in accordance with this Privacy Policy. We are responsible for the accuracy of the information provided by Customers & Clients.

                        

 

3. Personal Data We Collect                        

The categories of Personal Information we collect from you depend on your interactions with us. For example, we may collect:


●  Personal Data: Identifiers and contact information, such as your name, email address, mailing address, phone numbers, social security numbers, government-issued IDs (such as driver’s licenses), IP addresses, and unique identifiers such as your usernames and passwords. We collect this information directly from you and from third-party sources for the purpose of creating and managing your Profi account (“Account”), for communicating with you, verifying your identity, and providing our Services to you.

                                                                 
●  Professional Data: Professional and employment-related information, such as your Business name, calendar and scheduling information, and other information related to your Business. We collect this information directly from you for the purpose of administering your Account and providing you our Services, including facilitating your use of our Marketplace Service.         

                                                                        
●  Transactional information: data such as credit or debit card numbers and tax IDs. We collect this information directly from you in order to process your payments for our Services.                                                                             
●  Analog Data: Audio, electronic and visual information, such as your photograph or image, your voice and other similar information. We process this information to enable your use of our Marketplace Service.
                                                     
●  Usage Data: Internet and other electronic network activity information, such as your browsing history, search history, and your interactions with our Services and advertisements. We collect this information through our cookies to conduct business analytics in order to improve our business functionality and Services to you. Please review the “Tracking Technologies and Cookies” section below to learn more about our use of cookies and tracking technologies.
                                            
●  Commercial information: data such as products and services you have purchased from us. We collect this information to maintain customer records, identify trends in our customer relationships, and conduct business analytics.
                                                    
●  Customer Support Data: communication between Profi and You (inquiries submitted via the website, email, social media or chat).
                    

            
 

4. Purposes for collecting and Processing Your Personal Data
                                
Personal Data collected by Profi is Processed for the purposes established in the law or as described herein, including but limited for the following purposes:
            
●  Contractual Purpose: to maintain and service your Account, including to fulfill your orders, to confirm your orders, to send you requested product and Service information,
                                                    
●  Compliance Purpose: to comply with our legal, regulatory and risk management obligations, including establishing, exercising and/or defending legal claims.
                                                    
●  Analytical Purpose: to administer and improve our Services including measuring the effectiveness of the websites, diagnosing problems with our servers, and analyzing traffic;
                                                
●  Marketing Purpose: to send you newsletters and marketing communications;
                                                             
●  Communication Purpose: to contact You for administrative purposes such as customer service, address technical or legal issues related to the Service provided, or share updates and notifications about the Service;      

                 

● Security Purpose: To detect security incidents, to protect against malicious, deceptive, fraudulent or illegal activity, and to comply with our policies and procedures                        

Profi will not use Your Personal Data for any other purpose incompatible with the purposes outlined above or required, permitted or authorized by law.

                        

 

 

5. How We Share and Disclose Your Personal Information                        

We may share your Personal Information in the following circumstances:

                                                     
●  Publicly, but only with your permission: We may share your Personal Information publicly with your permission. For example, with your permission, we may publicly post your Business information through our Marketplace Services.
                                         
●  To Service Providers: We may share your Personal Information with companies that provide services to us, such as for hosting, third-party integrations, marketing and communication services, and payment processing (“Service Providers”). Our policy is to authorize these Service Providers to use your Personal Information only as necessary to provide services for us, and require that they not use or disclose your Personal Information for any other purpose.                      

                                                              
●  To third parties outside of Profi:                                                 

  • We may share your Personal Information with our parent and affiliate companies in order for them to provide analytics across the entire corporate family and for other internal business purposes.
    o From time to time, we may be required to provide Personal Information to a third party in order to comply with a subpoena, court order, government investigation, or similar legal process.

  • We may also share your Personal Information to third parties, such as law enforcement agencies, when we, in good faith, believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

  • To any other third party for whom you have given your consent for us to share your Personal Information.  

            

● In a corporate transaction: If Profi is involved in a bankruptcy, merger, acquisition, reorganization, or sale of all or a portion of its assets, we may share or transfer your Personal Information as part of any such transaction.

                        

 

6. EU Data Subject Rights
 

  • Right to Information: You have a right to be informed about the collection and use of your personal data. You can find all the related information in this Policy.               

  • Right to Access: You have the right to ask us for copies of your personal information. This right always applies.                                        

  • Right to Rectification: You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.           

  • Right to Erasure: You have the right to ask us to to erase Personal Data, unless Profi obliged to continue Processing Customer’s Personal Data under law or under a contract between the Customer and Profi.                        

  • Right to Restrict Processing: You have the right to ask us to restrict the Processing of his Personal Data in case the data is incorrect or incomplete or in case his Personal Data is Processed unlawfully.                    

  • Right to Data Portability: You have the right to ask us to provide the Customer or, in case it is technically feasible, a third party, his Personal Data, which the Customer has provided to Profi and which is Processed in accordance with Customer’s consent or a contract between the Customer and Profi.                    

  • Right to Object: You have the right to object to Processing his Personal Data in case there is a reason to believe that Profi has no lawful grounds for Processing the Personal Data.       

  • Right to withdraw Consent for the Processing of Personal Data: You are entitled to withdraw the consent granted for the Processing of Personal Data at any time. Withdrawal does not affect the lawfulness of the Processing conducted before the withdrawal.                    

  • Right to File Complaints: You have the right to file complaints regarding Processing of your Personal Data.

                        

 

7. Lawful Basis for Processing Your Information

                        

We are required to state the lawful basis under which we process the Personal Information of our end-users from the EU. Accordingly, the lawful bases upon which we process your Personal Information are as follows:

                                         
●  Processing is necessary for the performance or entry into a contract between Customer and Profi (GDPR article 6 (1) (b)), is Processing Personal Data for Contractual Purpose under contract entered into between Profi and Customer/ Client.


●  Processing is necessary for compliance with a legal obligation to which Profi is subject (GDPR article 6 (1) (c)). Profi is Processing Personal Data for Compliance Purpose under legal obligations to which Profi is subject to.


●  Processing is necessary for the purposes of the legitimate interests pursued by Profi. (GDPR article 6 (1) (f)). Profi is Processing Personal Data for Analytical or Personalization Purpose under legitimate interest.    

                     
●  You have granted a consent to the Processing of your Personal Data (GDPR article 6 (1) (a)). Profi is Processing Personal Data for Marketing Purpose under Customer’s consent. Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, we will obtain and rely on your consent in relation to the processing concerned;    

        
● Otherwise, we will process your Personal Information where the processing is necessary for compliance with a legal obligation to which we are a subject; or    

    
●  For the purposes of the legitimate interests pursued by us in promoting our business, providing the Service to our customers pursuant to or legal agreements with them, and in ensuring the security, accessibility and improvement of our Website and the Service and the development of new technology and services.
                                
 

8. Automated Decision Making
                                
Automated decision making refers to a decision which is taken solely on the basis of automated Processing of Customer’s Personal Data. This means Processing using, for example, software code or an algorithm, which does not require human intervention.
                                
Profi does not engage in automated decision making processes. If Profi starts making automated decisions, You are entitled to request human intervention or object to the decision by contacting our Data Protection Officer.
                                
 

9. Tracking Technologies and Cookies
                                
We use cookies and other tracking technologies (including from Google, Facebook and LinkedIn) to keep, and sometimes track, information about you on our Services. Cookies are small data files that are sent to your browser from a web server and stored on your computer’s hard drive. Cookies track where you travel on the Services and what you view. In doing so, a cookie may enable us to relate your use of the Services to your Personal Information.
                                
We use information gathered from these tracking technologies so that we can analyze trends, administer the Services, track users’ movements around the Services, and gather demographic information about our user base as a whole. We may combine information we obtain through tracking technologies with other Personal Information that we have collected about you in order to make our Services, communications and advertisements more targeted to your interests.
                                
If you reject cookies, you may still use our Services, but your ability to use some areas of our Services will be limited.
                                
 

10. Retention and Security
                                
We will retain your Personal Information for as long as your Account is active, as needed to provide you Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
                                      

We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, when you enter sensitive information (such as your login credentials), we encrypt the transmission of that information using secure socket layer technology (SSL). However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

                        

 

11. California Privacy Statement

                        

California residents have certain rights under the California Shine the Light law and the California Consumer Privacy Act (“CCPA”).

                

CCPA Disclosures: In general, within the preceding 12 months: 

                                                   
●  We have collected the categories of Personal Information listed in Section 2 above.
            
●  We have collected these categories of Personal Information directly from you, when you use our Services, and from third parties for the purposes described in Section 2 above.                                                         
●  We have disclosed the following categories of Personal Information for business purposes: Identifiers and contact information; professional and employment-related information; commercial information; transactional information; and internet and network activity information.
            
●  We have not sold your Personal Information.
                                
CCPA Privacy Rights: As of January 1, 2020, certain California residents are entitled to privacy rights under the CCPA. Customers who wish to exercise these rights should direct their requests to the customer who controls their Personal Information.

        
●  The right to know. You have the right to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information.    

    
●  The right to deletion. You have the right to request that we delete the Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.


●  The right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in anyway. If you exercise certain rights, understand that you may be unable to use or access certain features of our Services.
                                
You may exercise your right to know and your right to deletion. To exercise your right to know or your right to deletion, please contact us at privacy@profi.io.
                            

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to verify you are the individual about whom we collected Personal Information. If you have an Account with us, we will use our existing Account authentication practices to verify your identity. If you do not have an Account with us, we may request additional information about you to verify your identity. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

                        

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

                        

Shine the Light: Our California customers are also entitled to request and obtain from Profi once per calendar year information about any of your Personal Information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information please contact us at privacy@profi.io.

                        

 

12. Additional Information

                        

Information for Visitors from Outside of the United States: We are committed to complying with this Privacy Policy and the data protection laws that apply to our collection and use of your

 

Personal Information. By providing us with your Personal Information and using the Services, you acknowledge that your Personal Information will be transferred to and processed in the United States and other countries where we and our vendors operate. However, we make sure that your data is processed in a GDPR compliant manner.                        

 

Social Media Widgets: Our Services may include social media features and widgets, or interactive mini-programs that run on our websites (collectively referred to as “Features”). These Features may collect your IP address, which page you are visiting, and may set a cookie to enable the Feature to function properly. The Features are either hosted by a third party or hosted directly on our Services. Your interactions with these Features on a third-party site are governed by the privacy policy of the company providing it.                        

 

Links to Other Sites: The Services may contain links to other sites that are not owned or controlled by Profi. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects Personal Information. This Privacy Policy applies only to information collected by our Services

 

Children’s Privacy: Our Services are not directed to, and we do not knowingly collect any Personal Information from children.                        

 

Changes to This Policy: We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your Account) or by means of a notice on our websites prior to or upon the change becoming effective. We encourage you to review this page periodically for the latest information on our privacy practices.

                        

13. Contact Us

                        

For help with matters not related to exercising your rights under the aforementioned privacy laws, please contact us at help@profi.io.

                        

To exercise your rights, please, contact our Data Protection Officer: Vladimir Shidlovsky at privacy@profi.io

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