INTRODUCTION

This privacy policy (hereinafter “Policy”) provides information on how your personal data is processed in connection with your wellness journey. We reserve the right to change this Policy. The latest version of this Policy will always be available on our official website(healinggilead.com), and we indicate the last update date of the Policy at the very top of this Policy.

Data Controller

The data controller for processing your personal data in connection with your wellness engagement is Healing Gilead. For any matters or questions related to data protection, please contact us at hello@healingilead.com

Data Protection Officer

To contact our data protection officer, please contact us at hello@healingilead.com

DATA PROCESSING

We process your personal data for the following wellness-related purposes:

(a) Administer and manage your wellness journey with Healing Gilead to ensure a personalized and effective experience.

(b) Enable proper fulfillment of wellness-related services and duties tailored to your health goals.

(c) Facilitate access to Healing Gilead wellness facilities and resources.

(d) Implement necessary measures for financial transactions related to your wellness programs.

(e) Evaluate and enhance your health progress through personalized performance assessments and improvement plans.

(f) Ensure effective communication regarding your wellness journey within Healing Gilead.

(g) Keep records of your achievements and provide support through any wellness-related concerns.

(h) Maintain accurate records of your wellness education and training.

(i) Organize, invite, and provide access to wellness events designed for your health and well-being.

(j) Manage, provide, and deliver wellness benefits and services in line with your health objectives.

(k) Conduct voluntary surveys to gather insights for continuously improving our wellness offerings.

For the purposes outlined in 2.1, we process personal data of individuals engaging in wellness programs with Healing Gilead.

For the purposes outlined in 2.1, we process, in particular, the following categories of personal data about you:

(a) Personal identification data (name(s), date of birth, etc.).

(b) Contact information (address, email, phone number, emergency contacts).

(c) Information on wellness-related education, skills & professional experience.

(d) Wellness engagement information (terms and conditions, wellness goals, progress tracking).

(e) Information about your wellness-related training.

(f) Information about booked and attended wellness events.

(g) Wellness performance information (assessments, goals, progress tracking), improvement plans, and related correspondence.

DATA COLLECTION AND PROCESSING

In most cases, we collect personal data directly from you through various channels, such as wellness assessment forms, health history questionnaires, and other relevant documents. This may include information provided during the onboarding process, consultation sessions, or through forms completed at different stages of your engagement with Healing Gilead. Additionally, we may obtain processed or stored personal data from external sources, including publicly accessible databases or health authorities.

Legal Basis for Data Processing

We process your personal data based on the following legal grounds:

(i) To fulfill the wellness engagement contract with you.

(ii) To comply with applicable legal obligations, such as health and safety regulations.

(iii) To pursue legitimate interests related to enhancing your wellness experience, ensuring effective program administration, and improving our services.

(iv) In some instances, special categories of data, such as health or medical information, may be processed:

  • To fulfill wellness-related obligations, including health and safety purposes.
  • Based on your explicit consent.
  • If the information is required to protect your health in an emergency.

Data Storage Period

Personal data will be retained for a defined period, considering local legal requirements in the region where you are engaged with Healing Gilead. We adhere to applicable data retention regulations to ensure the appropriate handling of your information.

Data Recipients

For the technical and administrative handling of your personal data, we engage reputable data processors who are carefully selected, maintain confidentiality, and are bound by our instructions. Our primary categories of data processors include:

  • Wellness program administrators
  • Health insurers
  • IT and software providers and consultants
  • Professional consultants specializing in health and wellness
  • Hosting service providers

DATA SHARING AND SECURITY 

We prioritize the confidentiality of your personal data and adhere to strict practices:

We may share your personal data with competent authorities, such as health and wellness regulatory bodies or when required by law. In certain instances, your data may be transferred to third countries outside the local region, ensuring appropriate safeguards are in place to protect your rights.

 Data Security Measures

To protect personal data against various risks, we implement robust technical and organizational measures. All data you provide and we collect is stored on secure servers. If you have a password for our platforms, it is your responsibility to keep it secure and confidential.

YOUR RIGHTS 

Subject to applicable law, you have the following rights:

(a) Right to Access:

  • Obtain information on the origin, categories, storage duration, recipients, and purpose of your personal data processed by us.

(b) Right to Rectify, Erase, or Restrict Processing:

  • Request rectification, erasure, or restriction of processing of your personal data.

(c) Right to Withdraw Consent:

  • Withdraw your consent to processing at any time.

(d) Right to Data Portability:

  • Request assistance in transferring some of your information to other entities.

(e) Right to Object:

  • Object to the way we process your personal information.

(f) Right to Lodge a Complaint:

  • Lodge a complaint with relevant authorities regarding our handling of your personal data.

If you would like to exercise any of your rights listed above, please contact us at hello@healingilead.com.

Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavor to respond within an appropriate timeframe and, in any event, within any timescales required.

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