Updated: 10 May 2020
Changes to this Policy are effective as of the stated “Updated” date. Other than where we have sought such explicit consent from you, your continued use of our website after we make changes will constitute acceptance of, and agreement to be bound by, those changes, so please check the Policy periodically for any updates or changes.
At Vavanya we care about and respect your privacy and are committed to protect your personal information. We believe that you have a right to know our practices regarding the information we collect when you visit our website or subscribe to our services. We do not sell or rent your personal information to third parties for their direct marketing purposes without your explicit consent. We do not disclose it to others except as disclosed in this Policy or as required to provide you with the services as described on our website, or where we have a legal obligation to do so.
We collect information that you provide us or voluntarily share with us, and also some general technical information that is automatically gathered by our systems, such as IP address, browser information and cookies to enable you to have a better user experience and a more personalized browsing experience.
We will not share information that you provide us in the process of subscribing – including your contact information – except as described in this Policy.
Technical information that is gathered by our systems, or third-party systems, automatically may be used for website operation, optimization, analytics, content promotion and enhancement of user experience. In accordance with applicable local law, we may use your information to contact you – to provide notices related to your subscription, or offer you promotions and general updates, but we will not let any other person, contact you.
Your personal information may be stored in systems based around the world and may be processed by third party service providers acting on our behalf. These providers may be based in countries that do not provide an equivalent level of protection for privacy as that enjoyed in the country in which you live. In that case, we will provide for adequate safeguards to protect your personal information.
You can exercise your rights over your personal information, by contacting us at firstname.lastname@example.org.
By accessing and/or using our website and/or subscribing to our service you agree to the terms and conditions of this Policy, including to our collection, use, disclosure, processing and retention of your personal information.
In more Detail:
When you subscribe to our services on our website, we ask you to provide certain personal information, including a valid email address and username. We may ask you to provide or otherwise collect additional information that you provide us, such as, medical aid name and number, physical address, telephone number or other contact details, financial information (such as payment method and credit card number), and additional authentication information (such as your government issued ID, passport, or driving license, as permitted by applicable laws.
In addition, we collect information while you access, browse, view or otherwise use our website. In other words, when you access our website we are aware of your usage of our website, and gather, collect and record the information relating to such usage, including geo-location information, IP address, device and connection information, browser information and web-log information, and all communications recorded by browsers through our website. We use that information to enhance user experience, personalize your browsing experience as well as monitor our website for preventing fraud and inappropriate content or behaviour. We also collect supplemental information obtained from third parties such as demographic and navigation data, if applicable.
Additionally, to improve your online experience, we have implemented impression reporting. While you view our ads, we gather user Global Unique Identifier (GUI), HTTP request data like, user agent, IP, host, URL, location/continent from which request made, browser information, device used to access, operating system on device, operating system version on device.
Process of Information Collection
You directly provide us with most of the information we collect. You do this by filling out the subscription details on our website, as well as by sharing additional information voluntarily. This include confidential medical information and anything you choose to add to your user profile.
We also collect information from third party vendors and/or partners and/or other commercially available sources such as data aggregators and public databases, who provide us data to supplement the information we collect about you, in accordance with applicable laws. For example, we may receive fraud warnings from service providers for our fraud prevention and risk assessment efforts.
Do Not Track
Use of Collected Information
Where relevant under applicable laws, all processing of your personal information will be justified on the basis that:
- you have provided your consent for us to use your personal information for a specific purpose.
- our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with services which you have purchased/subscribed to).
- the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g. fraud prevention); or
- the processing is necessary to support our legitimate interests as a business (e.g. to improve our services to you), subject to your interests and fundamental rights and provided it is conducted at all times in a way that is proportionate.
We will use your personal information for the following purposes:
- to provide you with quality service and security, to operate our website and to perform our obligations to you. For example, we use the information collected from you to verify your identity. We also use this information to establish and set up your account, verify or re-issue a password, log your activity, enable your communications with our colleagues, provide customer support and contact you from time to time. The information is essential for the accurate fulfilment of our service offering to you.
- to ensure website integrity, prevent fraud and maintain a safe and secure environment. For example, we use your information to track and prevent fraudulent activities and other inappropriate activities and, monitor content integrity, conduct security investigations and risk assessments, verify or authenticate information provided by you, enforce our Terms of Service and comply with applicable laws. We conduct certain behavioural analytics to achieve the above objectives and in limited cases, if we detect activity that we think poses a risk to our community, or third parties, automated processes may restrict or limit your ability to use our website and/or services. If you would like to challenge any such decision, please contact us at email@example.com.
- to contact you, as requested by you or otherwise approved by you.
- to promote, advertise and to show you information that may be of interest to you, to organise and facilitate referral programs or other promotional activities or events.
- to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law.
We will ask for your consent before using information for a purpose other than those set out in this Policy.
- We use your personal information to send you direct marketing communications about our products, services or promotions that may be of interest to you or our related services. This may be via email, post, SMS, telephone, or targeted online advertisements.
- In most cases our processing of your personal information for marketing purposes is based on our legitimate interest, although some cases (such as where required by law) will be based on your consent. You have a right to prevent direct marketing of any form at any time – this can be exercised by following the opt-out link attached to each communication or by sending an email to firstname.lastname@example.org.
- We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevant to you, based on the information we have about you.
Retention of Information
We apply a general rule of keeping personal information only for as long as is required to fulfil the purpose for which it was collected. However, in some circumstances we may retain your personal information for longer periods of time. We may retain your information for the following purposes:
- as long as it is necessary and relevant for our operations, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge and
- in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our website terms and take other actions as permitted by law.
Sharing Personal Information with Third Parties
We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent.
We combine your personal information with information we collect automatically or obtain from other companies and use it to improve and personalize our content, services and advertising to you and/or to prevent fraud. If you do not wish to receive marketing communications from us, you can opt-out by sending an email to email@example.com.
We provide your personal details to third parties, only in order to operate our website, provide our services to you, fulfil obligations imposed on us by applicable laws and regulations, and prevent fraud, infringements and illegal activities, as detailed below:
- We share your information with service providers that provide us with services for the purpose of operating our website, opening and operating your account as well as providing ancillary services (example – payment vendors, CRM systems, forum hosting, community management services, IT SaaS services, mailing systems or technical consultants). Our contracts with these service providers do not permit use of your information for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your personal information and only process it in accordance with our instructions.
- We will share your information to law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe it necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to claims against us and to protect the rights, property, or personal safety of Vavanya, our customers, or the public.
- We share your information with payment processors, fraud detection agencies and similar third parties for the purpose of securing our website and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.
- Your personal information will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of Vavanya’s assets, acquisition, bankruptcy or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If we or substantially all of our assets are acquired by a third party, information held by us about our subscribers will be one of the transferred assets.
Personal Information Storage
Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions around the world, whose laws may differ from the jurisdiction in which you live. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.
When you visit our website, we use industry-wide technologies such as “cookies” (or similar technologies), which store certain information on your computer and which will allow us, among other things, to enable automatic sign-in to our website, make your browsing much more convenient and effortless and allow us to test user experience and offer you personalized browsing or promotions. By continuing to use our website, you are agreeing to our placing cookies on your computer or device in accordance with the terms of this Policy.
The following is a more detailed explanation of the types of cookies we use:
- Necessary cookies
Necessary cookies are essential and help you navigate our website. This helps to support security and basic functionality and are necessary for the proper operation of our website, so if you block these cookies, we cannot guarantee your use or the security during your visit.
- Functionality cookies
- Performance cookies
Performance cookies help us to understand the behaviour of users of our website. This allows us to continuously improve our website to provide the best information in support of our business objectives. These cookies are also used to help us understand how effective our website is. As an example, these cookies tell us which pages visitors go to most often and if they get error messages from web pages.
All of the information that these cookies collect is aggregated, to assist us to improve how our website works. Some of these cookies are managed by third parties, and you may refer to the third parties’ own website privacy notifications for further information.
In particular, we use Google Analytics cookies to obtain an overall view of user habits and volumes, and to help improve the overall experience on our website. Google Analytics is a third-party web analysis service provided by Google Inc, which uses performance cookies and targeting cookies. The information generated by these cookies about your use of our website (including your IP address) will be transmitted to and stored by Google Inc on servers in the United States.
Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
If you prevent these cookies, we cannot guarantee how our website will perform for you.
Preventing or Removing Cookies
We will store a cookie on your computer or device to remember us for next time, so that we can store your preferences and save you time on subsequent visits by eliminating the need to repeatedly enter the same data. You may set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. You should do this through the browser settings for each browser you use.
Please be aware that some of our services will not function if your browser does not accept cookies. However, you can allow cookies from specific websites by making them “Trusted Websites” in your internet browser.
The following links may assist you in managing your cookies settings, or you can use the ‘help’ option in your internet browser for more details:
Information on deleting or controlling cookies is also available at an independent resource www.aboutcookies.org (note that we cannot ensure its accuracy, completeness or availability). It is important to remember that many of our services may not function properly if your cookies are disabled. Cookies may, for example, in certain cases save you from the need to enter usernames and passwords and allow session continuity.
We take great care in maintaining the security of our website and your information and in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. In addition, we contractually ensure that any third party processing your personal information equally provide for confidentiality and integrity of your data in a secure way. However, the transmission of data via the internet is not completely secure, and although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website and therefore any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.
Subscribers to our services agree to keep their passwords in strict confidence and not disclose such password to any third party.
To exercise any of your rights in connection with your personal information or if you have any questions or comments concerning this Policy, we kindly ask that you please contact us at firstname.lastname@example.org.