Data Privacy Policy

Introduction

At Sustain Health, a women's health platform dedicated to empowering women to improve their lifestyle, we prioritise building trust with our community. Protecting your privacy is a cornerstone of that trust. This Data Protection Policy outlines how we collect, store, process, and protect personal data in compliance with relevant data protection laws, including the General Data Protection Regulation (GDPR), the UAE Federal Decree Law No. 45 of 2021 Regarding the Protection of Personal Data, the UAE Federal Law No. 2 of 2019 Concerning the Use of Information and Communication Technology (ICT) in Health Fields, and other applicable legislation. As our offerings evolve, this statement is regularly reviewed and updated to remain relevant and comprehensive. We are committed to safeguarding your personal data by fostering a culture of knowledge, professionalism, and ethical responsibility among our employees and contractors. Additionally, we implement robust measures to protect your information.

This policy covers how we process your personal data if you use our Application or order any Services. In these instances, we are the controller of your personal data (which means we decide what information we collect and how it is used).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Application. By accessing or using the Application you agree to this Privacy Policy.

This policy may change from time to time. Your continued use of the platform after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Purpose of Data Collection

We collect personal data for the purpose of delivering our services, which include providing personalized lifestyle solutions, engaging with users through our platform, and ensuring an optimal user experience. Personal data may include, but is not limited to, your name, email address, phone number, health-related information, and lifestyle data.

Types of Personal Data Collected

Personal Identification Information: Name, email address, phone number, date of birth, or demographic information
Lifestyle and Health Information: lifestyle information, and other health-related data you provide.
Usage Data: Data on your interactions with our app, such as features you use, session times, and browsing behavior.
Demographic Information: Age, gender, and location.
Tracking Technologies: Cookies and similar technologies to track your usage of the app and enhance your experience.

Legal Basis for Processing Personal Data

We process your personal data based on the following grounds:

Consent: When you provide your explicit consent, such as by subscribing to newsletters or using our platform.
Legitimate Interests: For purposes that are compatible with your expectations, such as improving our platform, conducting research, or analyzing trends.
Legal Obligation: When required to comply with legal requirements, such as providing information to law enforcement or regulatory bodies.

Sensitive information is only processed when necessary, with your explicit consent, and in compliance with legal requirements. You may share this data directly with us by subscribing to newsletters, requesting information or services, or accessing our offerings. Additionally, some data may be collected through tracking cookies when you interact with our website.

Use of Personal Data

Personal data will be used for:

Providing you with services including coaching and insights based on your data. Your data will be shared between Experts on the Sustain Health Application (only) to provide an optimal user experience and service.
Providing and improving our services, products, and user experience.
Communicating with you about updates, promotions, and important notifications related to your account.
Analyzing usage patterns and trends to enhance our offerings.
Responding to your queries, requests, and feedback.
Complying with legal obligations and protecting the rights and safety of users.

Where Is Your Personal Data Stored?

Sustain Health processes your personal data through three primary methods: in-house at our data center, online with leading providers, and via cloud-based applications developed by carefully selected third parties for specific products and services. Our servers and service providers may be located in the United States, United Kingdom and/ or Europe. By submitting personal information to us, you understand that we may transfer your personal information to a country foreign to you. Medical reports or any data related to health services provided in the UAE will not be stored or transferred outside the country. The laws that apply to the use and protection of personal information in other countries or jurisdictions in which we transfer or process personal information, may be different from the laws and protections in your country. We adhere to a strict security policy to ensure your personal information is protected. When partnering with online providers, we collaborate with industry leaders or organizations that comply with local laws and maintain robust security and privacy standards. The length of time we retain your data depends on the purpose it serves. For ongoing products and services, your data is stored as part of a continuous process until that process concludes. In all other cases, your data is promptly deleted once it is no longer needed unless legal requirements mandate a longer storage period.

Data Storage & Third Party Processors

Sustain Health will not sell, rent, or share your personal data with third parties for their independent business purposes. However, we may share your data with trusted third-party service providers to help us deliver our services, such as cloud storage providers or analytics services. These third parties are contractually bound to use your data only for the purposes outlined in this policy and must adhere to data protection standards at least as strict as our own. These third parties are also contractually obligated to notify us of any data breaches or non-compliance, and are liable for any damages resulting from such breaches. In certain circumstances, we may need to share your data with authorities or other parties to comply with legal requirements or protect vital interests.

Your Data Rights

We want you to be in control of your information, so we provide you with the following tools:

The right to access: You have the right to request copies of your personal data. We may charge you a small fee for this service.

The right to rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that We complete the information you believe is incomplete.

The right to erasure: You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.

Correction/Rectification. The right to request correction of inaccurate personal information maintained by the business.

The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions. You may withdraw your consent to the processing of your information at any time by stopping to use the Application.

Object to Processing: Object, on grounds relating to your situation, to our processing of personal data concerning you which is (i) necessary for the performance of a task carried out in the public interest, (ii) carried out in the exercise of official authority vested in us, or (iii) processed by us on the basis of our legitimate interest. In this case, where applicable, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves to assert, exercise or defend legal claims.

Non-Discrimination. The right not to be discriminated against for exercising any of the rights conferred at law.

Complaints. The right to lodge a complaint with the appropriate governmental authority.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

General Data Protection Regulation

The General Data Protection Regulation (GDPR) grants residents of the EEA specific rights regarding your personal data, and Sustain Health is committed to upholding these rights. These include the right to be informed about how your data is collected and used, the right to access your data, and the right to request corrections if your information is inaccurate. Under certain conditions outlined in the GDPR, you may also request the deletion of your personal data, limit how it is processed, or object to its processing. Additionally, you have the right to oppose automated decision-making and profiling, as well as the right to transfer your data to another service provider (data portability). If you believe your rights have been violated, you also have the right to file a complaint with the Data Protection Authority. Sustain Health is dedicated to ensuring your data is handled transparently and in accordance with all GDPR regulations.

Security Measures

We take the security of your personal data seriously and implement industry-standard technical and organizational measures to protect it from unauthorized access, disclosure, alteration, and destruction. These measures include encryption, secure servers, firewalls, and regular security assessments.

Marketing

We may send you updates, promotions, and information about our services that we believe could enhance your experience with the App by providing relevant and timely content.

If you have agreed to receive marketing communications, you can opt out at any time. To update your preferences or unsubscribe, visit the Settings section in the App or contact us at app@sustain.health

Please note that opting out of marketing communications may result in missing updates about new features, offers, or improvements to the App that could benefit your experience.

We will never share your personal data with third parties for advertising purposes. Any data shared with trusted partners will be strictly limited to providing services or promotions related to your use of the App, in accordance with your privacy preferences.

For assistance or questions about your marketing preferences, feel free to reach out to us at app@sustain.health

Cookies and Similar Technologies

We do not use cookies on the App to track personal data, device information, or IP addresses. Any cookies that may be used are strictly for gathering anonymous, aggregated data for statistical purposes only. As such, this privacy notice does not include a separate cookie policy.

Privacy Policies of Other Websites

Our Website may contain links to other websites. Our Privacy Policy applies only to our website, so if you click on a link to another website, you should read their Privacy Policy.

Privacy Statement

We will update this statement whenever changes are made. If any significant updates occur, particularly regarding how Sustain Health uses your personal data, we will notify you either by prominently posting the changes on our website or by sending you a direct notification.

In the event of a conflict between this privacy statement and the terms of any agreement between you and Sustain Health, the terms of the agreement will take precedence. Additionally, specific privacy statements may apply to certain Sustain Health entities, and these will be provided to you when relevant to the processing of your personal data.

Data Breaches

In the event of a data breach, we shall ensure that our obligations under applicable data protection laws are complied with where necessary.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: app@sustain.health

Created: December 2024