Baymed Limited (“Baymed”, “we”, “us”, “our”)
is committed to safeguarding the Personal Information that we collect and process about you when you use our mobile
application Manna (“App”,
“Service”). This Privacy Policy applies to the Services and is intended to help you understand (i) how we collect
and process your information, including Personal Information when you use the Services; (ii) how we use and disclose
your Personal Information; (iii) how we protect your Personal Information; and (iv) the choices you may have
concerning your Personal Information. Your privacy and the security of your Personal Information are very important
to us. Please read this Privacy Policy carefully.
By “Personal Information” we mean information
relating to an identified or identifiable health information. This is also referred to as “personal data” under some
laws.
Baymed is the controller of your Personal
Information, i.e. we decide on the means and purposes of the processing of your Personal
Information. You can contact us as set out in the “Contact Us” section at the end of this Privacy Policy.
Information We
Process
We collect and process information about you
in various ways and from various sources when you use the Services. For example, you may provide Personal
Information directly to us (or to vendors or other unaffiliated entities who may be acting on our behalf), or we may
collect certain information about you automatically through your use of the Services.
Information You Provide to
Us
You may provide information, such as the
following categories of information, to us directly or to entities acting on our behalf.
Name.You may provide us with your full name, such as when you become a
subscriber to the Services, log into the Services, including through an integrated sign-in partner like Google
Sign-In, request customer support, or inquire about the Services.
User Credentials. When you
register for the App, you may be asked to provide credentials to allow you to access your account. These credentials
may include a username and password, or the user ID associated with the mechanism you use to sign in to the Services
(such as Facebook Login or Google Sign-In).
User Identifiers. We may
assign you one or more unique numbers or other identifiers that we use to identify you in our internal systems and
recognize you over time and across different devices.
Contact Information. You may
provide us with your email address in connection with signing up for our newsletters, signing in with an integrated
sign-on partner (such as Facebook Login or Google Sign-In), purchasing a product, or otherwise communicating with
us. You may also provide us with your telephone number, such as when you request a “text” message from us, reach out
to customer support, send us an inquiry about our products or Services, or place an order.
Payment Type. We receive
your payment type when you place an order in the App or on the Site.
Camera and Album
Access. The App requires camera and album access to set the profile avatar.
Personal
information. We do not collect any personal information from you. We do not require you to register
or provide any identifying information to use the App.
Information We Collect
Automatically
We or the providers on which we rely may also
collect information from you automatically when you use the Services. We may use cookies, software developments or
other technologies to collect such information as set forth in the “Software Development Kits, and Other
Technologies” section below. The information we collect automatically will depend on the Services
you access and use and your engagement with them. It may include:
Technical Information. We
may automatically collect information about your mobile device, computer or web browser, such as:
Device Model
Device Name
Operating System
Hardware Version
File and Software Names
and Types
Connection Information
including Browser Type, Language, and Time Zone
CPU type
Display height
Screen size
IP Address
Referring URL
Browser or Device
Characteristics
Operating System
Language Preferences
Country and General
Location Information
Usage Information. We may
automatically collect information regarding your interaction with our Services. For instance, we may collect your
engagement with the App, including any chatbots we may provide in the future. Such usage information may include the
following:
Details regarding
how frequently and when you use the Services.
Information
regarding your interaction with the Services. This may include what pages you visit in the App,
how long you spend on them, the links you click, features and portions of the App you interact with, and the
actions you take within the App (such as when you upload a photo, log data or make a purchase, or interact with
chatbot).
Information
regarding your interaction with our emails and messages. This may include whether you open the messages
or click links within them or forward the messages.
Information
regarding App Performance. This may include data on crashes and App functionality.
How We Use Your
Information
We may use your information, including
Personal Information, for various reasons depending on the information provided and your relationship with us. For
instance, we may use your information in the following ways, or as otherwise disclosed to you:
To provide you with the
Services.We use your information to provide you with the Services. For instance,
we use your information to fulfill our contractual obligations to you, to facilitate your orders and transactions,
and to establish, administer and manage your account.
We also use your Personal Information to
provide you with specific features of the Services that you request.
We also provide personalized data analysis
and digital content for educational purposes.
Our lawful basis for processing your Personal
Information for these purposes is the performance of our contract with you.
To Communicate With You. We
may contact you via email, push notification or other means with critical user or service updates, with
transactional messages, to inform you of technical issues or other information which is important to support the
Services. We may also contact you for purposes of customer engagement and support (including to receive feedback and
comments from you about the Services and inquire about any features you would like to see in future versions).
We will contact you to send you marketing
communications, ask for your satisfaction rate, or to offer you upgrades, promotions and additional products (our
products or third parties' products) that you may be interested in.
Our lawful basis for processing your Personal
Information for these purposes is the performance of our contract with you and/or our legitimate interests in
providing you with such communications. You may opt-out of receiving non-service messages at any time by contacting
us via email at support@themanna.app.
For analytics purposes. We
may use your Personal Information to evaluate your usage, preferences, and trends for statistical and analytical
purposes which we may use for marketing purposes, operations and product development. We may also use it to improve
the user experience and customize, measure and improve our Services and content.
Our lawful basis is our legitimate interests
in understanding, customizing and improving our Services.
To engage in marketing and
advertising.We may use your Personal Information to market to you and for
advertising purposes. This may include sending emails, text messages, push notifications, and in-app messages or
other communications and marketing or advertising products, services, features, offers, promotions, sweepstakes,
news, and events.
Our lawful basis is our legitimate interests
in engaging in such marketing and advertising and to grow our business. You may opt-out of receiving non-service
messages at any time by contacting us via email at support@themanna.app.
For compliance with law, to enforce
our rights and manage our business. We may use your Personal Information to carry out our obligations,
enforce our rights and manage our business, including to enforce the Terms of Service, EULA or any other agreement
between you and us.
We may also use your Personal Information to
prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or
required by law, including for auditing, fraud and security monitoring purposes.
Our lawful basis is the performance of our
contract with you and/or compliance with our legal obligations and/or our legitimate interests in managing our
business and detecting and preventing illegal or impermissible activity and monitoring security.
To Whom We Disclose Your
Information
We may disclose your information, including
Personal Information, to unaffiliated entities or permit them to access your information. For example:
To provide the Services and operate
and promote the Services. We employ or engage other companies and people to perform tasks on our behalf
and we may need to share your Personal Information with them to provide the Services to you, to respond to your
technical support questions, to provide customer support, to improve the user experience and/or to otherwise assist
us with providing the Services. We may also disclose your Personal Information to providers when we promote our
business, including for marketing and advertising purposes, and to conduct audience engagement and analytics related
to the Services.
To comply with legal requirements and
enable protection of rights. We may disclose your Personal Information at the request of law enforcement
or government agencies, in response to subpoenas, court orders, or other legal processes, or as otherwise required
by any law, regulation or legal order that we are subject to.
We may also disclose your Personal
Information to protect the rights, property, or safety of another person, to monitor for or prevent fraud, or to
investigate or prevent your violation of any contractual or other relationships with us or your suspected illegal or
unlawful activities.
As otherwise described to you or with
your consent. We may disclose your Personal Information to unaffiliated entities as otherwise described
to you or with your consent.
In connection with a business
transaction. If Baymed or any of its affiliates, subsidiaries or lines of business is merged, acquired,
divested, financed, sold, disposed of or dissolved, including through merger, consolidation, sale or divestiture of
assets, any information collected pursuant to this Privacy Policy, including Personal Information we may possess
about you, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of
that transaction or proceeding.
Vendors
Specific entities, among others, with which
we may share your information, including Personal Information, the information we share and the purposes for which
we share it are set forth below.
Vender
Data shared
Purpose
Vender's Privacy Policy
Adjust
Data relating to device model,
language and operating system
To optimize our advertising
strategy and provide more accurate ads and marketing communications to potential users
https://www.adjust.com/terms/privacy-policy/
AWS
All information you provide to us
and that we collect about you
To store your information when you
use our Services
https://aws.amazon.com/privacy/
Apple ( Apple, Inc.)
Payment and banking information
Personal identifiers
Fact of App launch if using Apple
ID to login
To collect and process payments for
subscription to the App
To permit login to App via Apple ID
https://www.apple.com/legal/privacy/en-ww/
Each of the vendors listed above is permitted
to use personal information shared (i) for purposes of providing the relevant services; (ii) to comply with
applicable law, regulation, or legal process; and (iii) to detect, prevent, or mitigate fraud or security
vulnerabilities. Each of the vendors listed above may be permitted to transfer information to other parties, such as
to subcontractors who are engaged to assist in providing the contracted for services. Baymed reviews the privacy
policies and terms of service (or other relevant contractual provisions) for each vendor to assess their privacy and
information security practices.
Software Development Kits, and
Other Technologies
When you use the Services, we and our vendors
may use cookies or similar technologies (such as software development kits (SDKs)) to collect or receive certain
information about your use of the Services. Some of these technologies that we use are “strictly necessary” or
“required” for the Services to function. We also use analytics tools, such as to help us measure traffic and usage
trends for the Services. Such analytics tools may provide data, such as information about your engagement with the
Services which may be used to provide content, analysis or functionality or to measure and analyze engagement with
the Services.
Retention of Your Personal
Information
We will retain your personal information for
as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of
satisfying any legal, regulatory, accounting or reporting requirements. To determine the appropriate retention
period for your Personal Information, we will consider the amount, nature, and sensitivity of the Personal
Information, the potential risk from unauthorized use or disclosure, the purposes for which we process Personal
Information and whether we can achieve those purposes through other means, and applicable legal requirements.
If you choose to delete the App from your
device (note that deletion of the App does not mean that your account is deleted – please contact us
at support@themanna.app if you wish to delete your account) or your
account becomes inactive, we will retain your Personal Information for a period of five (5) years in case you decide
to re-activate the Services or re-install the App. We have determined that this retention period is appropriate
taking into account the factors described above and based on our experience with our App users, in order to secure
your smooth experience with our App functions.
You may delete your account and erase your
Personal Information at any time in our App or contact us at support@themanna.app. Please note that if you choose to do this, your
Personal Information will not be recoverable should you later create another account.
Please note that, in all cases, we may need
to retain Personal Information for a longer period where we are subject to legal or regulatory requirements to do
so.
Information Security
We believe that the largest threat to
security and privacy is that someone could get your device and account information. You can help keep your Personal
Information secure by properly selecting and protecting passwords, not sharing passwords with others, and preventing
others from using your mobile device, laptop or other devices that can access the Services.
Links
Although the Services may contain links to
other websites or services, we are not responsible for the privacy policies and/or practices on those websites or
services. The information practices of those websites or services are not covered by this Privacy Policy. You should
read the privacy policy stated on that website or service before sharing your Personal Information with any websites
or services. We are not responsible for the privacy policies or other sites and encourage you to read their privacy
policies.
Note About Children and the
Permissible Age of Use of the Services
United States. Children are
not eligible to use the Services and we ask that people under the age of 13 do not submit any Personal Information
to us. If you are aware of anyone under 13 using the Services, please contact us at support@themanna.app and we will take the required
steps to delete their Personal Information and (or) delete their account.
European Economic Area, United
Kingdom and California. You must be at least 16 years old to use the Services. If you are aware of anyone
younger than 16 using the Services, please contact us at support@themanna.app and we will take steps to delete their Personal
Information and (or) delete their account.
Your Choices: if you
wish to withdraw your consent for us to contact you to send you marketing or commercial communications, you may
contact us via email at support@themanna.app.
Your Rights to Your Personal
Information
You may have rights in relation to your
Personal Information, including the right to delete your Personal Information (subject to certain limitations);
access the Personal Information you enter into the Services; and ask us about what kind of Personal Information we
have about you. These rights may depend on the country and state of your residence.
Please contact us at support@themanna.app for additional
information.
For individuals in the European Economic Area
(“EEA”) or United Kingdom (“UK”), please see “General Data Protection Regulation (“GDPR”)”
below.
For individuals who are California residents,
please see “Your California Privacy Rights” below.
General Data Protection Regulation
(“GDPR”)
If you are in the EEA or UK, you have certain
rights regarding the Personal Data we have about you that you can exercise in certain circumstances. The GDPR
defines “Personal Data” as any information which is related to an identified or identifiable natural person. These
rights are to:
Access the Personal Data
we have about you.
Correct the Personal Data
we have about you.
Restrict the processing
of your Personal Data
Have your Personal Data
deleted (i.e., the “right to be forgotten”)
Object to the processing
of your Personal Data
Not be subject to
automated decision-making.
Take your Personal Data
somewhere else (i.e., the right to portability)
Where you have provided your consent to the
processing of your Personal Data for a specific purpose, you have the right to withdraw your consent for that
specific processing at any time. However, please note that if you withdraw your consent, we may no longer be able to
provide you with our Services. You may contact us at support@themanna.app to make any of these requests. We may require you
to provide proof of your identity before we are able to fully review your request. Please note that, where we
determine that we can grant your request, we will do so as soon as possible, but it may take us more time in some
cases, for example for full erasure of your Personal Data stored in our backup systems. There may be situations
where we are not required to comply with your request and we will let you know if one of those situations arises.
Our lawful basis for processing your Personal
Data is typically going to be your consent, but we also may process your Personal Data because of a legal
obligation, performance of a contract with you, or because we have a legitimate interest in doing so.
We use intelligent algorithms that provide
certain App functions, such as the recommendation of habits that may be suitable to your living habits. The more
Personal Data that our intelligence algorithm can work with, the more accurate recommendations you get from the
algorithm.
We hope that you don’t ever have an issue
with the way that we handle your Personal Data, but if you do, contact us at support@themanna.app to let us know so that we can
make it right. If you’re ever not happy with the way that we handle your request, you can file a complaint with your
local supervisory authority.
Your California Privacy
Rights
If you are a resident of California, you may
have certain rights under the California Consumer Privacy Act (“CCPA”).
Right to Know. You may have
the right to know how we have collected, used and disclosed your Personal Information. Specifically, you may have
the right to know:
The categories of
Personal Information we have collected about you.
The categories of sources
from which we have collected your Personal Information.
The business or
commercial purpose for which we collect, sell or share your Personal Information.
The categories of third
parties to whom we have disclosed your Personal Information.
The categories of
Personal Information that we have sold or shared about you and the categories of third parties to whom it was sold
or shared.
The categories of
Personal Information we have disclosed about you for a business purpose and the categories of persons to whom we
have disclosed it.
In addition, you may have the right to know
the specific pieces of Personal Information we have collected about you. Subject to certain limitations, you may
request that we provide this information dating back to November 1st, 2023.
Right to Make a Deletion
Request. You may have the right to request that we delete your Personal Information that we have
collected or received. Subject to certain exceptions, we must delete your Personal Information and direct our vendor
to delete your Personal Information.
Right to Correct Inaccurate Personal
Information. You may have the right to request that we correct inaccurate Personal Information about you,
taking into account the nature of the Personal Information and the purposes of the processing of the Personal
Information.
Right to Opt-Out of Sales of Personal
Information. You may have the right to opt-out of the sale of your Personal Information.
Right to Opt-Out of Sharing of
Personal Information. You may have the right to opt-out of us sharing your personal information for
cross-context behavioral advertising purposes.
Right to Limit Use and Disclosure of
Sensitive Personal Information. Subject to certain exceptions, you may have the right to limit our use
and disclosure of your sensitive personal information.
Right to Non-Discrimination.
You have the right not to be discriminated against by us for choosing to exercise your rights under the CCPA.
How to Exercise Your California
Privacy Rights. You may email us at support@themanna.app with “CCPA Privacy Rights” in
the subject line and in the body of your message to exercise these rights.
Shine the Light. If you are
a California resident who provides Personal Information in obtaining products or services for personal, family or
household use, California Civil Code Section 1798.83 (“Shine the Light Law”) permits you to request in writing and
obtain from us, once per calendar year, data about the Personal Information we shared, if any, with other third
parties for their own direct marketing purposes. To make such a request, please contact us at support@themanna.app and write
"Shine the Light - Request for California Privacy Information" for the subject of your message. We will send you a
reply email within 60 days containing the requested information once we confirm your request. Not all the shared
Personal Information is covered by the Shine the Light Law requirements and therefore only Personal Information
which is covered will be included in our response.
Changes to the Privacy
Policy
We may update this Privacy Policy
periodically. We will post the changes to this policy in our App and update the “Last Updated” date at the top of
the Privacy Policy. We encourage you to review our Privacy Policy to stay informed. If you disagree with the changes
to this Privacy Policy, you should discontinue your use of the Services. By accessing and/or using the Services, you
agree that we may collect, process, and share your information (including Personal Information) consistent with this
Privacy Policy.
Contacting Us
Any questions in respect of this Privacy
Policy or other questions should be sent to the following email address: support@themanna.app.
If you would like to: access, correct, amend,
or delete any Personal Information we have about you, register a complaint, or simply want more information, contact
us at support@themanna.app.
Versions in other languages than
English
The original version of this Privacy Notice
is written in English. To the extent a translated version of the Privacy Notice is in conflict with the English
version, the English version shall prevail.