Last Revised: February 1, 2023
This Healtheek wellness Privacy Policy (“Policy”) applies to Healtheek wellness (powered by Lucentik private limited) , Inc. and its subsidiary and affiliate entities worldwide that link to and rely upon this Policy. It applies to all information collected by Healtheek through its online properties and mobile applications (the “Sites”) where this Privacy Policy is posted. Some Healtheek wellness websites also link to their own territory-specific online privacy notices, which may contain additional information and disclosures to address local requirements. It also applies to information that Healtheek wellness collects through offline methods. Unless otherwise indicated, this Policy does not apply to an Healtheek Wellness Independent Distributor’s (“Distributor” or “Healtheek Executive”) collection or use of information obtained by the Executive directly from you or from sources other than Healtheek wellness, unless it then is shared with and retained by Healtheek wellness.
The purpose of this Privacy Policy is to inform you of the kinds of information we may collect, how such information may be used, with whom such information may be shared, your choices regarding the collection, use and sharing of such information, your ability to access and correct such information and the security procedures we use to protect this information.
1. What information does Healtheek wellness collect?
Healtheek wellness limits the collection of personal information to what is relevant to the purposes of collection whether directly or through third parties acting our behalf, and we always collect personal information using lawful and fair means, consistent with the jurisdiction governing the collection of personal information.
Information You Provide Us Directly
At different occasions, you may provide information directly to Healtheek wellness, such as your first and last name, mailing address, telephone number, email address, credit card information, banking information, and biographical information (including, but not limited to, date of birth, and marital status). For example, you may provide us with information when using the Sites or when becoming an Healtheek Executive or an Healtheek prime Member (“Prime customer”). If you do not provide us with the requested information, in some cases, we will not be able to provide you the service you have requested.
If you disclose to us any information of another individual, you are required to have secured the appropriate consent of that individual for disclosing such information to us.
Information About Your Device and Your Use of the Sites
We may gather certain information automatically, such as Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamps, your Site activity (including the Site content you view, mouse movements, mouse clicks, taps, swipes, and information you view), and/or clickstream data for purposes such as analysing trends, administering the Sites, improving the function and content of the Sites, and enforcing our Terms. We use standard Internet technologies, such as cookies, web beacons, session replay/screen capture, and similar technologies to collect this information, as explained below in the section on cookies.
We may also collect precise information about your location, such as your mobile device’s GPS coordinates, cell tower information and/or Wi-Fi signals. Healtheek wellness may use this information to personalize your experience in connection with your use of the Sites, Wellness Clubs, or other Healtheek wellness products and services. If you do not want Healtheek wellness to collect and use your specific geolocation information, you can disable the location features on your device. Check your device manufacturer settings for how to do so.
Information from Third Party Sources
We may receive additional information about you from public and commercially-available sources and other third parties. Executives may also share information about you with Healtheek Wellness. If you access third-party services, such as Facebook, Google, or Twitter through the Sites or all other social platforms, to login to the Sites or to share information about your experience on the Sites with others, we may collect information from these third-party services. We may combine all of the information we collect and receive about you, both online and offline, and use or disclose it in the manner described in this Privacy Policy.
We may also receive the following types of personal information about you from our Executives, depending on what you choose to provide to them: name, contact information, payment information, and wellness information.
2. How does Healtheek Wellness use my Information?
We use the information we collect about you for a variety of purposes, including: providing you with the products, services and support you request; processing your transactions and shipping your orders; communicating with you about your account or transactions, changes to our policies and other administrative matters, or your questions and comments; to better understand your interests in order to provide you with promotional information, relevant content, surveys, questionnaires, and other materials; improving our products, services and operations; and ensuring compliance with our company policies and rules and the law, or as we believe is necessary to protect, enforce or defend the legal rights, privacy, safety or property of ourselves and others. We also use this information to validate sales made by Healtheek Executives, to help Healtheek executives search for, communicate with and validate customers in our systems, and for Healtheek wellness compliance purposes. Healtheek Wellness or its authorized third parties may contact you directly for these purposes using various contact methods described below.
Healtheek wellness may also use this information to support the operation of the Prime Customers and Executives, and to maintain proper functioning of the Healtheek Sales & Marketing Plan. For example, information about Prime Customers may be used to support, calculate and track your product discount and to provide you with information on special promotions. Information about Healtheek Executives may be used to support, calculate and track discounts, earnings and bonuses, to issue payments to and report income to taxing authorities, to provide training, and to ensure compliance with applicable law and company policies, plans and agreements, including the Executives Application and Agreement.
We may retain your information for as long as needed to: provide you services; fulfil other legitimate business needs, such as maintaining the proper function of the Sales & Marketing Plan; fulfill our compliance and legal obligations; and resolve disputes and enforce our agreements, including the Executives Agreements.
3. With Whom does Healtheek Wellness Share my Information?
Affiliates and Partners
We may share any of the personal information described above in Section 1 with our affiliates (companies that control, are controlled by, or are under common control with, Healtheek wellness) as well as select partners. Examples of how these entities may use your information include making predictions about your interests and providing you with special offers, promotions, advertisements, and other materials.
Vendors & Service Providers
We may share any of the personal information described above in Section 1 with vendors and service providers that perform functions on our behalf. Examples of such functions include fulfilling orders, delivering packages, email administrative functions, processing credit card payments, providing customer service, and for market research. Vendors and service providers must handle your personal information in accordance with Healtheek wellness instructions and are prohibited from using or disclosing your personal information for any other purpose.
Healtheek Independent Executives
If you are an Healtheek Executive, Prime Member, or Customer, we may share your information with other Healtheek Executives, including without limitation as part of a Lineage Report which contains information (such as name, contact information, level or rank, and volume and sales statistics) on other Distributors/executives and Prime customers in a Healtheek Executives downline. (The downline organization consists of all Executives and Prime Customers that were personally sponsored by a particular Executive, and in turn, all other persons sponsored by the subsequent Executives.) To the extent the Lineage Report contains data from persons outside of the United States, we have taken appropriate measures to protect the data in accordance with applicable law. Lineage Reports are provided to Executives in strict confidence and for the sole purpose of supporting the Executives in further developing their Healtheek Wellness businesses, including for use in marketing tools and platforms.
We may share your information with Executives to offer and provide you with products and services, and these Executives may further share your information as described in their privacy policies. For example, if you use some of our Sites, such as www.www.com--------------------------, your information may be shared with one or more Executives servicing those sites. Similarly, if you participate in a Wellness Club, we may share your information with any of the Executive operating the wellness Club. We may also share your information with Executives so that they can provide you with a more personalized experience, such as recommending products and services that are most relevant to you. Healtheek Executives who receive your information are bound by the terms of their Executive Agreement and the privacy and data protection covenants contained therein. Some of these Executives may be based in countries that do not offer the same or a similar level of privacy protection as is available in your own country.
If you operate a Wellness Club, we may share the location of that Club with Prime Members, Customers, and other Healtheek Executives.
Legal & Compliance Disclosures
We may also disclose your information: as required by law, such as to comply with a subpoena, legal proceedings, or similar legal process, including disclosure to authorized third party auditors; or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate or prevent fraud, or respond to a government request.
Business Transitions
We may share your information if Healtheek wellness is involved in a merger, acquisition, or sale of or transfer of assets, or in the unlikely event of bankruptcy.
Other Parties with Your Consent
In addition to the sharing described in this Privacy Policy, we may also share information about you with third parties for any other purpose disclosed to you at the time we collect the information or pursuant to your consent or direction.
4. How will Healtheek Wellness Communicate with me?
Healtheek Wellness may communicate with you via email, postal mail, telephone, text message, or other means on a regular basis to provide requested products and services and/or in regards to issues relating to your Healtheek business (if you are a Executive). In order to validate customer sales, Healtheek wellness may communicate with you via email, postal mail, telephone, text message, or other means on a regular basis (if you are a Customer).
Additionally, you may receive periodic information on Healtheek Wellness business, products, services, special deals, and the Healtheek Family Foundation through various communication means as described above. He and Preferred Members may manage certain communications within their MyHealtheek subscription centre. In addition, you may manage these kinds of communications by following the instructions provided in the communication or by contacting us at +916281861840.
5. Is my Personal Information Secure?
We take reasonable steps to ensure that the personal information we collect about you remains accurate, timely and secure. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure and while we strive to protect your personal information, we cannot guarantee or warrant its complete security.
6. How can I Access or Correct my Information?
Healtheek Wellness respects your control over your information. In some instances, you may visit one or more of our Sites to verify and update certain information (for example, certain Executive and Preferred Member account information on Healtheek). Upon request, we will confirm whether we hold or are processing information that we have collected from you. You have the right to amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. Under certain circumstances we will not be able to fulfil your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation. Our typical response time for requests is 30 days. In order to make personal information requests, please contact us online or offline, using the information provided below.
Submit your request here: ………………………………………..link
7. International Transfers
The Sites are headquartered in the India. Please be aware that information you provide to us or that we obtain as a result of your use of the Sites may be collected in your country and subsequently transferred to another country in accordance with applicable law. Using the Sites demonstrates your consent to the processing of information as described in this Policy.
8. Children’s Information
The Sites are general audience web sites that are not directed to children younger than 13. We do not knowingly collect, use or disseminate any personal information from children under the age of 13, unless permitted by law. If you believe we may have collected personal information from your child on the Sites, please contact us at [email protected] and we will make reasonable efforts to delete it from our records, when required by law.
9. Cookies and Tracking
Healtheek wellness, as well as certain third parties that provide content and other functionality on our Sites, uses cookies, web beacons, session replay/screen capture, and other similar technologies for various purposes, including to analyse trends, administer the website, track users’ movements around the Sites and to gather demographic information about our user base as a whole.
Cookies are small pieces of information that are stored on computer hard drives. A cookie enables the entity that put the cookie on your device to recognize it across different websites, services, devices, and browsing sessions. For example, we may use cookies to recognize you when you return to the Sites in order to provide you with a better user experience. We may allow third parties to use cookies on the Sites but we do not control the use or contents of third party cookies. Web browsers often allow you to configure the browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. If you elect to reject cookies, please note that you may not be able to take full advantage of the features and functions of the Sites. To learn more about cookies and how to manage them, please visit http://www.allaboutcookies.org/.
Web beacons and similar technologies are small bits of code, which are embedded in web pages, advertisements, and e-mails, that communicate with third parties. We use web beacons, for example, to count the number of users who have visited a particular web page, to deliver or communicate with cookies, and to understand usage patterns. We also may include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
There are other local storage and internet technologies, such as Local Shared Objects (also referred to as “Flash cookies”), HTML5 local storage and embed scripts, which can operate similarly to the cookies discussed above. Please note that these technologies are distinct from cookies, and you may not be able to control them using standard browser tools and settings. For information about managing Flash cookies, please click www.adobe.com/privacy.html. To learn more about Adobe analytics and to opt out, click www.adobe.com/privacy.html.
We may use Bluetooth beacon technology to improve the Wellness Club experience. Mobile devices that have enabled Bluetooth can receive a signal when in range of a beacon. The signals will not be received unless the user has turned on Bluetooth, installed an Healtheek wellness mobile application and enabled push notifications. The beacon functionality may allow for notifications, customer check-ins, and payments. You can disable the beacon functionality in the app’s settings.
10. Do Not Track
Web browsers may allow you to send “Do Not Track” requests. We do not currently take actions to respond to Do Not Track signals because there is no current industry standard concerning what, if anything, websites should do when they receive such signals. We continue to review new technologies and may adopt a standard if and when one is created.
11. Online Advertising
We may display advertising on our website and partner with third parties to manage advertising on other websites for our products and services. We may also partner with third parties, including business partners, advertising networks, and other advertising service providers, who gather information about you on our Sites and other sites to provide you with advertisements on the Sites and elsewhere online based on your browsing history and tailored to your interests, preferences, and characteristics. Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Policy.
Some third parties collect information about users of our Sites to provide interest-based advertising on our Sites and elsewhere, including across browsers and devices. These third parties may use the information they collect on our Sites to make predictions about your interests in order to provide you ads (from us and other companies) across the Internet. Some of these third parties may participate in industry-developed programs designed to provide consumers with choices about whether to receive targeted advertising. Due to differences between using apps and websites on mobile devices, you may need to take additional steps to disable targeted ad technologies in mobile apps. Many mobile devices allow you to opt out of targeted advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. You also may uninstall our apps using the standard uninstall process available on your mobile device or app marketplace.
To opt out of interest-based advertising across browsers and devices from companies that participate in the Digital Advertising Alliance or Network Advertising Initiative opt-out programs, please visit the websites operated by the Network Advertising Initiative (//www.networkadvertising.org/choices/) and the Digital Advertising Alliance (//www.aboutads.info/choices/). You may also be able to opt out of interest-based advertising through the settings within the mobile app or your mobile device, but your opt-out choice may apply only to the browser or device you are using when you opt out, so you should opt out on each of your browsers and devices if you want to disable all cross-device linking for interest-based advertising. Further information in local languages may be available at www.youronlinechoices.com/. Please note that even if you use an industry-based opt-out for interest-based advertising, you will continue to receive generic advertisements and your experience on our Sites may be degraded.
12. Online Forums
The Sites may offer publicly-accessible community forums. You should be aware that any information you provide in these areas is public and may be read, collected, and used by others who access them. To request removal of your personal information from these forums, email us at [email protected] . In some cases, we may not be able to remove your personal information.
13. Third-Party Links
The Sites may contain links to websites operated and maintained by third parties over which we have no control. Any information you provide to third party websites will be governed under the terms of each websites' privacy policy and we encourage you to investigate such policies before disclosing any information to the operators of third party websites. We have no responsibility or liability for the content, actions or policies of third party websites. The inclusion of links to third party websites on our Sites in no way constitutes an endorsement of such websites' content, actions or policies.
14. Third-Party Functionality
Some of the functionality on the Sites may be provided by third parties that are not affiliated with Healtheek. These entities may collect or receive certain information about your use of the Sites, including through the use of cookies, Web beacons, and similar technologies. Healtheek is not responsible for the privacy practices of these entities.
If you access third-party services, such as Facebook, Google, or Twitter, through the Sites, to login to the Sites or to share information about your experience on the Sites with others, these third-party services may be able to collect information about you, including information about your activity on the Site, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies.
15. Modifications to this Policy
This Privacy Policy was last updated on the date listed at the beginning of this Policy. Healtheek wellness reserves the right to change this Privacy Policy at any time. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. Your subsequent use of the Sites will be deemed acceptance of such changes. Be sure to review this Privacy Policy periodically to ensure familiarity with its most current version. By using the Sites following the posting of changes to this Privacy Policy, you agree to all such changes.
16. What if I have Questions?
Healtheek wellness takes privacy concerns seriously. If you have questions or comments, you may contact us at: +916281861840 Madhapur, Hyderabad, Telengana. (Attn: Privacy Dept.), [email protected] , +916281861840.
SUPPLEMENTAL PRIVACY POLICY OF HEALTHEEK INTERNATIONAL INDIA PRIVATE LIMITED
If you are a resident of India, the India-specific provisions mentioned in this addendum (“India Addendum”) apply to our processing of personal information about you in addition to the relevant sections above of Healtheek Global Online Privacy Policy (the “Policy” and collectively with India Addendum, “Privacy Policies”). In the event of a conflict between the relevant sections above of the Policy and the provisions of this India Addendum, the provisions of the India Addendum will govern. As used in this India Addendum, all capitalized terms when not defined herein shall have the meaning as ascribed to them under the Policy.
Healtheek International India Private Limited (“we”, “us” or “our”) recognizes the importance of the personal information we hold about individuals and the trust you place in us. By using, accessing or continuing to use the Sites, availing our services or submitting your personal information, you confirm that you have carefully read, fully understood and consented to each provision of the Privacy Policies and agree to our use of your personal information (including sensitive personal information) in accordance with the Privacy Policies.
Collection and Storage of Information
Please note that any personal information provided on or gathered by the Sites will be collected, stored, and controlled by Healtheek International India Pvt. Ltd., Madhapur, Hyderabad, Telangana.
Access and Correction of Information
You are entitled to access and review your personal information held by us on request by contacting us using the contact details set out below.
We will take reasonable steps to ensure that the personal information found to be inaccurate or deficient is corrected or amended, as feasible. You can help us to do this by letting us know if you notice any inaccuracy or deficiency in personal information we hold about you and/or by letting us know if your personal details change.
You may choose to not provide us with your personal information or withdraw your consent of collection and use of your personal information at any time, on request, by contacting us using the contact details set out below. If you do so, we may no longer be able to provide you with the corresponding products or service for which the said personal information was sought by us under the Privacy Policies.
Direct Marketing Communications
If you have provided Healtheek with consent, we will send you promotional and advertising communications from time to time. By providing consent and/or verifying your contact number with us, you agree to receive promotional and advertising communications (through call, SMS, email or other digital and electronic means) from us even if your mobile number is registered under the DND/NCPR list under the Telecom Commercial Communications Customer Preference Regulations, 2018. You may opt-out of receiving promotional and advertising communications from us at any time by following the instructions in those communications or emailing us at [email protected] or contacting us at +916281861840.
Sharing of Information
Please be aware that information you provide to us or that we obtain as a result of your use of the Sites may be shared with those mentioned in the Privacy Policies and you consent to such disclosure. Using the Sites demonstrates your consent to the processing of information as described in the Privacy Policies. Please note that information about our customers is an important part of our business and we disclose your information to only those mentioned in the Policy who are either subject to the Privacy Policies or follow practices at least as protective as those described thereunder. Other than as set out in the Privacy Policies, you will receive notice when your personal information might be shared with third parties and you will have an opportunity to choose not to share such personal information.
Transfer of Information
Please be aware that information you provide to us or that we obtain as a result of your use of the Sites may be collected in your country and subsequently transferred to another country in accordance with applicable law and you consent to such transfers. However, please be assured that in such cases, we will take appropriate measures to ensure that your information that we store outside the country is processed in accordance with the Privacy Policies and applicable laws and that your personal information is equally protected as in the country/region where you use or access the Site. Using the Sites demonstrates your consent to the processing of information as described in the Privacy Policies.
Children’s Information
The Sites are general audience websites that are directed for adults who can form a legally binding contract under the Indian Contract Act, 1872. If you have not attained the legal age, you must not access or use our Sites without the consent of your parent or guardian or their involvement. We collect, use or disseminate any personal information of children only with the express consent of the parent or guardian, as permitted by law or when it is necessary to do so in order to protect the children concerned.
If you believe we may have collected personal information from your child on the Sites without having obtained an expressed and verifiable parental/guardian consent, please contact us at [email protected] and we will make reasonable efforts to delete it from our records.
Security of Personal Information
We take reasonable steps to ensure that the personal information we collect about you remains accurate, timely, and secure. We have put in place reasonable security practices and procedures to implement appropriate technical, operational, managerial, and physical security controls in order to protect your personal information from unauthorized access, or disclosure while it is under our control.
Making a Privacy Complaint
Your privacy is important to us. If you have a complaint, you may contact our Grievance Officer at the details provided below, who is responsible for redressing your grievances:
Name: S TULASI VENKATESH
Contact No: 6281861840
E-mail: [email protected]
Your complaint will then be investigated. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved. Our Grievance Officer will redress your grievances expeditiously, within 30 days from the date of receipt of the grievance.
India Addendum: Last Updated – February 2023