Calmclinic acknowledges that the protection of personal data is important to you, our clients, and is therefore committed to respect and protect the privacy of each data subject. Data subjects trust us in our personal information and we are responsible for working every day to justify their trust.
- processing of personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as - General Data Protection Regulation) and other applicable law the requirements of the Acts;
- implementation of appropriate technical and organizational measures to protect personal data from unauthorized access, disclosure, accidental loss, alteration or destruction or any other unlawful processing;
- implementation of the rights of the data subject;
- that personal data is stored in such a way that the identity of the data subjects can be determined for no longer than it is necessary for the purposes for which the data was collected and processed;
- only personal data that is necessary for each particular purpose of data processing is processed.
Why are we collecting your personal data?
On the website www.calmclinic.com we provide users with informational services - articles, tests and information materials on health and other topics. In order to properly provide these services, to fulfill the legal and tax obligations applicable to us, as well as to carry out direct marketing, we collect your personal data. The information we collect about you depends on the information you provide to us when ordering services, whether you sign up to our website, as well as, what services you order or use.
What personal data are we collecting?
Depending on your actions taken on our website, we ask you to provide the following personal data that we collect: gender, area for which the user requests information (sleep, distrust, anxiety, frightening thoughts, fear for health, etc.), name, surname, e-mail, country, user’s results and choices that had been made during the test on the user's website.
We also collect anonymized website usage data such as click data, pages visited and so on.
We inform you that to use our web site and to receive certain services provided by us you can choose to remain an anonymous user and not provide any personally identifiable data like name, email, etc. In this case, we do not collect your personal data in any form.
In order to provide you with some services, you must provide us with more information about yourself, such as email, name, surname, country, also you have to create an account. We note that your personal data is being inputted by you, so you are solely responsible for the accuracy of this data.
Calm Clinic collects personal information reasonably necessary to carry out our business, to assess and manage our members' needs, and provide our services to you. We may also collect information to fulfill administrative functions associated with these services, for example, billing, entering into contracts with you and/or third parties and managing member relationships.
The purposes for which Calm Clinic usually collects and uses personal information depends on the nature of your interaction with us, but may include:
- third party suppliers and contractors who assist us to operate our business;
- our affiliated and related companies;
- to improve the relevance of marketing messages we may send you (which you can opt out of as explained below);
- to bring to your attention (in person or by post, email or telephone) information about additional services offered by us and/or our [global affiliates], which may be of interest to you, unless you indicate at any time that you do not wish us to do so; and if instructed to do so by you or where you give us your consent to the use and/or processing involved;
- to share information with relevant third parties in the context of a sale or potential sale of a relevant part of our business, subject always to confidentiality obligations;
- to check your instructions to us, to analyze, assess and improve our services to members, as well as for training and quality purposes, we may monitor, record and analyze any communications between you and us, including phone calls;
- to fulfill our obligations under any reporting agreement entered into with any tax authority or revenue service(s) from time to time;
- to comply with any requirement of any applicable statute, regulation, rule and/or good practice;
- to follow up with you after you request information to see if we can provide any further assistance (for example if you inquire about a membership package);
- to confirm your identity and carry out background checks, including as part of our checks in relation to your application to become a subscriber member;
- for our reasonable commercial purposes (including quality control and administration and assisting us to develop new and improved products and services);
- responding to inquiries and complaints; recruitment processes; and informing you of our activities, events, facilities, and services;
- researching, developing and expanding our facilities and services;
- managing, planning, advertising and administering programs, events, competitions, and performances;
- responding to requests for information and other general inquiries;
- to record statistical data for marketing analysis from members;
- to obtain opinions or comments about products and/or services from members;
- to provide information about products, services and/or special offers to members;
- to fulfill obligations under a membership agreement and/or any other contract you may have with us;
- any additional personal information you provide to us or authorize us to collect, as part of your interaction or membership with Calm Clinic;
- any additional information relating to you that you provide to us directly through our websites or by other means such as over the phone, via email or in person; information you provide to us via voluntary members feedback or engagement surveys;
- your login details and passwords which you use to access your account with us as well as your online interactions with us;
- details of the products and services (such as membership options) you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your inquiries;
In addition, some of your personal information may be used for other business purposes. Examples of the types of uses are set out below:
Calm Clinic generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:
Calm Clinic also collects and uses personal information for market research purposes and to innovate our delivery of products and services. We have a legitimate interest in using your information in the ways listed above. In some cases, it will be lawful for us to collect and use your personal information, for example where it is necessary as part of our, or a third party’s, statutory or public functions or because the law permits or requires us to.
Can you disagree with the processing of your personal data?
We inform you that you have a right to disagree with the processing of your personal data by Calmclinic, as well as you can cancel your consent to the processing of personal data at any time.
If you do not agree to provide us with such personal data as your e-mail, you can use the website anonymously, then we will not collect or store any data about you.
How do we protect your personal data?
The security of your personal data is very important to us. Calmclinic has implemented appropriate organizational and technical security measures to help protect your personal data, which helps to protect your personal data against accidental or unlawful destruction, modification, disclosure, and any other unlawful handling We avoid storing obsolete or unnecessary information.
To whom do we provide your personal data?
We may provide your data to our data processors who provide us with services and manage (store) your data on behalf of Calmclinic as a data controller. Data controllers have the right to process personal data only in accordance with our instructions and only to the extent necessary for the proper performance of the obligations set out in the contract. Through our processors, we take all necessary steps to ensure that our data controllers have implemented the appropriate organizational and technical security measures and maintain the confidentiality of personal data.
If your place of residence is within the European Union, the General Data Protection Regulation and the implementation of your rights enshrined therein should be relevant to you and therefore we inform that our data processors may be established outside the European Union or the European Economic Area. If we transfer your personal data to such processors, we will take all the necessary legal measures to ensure that your right to privacy remains properly protected.
Personal data may be transferred and processed outside the EU / EEA where the transfer is indispensable for the provision of the service or the user has given his consent and also if adequate security measures are implemented. Appropriate security measures include:
- an agreement has been concluded that includes the standard conditions adopted by the European Commission or other approved items, codes of conduct, certificates, etc., approved in accordance with the General Data Protection Regulation;
- A country outside the EU / EEA containing the recipient of personal data ensures an adequate level of protection of personal data by a decision of the European Commission;
- The recipient is certified in accordance with the requirements of the Data Protection Agreement between the EU and the United States of America (also known as the "Privacy Shield") (applicable to recipients located in the United States).
If your place of residence is in the European Union and the General Data Protection Regulation is relevant to you, you can request more information about the possible transfer of your personal data outside the EU / EEA.
Your personal data is not transferred to other third parties, except when such data is required by the competent public authority.
What are your rights?
You have the right:
- to require to correct your personal data if it is incorrect, incomplete or inaccurate;
- to disagree to process your personal data when your personal data is processed or intended to be processed for direct marketing purposes or for a legitimate interest pursued by Calmclinic or a third person to whom personal data is provided;
- to require to erase your personal data which is processed only with your consent if you cancel the given consent. This right does not apply if the personal data requested to be erased is also processed on another legal basis, such as processing necessary for the execution of a contract or enforcement of obligations under applicable law;
- to restrict the processing of your personal data in accordance with the applicable law, for example - the period during which we will assess whether you have the right to request your personal data to be erased;
- to receive information on whether we handle your personal data and, if so, to get acquainted with the data;
- to receive personal data you have submitted that is processed in accordance with your consent or the basis for the execution of the contract, in writing or in a commonly used electronic form, and, where possible, transfer such data to another service provider (data portability);
- to cancel your consent to process personal data;
- to disagree that you will be covered by a fully automated decision making, including profiling, if such decision making has legal effects or any significant similar effect. This right does not apply if such decision making is necessary for the purpose of concluding or executing a contract with you, is permitted by applicable law, or you have given explicit consent;
- to submit a complaint regarding the processing of personal data to the supervisory authority if you believe that your personal data is being processed in violation of your rights and legitimate interests in accordance with applicable law.
You may choose, whether you want to accept cookies. The user gives his consent to accept cookies during his visit to the website www.calclinic.com by clicking “Got it!” button.
The types of cookies we use
Specifically, we use the following cookies:
Strictly necessary cookies: are required for the operation of our website, such as cookies that enable you to log into secure areas of our website (for example, our membership portal).
Analytical/performance cookies: allow us to count the number of users and see how users move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Targeting cookies: these cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information, subject to your choices and preferences, to make our website and any advertising displayed on it more relevant to your interests.
Third party/sharing cookies: are cookies that are set by a domain other than the one being visited by you. If you visit our website and a separate company sets a cookie through that website this is a third party cookie. To try to bring you offers and advertisements that are of interest to you, we have relationships with third-party companies including [Google, Adobe Analytics, Facebook, LinkedIn] (Third Party Providers) that allow them to place cookies on our websites.
These Third Party Providers may:
- use Third Party Cookies, web beacons, and other storage technologies to collect or receive information from our Websites and elsewhere on the internet;
- compare de-identified information from us with information collected elsewhere on the internet; and
- use that information to provide measurement services and target ads to you.
How can you reach us?
You have the right to contact us in order to submit inquiries, cancel your consent, submit requests for your rights as a data subject, and complaint about the processing of personal data.
You can contact us by sending a message on the website.