Welltech.com PRIVACY NOTICE
Version 1.0
Last updated: 30 March 2023
This Privacy Notice is here to inform you, as a visitor of https://welltech.com/ and https://welltech.breezy.hr/ (further “Website”, “we/us”), on the processing of your personal data.
When We say “personal data” or “personal information”, We refer to information related to you. Such information is not limited to what directly identifies you, such as your name. In fact, you own and have legal rights to anything that speaks of you: the data you put in about your working experience and education may also qualify as personal information.
Contents:
The controller responsible for processing is Welltech Apps Limited, with its registered address at Karaiskaki 13, 3032, Limassol, Cyprus.
Should you have any general questions about this Privacy Notice, the use of your data by us, or if you want to assert your data protection rights, please contact us at [email protected].
Please note that in some cases, for your safety and when we have reasonable concerns about the authenticity of a request, we may need to authenticate you before proceeding with your request.
You are entitled to data-related rights as described below. You may assert them via the contact options.
Please note that these rights are based on European laws, namely the General Data Protection Regulation (the “GDPR”). Depending on your country of residence, those rights may have different interpretations. Should you wish to assert your country-specific rights, kindly let us know, and we will review your case individually.
You may ask to confirm whether we process your data and if so, to provide you with the scope of such processing and a copy of the data concerning you stored by us.
You have the right to request correction of inaccurate personal data concerning you and the completion of incomplete data.
You may request the erasure of your personal data stored by us. Please note, however, that the right to erasure is not absolute and shall be fulfilled by us only provided specific legal requirements are met. You may request data erasure only if:
Further, your right to erasure is subject to restrictions. For example, we are not under obligation or even allowed to delete data that we are still obligated to retain due to statutory retention periods. Similarly, data that we need for the establishment, exercise, or defense of legal claims is excluded from your right to erasure.
If we have transferred personal data to third parties, we will either initiate the deletion of your data from such third parties or inform them about the erasure, insofar as required by applicable law.
In order to avoid any unnecessary legalese and keeping in mind the general use of such words, we will interpret all user requests asking us to “delete my data” as requests for erasure of data under Article 17 GDPR.
You have the right to request, under certain conditions, restriction of processing (i.e. the marking of stored personal data to restrict its future use). The requirements for restriction of processing are as follows:
You have the right to object to the processing of your personal data in whole or in part at any time, and in any form, in the event that our processing is based on a legitimate interest (balancing of interests). In order to process your objection, we kindly request you to refer to your particular situation as to why you believe that your rights and freedoms are at a particular risk (see Article 21 of GDPR for more details).
Please note that the right to objection is not absolute, and we will stop the processing of your data only provided we cannot demonstrate compelling legitimate grounds for processing.
Where the processing you object against concerns direct marketing purposes, we will stop any processing once we receive an objection from you. A common example of how you can exercise an objection to marketing communications is pressing the “unsubscribe” button in emails.
You have the right to receive the data you provided to us in a commonly used and machine-readable format to transfer that data to another controller without our interference.
To the extent possible, we will allow you to export data for further use directly via the Website. You may also ask us to assist you with moving your data where it is technically feasible. Please note that this option relates only to data processed based on the performance of our contract with you or based on your consent. For more information about the contract and consent, please refer to Section 5 below.
If you provide consent to the processing of your personal data, you can withdraw it at any time. Consent withdrawal does not have a retroactive effect, meaning that any processing which occurred before the withdrawal shall not be affected.
You can lodge a complaint with the data protection authority at any time if you believe that your data has been processed unlawfully. Here is the contact information for the supervisory data protection authority:
Data Protection Commissioner, 1 Iasonos Street, 1082 Nicosia, Cyprus, tel: +357 22818456, fax: +357 22304565, email: [email protected]
In this Section, you can find a description of your privacy rights as a California resident, which are established under California laws, such as the California Consumer Privacy Act (the “CCPA”).
Please note that in this Section 3.1, we describe California-specific rights that substantially differ from those established under the GDPR. These rights are in addition to those established under the GDPR described above in Section 3 for California residents.
You may assert these rights via the contact options.
Generally, your right to request data access and data portability are described above in Section 3 under the titles “Right to access” and “Right to rectification”, respectively. The scopes of these rights differ slightly under the CCPA.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months only. Once we receive and confirm your verifiable consumer request, we will disclose to you:
If we sold or disclosed your personal information for a business purpose, we will disclose such facts separately.
Please note that you may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Generally, your right to request erasure is described above in Section 3 under the name “Right to erasure (Right to be forgotten)”.
Despite the fact that the right to request deletion of data under the CCPA and the right to erasure under the GDPR are essentially the same, please note that under the CCPA we are under no obligation to comply with your request if we need to maintain your information for certain reasons. For your convenience, you may find below an abridged version of such exceptions. To learn more, please refer to the full text of the CCPA or the additional clarifications from the California Attorney General.
Under the CCPA, we may retain your personal information if we need it to, among other things:
California consumers have the right to non-discrimination in relation to the exercise of their rights under the CCPA. In particular, we cannot deny you the Website, charge you different prices for the Website, either by denying benefits or imposing penalties, provide you with a different level or quality of the Website in comparison to how we proceed with other California users, or threaten you with any of the above.
Under California’s “Shine the Light” law (Civil Code Section § 1798.83) Website users can request information regarding the disclosure of personal information to third parties for their direct marketing purposes.
We do not sell the personal data we collect (as defined in the CCPA) and will not sell it without providing you with the right to opt out. Please note that we share users’ personal information for our business purposes as described in Section 7 “Personal Data Transfers”.
Data you provide
| Data Category | Data Collection |
|---|---|
| General Information | When you start using the Website, or in the course of Website use, we collect the following personal data:Name, Email address, Postal address,Phone number, Birth year, age (inferred based on the birth year),Country of residence,Education, Work experience, Professional skills, Other information you may provide. |
| Customer Support and Other Communications Information | When you contact us for customer support or otherwise communicate with us, you may provide us with information related to your use of the Website, additional contact information, payment information, identification documents, or other information you may find helpful to resolve your query. We also collect information on the feedback you provide on the customer support experience. |
| Your User Choices | We may collect information about your cookie-related privacy settings or other active choices. |
| Feedback Information | We will collect and process your feedback should you communicate it to us. |
Automatically collected data
| Data Category | Data Collection |
| Usage Information | We collect information about your activity on our Website, like frequency of use, areas and features that you access, visit, or use, and engagement with particular features. |
| Device-Related Information | When you install, access, or use the Website, we may collect a limited amount of device-related information. This includes, for example, IP address and browser information, language and time zone. |
| Log and Troubleshooting Information | We collect some troubleshooting, bug, and crash reporting information from you to help determine problems with the Website. We also collect and write logs to be able to access historical data for internal and external investigations. |
Information third parties provide about you
Should you wish to apply for a job via the LinkedIn plugin available at https://welltech.breezy.hr, We will receive information about your respective account and work experience, including your name and email address. The exact scope of information provided is always displayed on the LinkedIn screen presented to you during the application process.
On the Website, we also use cookies and other tracking technologies for various purposes. Please refer to Section 6 for more information on cookies and similar technologies.
All processing of your data must be lawful, i.e. reliant upon one of the lawful bases referenced under applicable law. Below you can see described the purposes of our processing (why we process your information) for each lawful basis and the corresponding data categories used in each case.
When you apply for a job, we need to process your data in order to prepare for the conclusion of a contract with you. We may need General Information and Information third parties provide about you.
Please note that preparation for a conclusion of a contract may be subject to additional privacy notices.
We may use the Data you provide, Automatically collected data and Information third parties provide about you to pursue our legitimate business interests as follows:
| Why and how we process your information | Substantiation of Legitimate Interest |
| To review your application as a job applicant, for example, to understand if coincides with Our expectations or general recruitment plans. | It is in our interest to scrutinise the information you provide to make a conclusion on further steps. |
| To analyze the performance of our Website, improve it, and further deliver a better user experience based on analysis of your interaction with the Website.For example:We count users and events for reporting to identify how many visitors the Website has. This includes metrics like how many unique users the Website has.We analyze bugs and fix issues with the Website. | Our interest is to measure the use of our Website and count the people who interact with it. Such actions are aimed at improving Website development and enabling the provision of accurate and reliable internal reporting. |
| To communicate with you in various ways, e.g to provide customer support. This includes, for example, responding when you request our help such as assisting with your privacy rights. | It is in our interest to assist our users with any inquiries or requests. |
| To defend ourselves from prospective legal claims, litigation, or other disputes, including in relation to violations of the Terms of Use, Privacy Notice, Subscription Policy, and/or Refund Policy. To ensure the safety, security, and integrity of the Website. To provide information to the authorities upon request. | It is in our interest to respond to complaints and prevent and address fraud, unauthorized use of the Website, violations of our Terms of Use and/or other policies, or other harmful or illegal activity.It is in our interest to seek legal advice and protect ourselves (including our rights, personnel, property, or products), and our users or others, including as part of investigations or regulatory inquiries and litigation or other disputes. |
| To identify disruptions and maintain Website security, including the detection and tracking of inadmissible access attempts and access to our servers. | It is in our interest to eliminate disruptions, maintain system security, and detect and track inadmissible access and access attempts. |
We do not use your data to make decisions based solely on automated processing that would create legal or comparably significant effects.
Cookies (“Cookies” or “Cookie”) are small text files that are placed on your device while you browse our Website. They help us remember/recognize some of your actions or choices during Website use for various purposes. Sometimes, they help us track you through websites and devices to understand the effectiveness of our ads.
There are two main types of Cookies that we can set:
We recommend checking Section 7 of this Privacy Notice to understand with whom we cooperate while using Cookies and Similar Technologies.
We use Cookies and Similar Technologies for a number of reasons, such as:
The Cookies and Similar Technologies we use generally fall into one of the following categories, whereas each category description allows us to understand why those Cookies are necessary.
Strictly Necessary Cookies and Similar Technologies
These Cookies and Similar Technologies are necessary for the Website to function and cannot be switched off in our systems. They are set out in response to actions you make, mainly in order to remember your choices, including cookie preferences.
If you block strictly necessary Cookies, some parts of the Website will not work.
Performance (Analytics) Cookies
These Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us know which pages are the most and least popular and see how the user moves across the Website.
Most browsers allow you to manage how Cookies are set and used as you’re browsing, and to clear Cookies and browsing data. Typically, such information can be found under the browser’s ‘Help’, ‘Preferences’, or ‘Options’ menus. Also, your browser may have settings allowing you to manage Cookies on a site-by-site basis as well as provide for incognito mode.
Should you wish to change your previously provided to us Cookie-related choices, please use the button below.
Do Not Track
“Do Not Track” is a preference you can set in your web browser to let the websites you visit know that you do not want them collecting information about you. The Website does not currently respond to a “Do Not Track” or similar signal.
A number of Website functions rely upon services from third parties, so-called ‘processors’. Processors act based on and in accordance with our requests and shall not use your data for their own purposes.
The main service providers the Website shares your data with are as follows:
Google Analytics is a analytics tool provided by Google, which helps us to analyze and optimise the Website performance.
We share your information with our affiliates, i.e. companies which are related to Welltech Apps Limited, by having the same owner, for example. Where such sharing takes place, related companies will honor this Privacy Notice.
We may use and disclose personal data to enforce our Terms of Use to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by applicable law.
Please note that in the course of doing business, we transfer your personal data outside of EU/EEA countries. For example, some of our service providers are located in the United States of America.
We shall implement measures as established under applicable law to ensure data transfers are protected as required. When a recipient is located in one of the jurisdictions listed on the official website of the European Commission here, the appropriate safeguard is the corresponding adequacy decision of the Commission. Where no such adequacy decision is present, we rely on the so-called Standard Contractual Clauses (see more about them here), along with a thorough analysis of the law of the destination country to safeguard your data and your rights.
We keep your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless further retention is required under applicable law.
You can request to tdelete your data at any time. We will accommodate such requests and terminate any data processing under respective legal bases.
Please note that certain data can be retained even after your deletion request. That may be the case where processing is based upon our legitimate interest. For example, we may keep information on purchases in order to protect our rights in a legal action. Such storage is not indefinite and is limited to such data’s usefulness and achieving our legitimate goals. As described in the Your Privacy Rights and How to Exercise Them section, you may object to our legitimate interests. If you wish to do so, please indicate this specifically in your message to us.
We may also keep data if deletion is not technically possible (for example, because your personal information has been stored in backup archives). We will securely store your personal information and isolate it from any further processing until deletion is possible.
The same applies to cases where we are obliged to retain your data under applicable law (e.g. accounting and tax laws). In the event of such retention, we will ensure via technical and organizational means that such data is not used for conflicting purposes, for example, advertising to you.
We may change this Privacy Notice from time to time by posting those changes directly on this webpage. Please make sure to review this Privacy Notice regularly. Should the change be major, we will try our best to draw your attention to it, e.g. via a pop-up or email. By continuing to use our Website, you acknowledge you have read and understood the most up-to-date Privacy Notice.
