2. Information we collect
The information we collect can be divided into the following broad categories:
More specifically, we may collect and store the following information relating to you:
2.1 Anonymous data
2.2 Direct Interactions
We collect information from you when you voluntarily submit information directly to us or via our Website. We may ask you for personal information at other times. We will not share that information in a manner that identifies you as an individual with any other entity unless we have your permission.
2.3 Tracking technologies
We use “cookies” and similar tracking technologies (as described in Section 5 below) to track your activities on our Website, and may also receive data about you if you visit other websites employing our cookies. When we send you emails that include a link to the Website, that link may contain an alphanumeric identifier that allows us to identify the person to whom we sent the message so that we can personalize our content for that individual.
2.4 Automated technologies or interactions
As you interact with our Website, we may automatically collect technical and usage data about your device, browsing actions and patterns. For example, we collect information which may include your IP address, browser type, your location, language preferences, device information and access times. While an IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual. Your IP address can reveal what geographic area you are connecting from, or which ISP you are using. Finally, other websites you visit have IP addresses, and we may collect the IP addresses of those websites and their pages. We also collect IP addresses for system administration and to report aggregate information to any sponsors. We may also receive information from our web logs, which automatically record anything a web server sees, which may include email addresses you enter into a form or pages viewed by a user at a particular IP address. We collect this personal data by using cookies, pixel tags and other similar tracking technologies. The sole purpose of passively collecting your information is to improve your experience when using our Website.
2.5 Promotions & surveys
2.6 Information received from our service providers and partners
We may also receive information about you from our service providers and partners, which we use to personalize our Service, to measure ad quality and responses to ads, to display ads that are more likely to be relevant to you, and to offer you opportunities to purchase products or services that we believe may be of interest to you.
3. How we use the information we collect
We have set out below, in a table format, a description of all the ways we process your personal data, and the legal basis we rely on to do so. :
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. How we share the information we collect
This section describes how the information collected or generated through your use of the Website may be shared by us with third parties.
4.1 Marketing and advertising
We may send you promotional communications about our Website or our advertising partners, including relevant advertising for third-party products and services that may be of interest to. We may also share aggregate user information in a non-personally identifiable manner with advertisers and other third parties in order to present to users more targeted advertising, products and services. We do not provide any personally identifiable information to third-party advertising companies.
4.2 Service providers
To provide you with the best experience on our Website, we may use third parties who automatically process your Usage Data on our behalf. Where possible, we will make sure this data is anonymized.
4.3 Promotions and surveys
When one or more of our business partners co-sponsor a service, promotion, contest/sweepstakes, or survey, we may share some or all of the information collected in connection with such service, promotion, contest/sweepstakes, or survey with the co-sponsor(s). If we intend to share such information, you will be notified prior to the collection of that information. If you do not want your information to be shared, you will be able to choose not to allow the transfer by not using or signing up for that particular service, promotion, contest/sweepstakes, or survey.
5. Cookies and other tracking technologies
6. Information collected by third parties
Please read these third parties’ privacy policies to find out how they collect and process your personal information.
7. Your rights under the EU’s GDPR
If you are located in the European Union, or if the EU’s General Data Protection Regulation (“GDPR”) otherwise applies to your data as processed by us, you have the right to:
If you wish to exercise any of the rights set out above or request details about the specific legal basis we are relying on to process your personal data, please email us at firstname.lastname@example.org
We will respond to you within 30 days of receipt of your request. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise your other legal rights). This is a security measure to ensure that your personal data is not disclosed to any person who does not have the right to receive it. We may also contact you to ask you for further information, in relation to your request, to speed up our response.
You will not have to pay a fee to access your personal data (or to exercise any of your other legal rights). However, we may charge a reasonable fee (or refuse to comply) if your request is clearly unfounded, repetitive or excessive.
8. Data retention
If you are located in the European Union, or if the GDPR otherwise applies to your data as processed by us, we will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or internal reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for compliance, governance, legal and/or regulatory purposes in which case we may use this information indefinitely without further notice to you.
9. Email Opt-out
Users who no longer wish to receive email updates or other notifications may opt out of receiving these communications by following the instructions contained in the applicable email. Please know that such a decision will not stop advertising or content that is generated prior to the time when we can accomplish the removal of your information.
10. Credit Card Processing
Credit card transactions are handled by a third-party processor that receives credit card numbers and other personally identifying information only to verify credit card accounts and process transactions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered or disclosed, used or accessed in an unauthorized way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, the transmission of data via the internet is not completely secure and we cannot guarantee that unauthorized parties will not be able to defeat those measures: unauthorized entry or use, hardware or software failure, and other factors may compromise the security of our user information at any time.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
12. Children and COPPA compliance
We believe that parents should supervise their children’s online activities and consider using parental control tools available from online services and software manufacturers that help provide a child-friendly online environment. These tools can also prevent children from otherwise disclosing online their name, address and other personal information without parental permission.
13. Business transitions
14. California user consumer rights
In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, STE1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to email@example.com. Under California law, California residents who have an established business relationship with us or one of our subsidiaries may choose to opt out of our disclosure of personal information about them to third parties for direct marketing purposes. As detailed above, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, email firstname.lastname@example.org.
15. Users located outside of the United States
16. Cooperation with law enforcement; fraud protection
We fully cooperate with law enforcement agencies in identifying those who use our Website or Service for illegal activities. We reserve the right to disclose information about users who we believe are in violation of applicable laws or regulations, or as required to respond to a subpoena, court orders or other legal process requiring such disclosure. We also reserve the right to report to law enforcement agencies any activities that we reasonably believe to be unlawful and to exchange information with other companies and organizations for fraud protection.
Please note that if you opt out of receiving notices from us, change notices will still govern your use of the Website, and you are responsible for reviewing such legal notices for changes, as posted on the Website.
18. Who we are
For the purposes of the GDPR, Thrive Health Access, SRL, located at Hotel Rythmia Life Advancement Center, Hacienda Pinilla, Playa Avellana, Guanacatse, Costa Rica is the Data Controller and is responsible for your personal data. This means that we determine the purposes and ways of the processing of your personal data.
Effective as of May 25, 2018
HemaLucent is a program provided by Thrive Health Access. Thrive Health Access is a duly organized Costa Rican SRL acting as a management services organization (MSO) that specializes in providing services for unique and cutting-edge programs. Thrive Health Access is not related to Clear Compass Media , Thrive Movie, LLC or Thrive Movement International, Inc. other than commonality of shareholders.
© 2018 Thrive Health Access. | All Rights Reserved.