9 July 2018
By visiting http://truluv.ai or by using the apps BreatheLUV or #SelfCare (collectively the “Services”), contacting us or agreeing to receive emails from TRU LUV, you accept the terms and conditions of this Policy.
This Policy does not extend to websites/services operated by third parties. TRU LUV is therefore not liable for their privacy policies, procedures and practices.
1. Collection of Information
We collect your personal information in several ways, including when you enter information on our Services, use the apps BreatheLUV or #SelfCare, contact us by telephone or by email, post on our social media accounts, etc. Depending on the circumstances, personal information may include your name, email address, phone number, etc.
When using the app BreatheLUV with an Apple watch or similar wearable device, we ask for your explicit consent to collect certain information including your health data. We use this information to measure your heart rate, to track and show your progress in the application, and to improve our content. You can use your account settings and tools to withdraw your consent at any time, including by stopping use of a feature, removing our access to a third-party service, or deleting your data or your account. Your data generated by the Apple Health Kit API will not be furnished, published, or sold to any third parties for advertising and/or marketing purposes. If you choose to withhold any personal information requested by us, it may not be possible for you to gain access to certain parts of the Services.
We may collect analytics data on your use of the app #SelfCare through Unity Analytics, such as the number of sessions, the tutorials consulted, the objects found, etc. For more information, please consult the Unity Analytics Terms of Service at https://unity3d.com/legal/monetization-services-terms-of-service.
The legal bases for our processing of personal information are primarily that the processing is necessary for providing the Services and that the processing is carried out in our legitimate interests, which are further explained in the “Use and Communication of Information” section. We may also process personal information upon your consent, asking for it as appropriate.
In relation to the health data, this can be processed by TRU LUV only with the user’s prior consent and will be used only for the purposes of performing the App BreatheLUV.
2. Use and Communication of Information
We take steps designed to ensure that only those employees who need access to your personal information to fulfil their employment duties will have access to it. We use and disclose your personal information mainly:
- to operate, maintain, enhance and provide all features of the Services, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Services;
- to understand and analyze the usage trends and preferences of our users, to improve the Services, and to develop new products, services, feature, and functionality;
- to send you communications; or
- for any other purposes authorized or required by law.
When we disclose your personal information to third parties, we take reasonable measures to ensure that the rules set forth in this Policy are complied with and these third parties provide sufficient guarantees to implement appropriate technical and organisational measures.
In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of TRU LUV, in whole or in part, your personal information may be transferred as part of the transaction.
We may finally make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding your interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Services.
3. Retention of Information
Your personal information may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using the Services, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices regarding your personal information will at all times continue to be governed by this Policy and, if applicable, we will comply with the GDPR requirements providing adequate protection for the transfer of personal information from the EU/EEA to third country.
TRU LUV has implemented various physical, administrative and technical safeguards designed to protect the confidentiality and security of personal information under our control. However, no security measures are absolute or wholly guaranteed.
We will only keep your personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Policy and in order to comply with our legal and regulatory obligations. If you would like further information regarding the periods for which your personal information will be kept, please contact us as set forth in the “Contact” section.
4. Right Regarding Personal Information
On written request and subject to proof of identity, you may access the personal information that we hold, and ask that any necessary corrections be made, where applicable, as authorized or required by law. However, to make sure that the personal information we maintain about you is accurate and up to date, please inform us immediately of any change in your personal information.
Specific Provisions for Europeans Users
Please note that the term personal information used in this Policy is equivalent to the term “personal data” under the GDPR and other applicable European data protection laws. Under the GDPR, you may be entitled to additional rights, including: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your personal information and certain other supplementary information, under certain conditions; (iii) the right to object to unlawful data processing, under certain conditions; (iv) the right to erasure of personal information about you, under certain conditions; (v) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, or believe your personal information is inaccurate; (vi) the right to data portability of personal information that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; (viii) the right to lodge a complaint with data protection authorities. If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection at http://ec.europa.eu/justice/data-protection/index_en.htm.
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Services, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Services after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
6. Children’s Privacy
The Services is not directed to children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, then please do not use or access the Services at any time or in any manner. If we learn that Personal Information has been collected via the Services from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 16 years of age has provided Personal Information, then you may alert us as set forth in the “Contact” section and request that we delete that child’s Personal Information from our systems.
If you have any questions or comments about this Policy or your personal information, to make an access or correction request, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers outside Canada, our Privacy Officer can be reached by email at: email@example.com.
Last Update: 9 July, 2018