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Privacy policy

We take yours and everyone’s privacy seriously. Please read this Privacy Policy to learn how we treat your personal data.

1. What this Privacy Policy covers

This Privacy Policy covers how we treat Personal Data that we gather and subsequently process when you access or use our Service. “Personal Data” means any information that identifies or relates to you and also includes information referred to as “personally identifiable information” or “personal information” under applicable privacy or data protection laws. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

2. What personal data we collect

2.1 Categories of Personal Data we collect
This list details the categories of Personal Data that we collect and have collected over the past 12 months.

2.1.1 Customer Information
This is information about you that we use to manage your account, for example your name, address, email address and telephone number. We use this data to:

  • Manage your account.
  • To input relevant information into our analysis, for example your geographical location.

We need this information in order to deliver the service to you which means that you will not be able to sign up to an account without providing it.
We use your email address, telephone number, first name, last name, birth date, and country to improve our use of Facebook advertising, see the “Facebook” section below.

2.1.1.1 Emails

We may also use your email address, in order to send you emails for the following purposes:

  • Providing you with information about our products or services.
  • Keeping in touch with you about the health dashboard and its performance as well as about new services we may develop.
  • Sending you updates on our latest developments and scientific discoveries.
  • Inviting you to register for courses and groups that might support your health journey.

Our legal basis for doing so is our legitimate interest in promoting our services. For more information, see the “User Research” and “Mailing Lists” sections below.

2.1.1.2 How long do we keep customer information for?

We keep this information for a period of 5 years after the end of your subscription. Keeping it for this length of time allows us to recognise you if you wish to subscribe again.

2.1.2 Samples

These biological blood samples, that you have sent to us for scanning and therapy.

We will keep this sample for no more than one year.

2.1.4 Test Results

These are the results received back from devices that measure your physiological data (such as a blood sugar sensor), possibly via intermediate data management systems managed by the manufacturer/distributors of the devices, and which facilitate the transfer of the data from the devices to the Health Dashboard. An example of a Test Result is the concentration of glucose in your blood.

We keep this data for as long as you have an account with us.

2.1.5 Device & Browser Data

If you visit our website, then we will also collect information about you. Some of this information is direct: such as your IP address, the type of browser you are using, the make of your mobile phone and the contents of cookies we set. We also use third party analytics providers such as Google Analytics, who collect similar information and then supply us with further analysis derived from it.

We process this data in order to:

  • Locate errors in our systems or problems our systems may be facing with other systems (such as compatibility with a web browser)
  • Improve the functioning of our Service
  • Prevent fraud or other criminal activity

This information is automatically sent to us – although there are technical ways you can prevent us from receiving this information (for example by changing the information your browser supplies to us) – the way in which browser works means it is inevitable that we process it.

2.1.6 Payment Information

This is information that is necessary in order for payments to be processed by our third party payment processor. For example the amount of the payment, payment card type, payment card number, and your billing address.

For your security our payment processor only shares the last 4 digits of your payment card number with us.
We retain this data as long as necessary to comply with our legal obligations under tax and corporate law. As soon as we no longer need the information, we delete it.

2.1.7 Correspondence

Where you directly correspond with us (such as sending us an email, online chat message, or call us) we will process information about you concerned with that correspondence, including your email and our responses. We keep that information for as long as necessary to deal with the correspondence.

2.2 Our purposes for using Personal Data

We have explained specific reasons for processing categories of personal data above. Our core purpose is to help you manage your health. For that purpose we use samples and some customer information.

We may process any of the information you provide us for the purposes of providing support and assistance in using the Service.
We will not collect additional categories of Personal Data or use the Personal Data we collected for different purposes without providing you notice.

3. How we share your Personal Data

We do not share Personal Data with anyone else, other than with:
Contractors providing us services we use for processing Personal Data, which include:

  • Hosting, technology and communication providers.
  • Analytics providers.
  • Payment processors

Data that is not Personal Data

We may convert Personal Data into anonymous data, that is data which can no longer be linked with identifiable individuals, for example by aggregation of data about multiple individuals. We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user.
We may use such anonymous data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Service and promote our business, provided that the data remains anonymous. We do not delete anonymous data on any particular timetable. You may assume that we could keep it indefinitely.

4. Tracking tools, advertising and your rights to opt-out

4.1 General tracking

The Service uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Service, analyze trends, learn about our user base and operate and improve our Service. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Service. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

4.2 Facebook

We advertise our services in a number of places. One of those is Facebook. In order to make sure that our adverts reach the most appropriate people, we use two of Facebook’s “Business Tools”: Facebook Pixel and Conversions API.

For Facebook Pixel, we include a small script on our web page, which causes your browser to send a message to Facebook whenever it is loaded. Facebook will receive:

  • Information automatically transmitted by your browser (such as IP address and the version of browser you are using)
  • A “hashed” version of your email address, telephone number, first name, last name, birth date, zip code, and country. Facebook will not be able to convert these back into your original data, but if you have told Facebook these pieces of information, Facebook will recognise you.

4.3 Mailing Lists

You can subscribe to our mailing lists to get information about our products without creating an account and we will use the data you provide us with for these purposes.
We process this data because you have consented to us doing so.
If you do not wish to receive emails from us regarding this information, then you can opt out by clicking “unsubscribe from this list” at the bottom of our email.
If you unsubscribe from our mailing lists, we will need to keep just enough information on file to make sure we respect your preferences in the future.

5. Data security and retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

The periods for which we retain individual categories of Personal Data are explained under the heading “Categories of Personal Data we collect”.

6 Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

6.1 Personal Data Use and Processing Grounds

The “Our Purposes for Using Personal Data” section above explains the purposes for which we process your Personal Data.

We will only process your Personal Data if we have a lawful basis under the POPD / GDPR for doing so. Lawful bases for processing include:

  • Consent: Except for the specific situations explained below, we process your customer information, self-reported health information; samples by consent. You may withdraw your consent at any time and we will stop processing your Personal Data in this way.
  • Contractual Necessity: In order to be able to perform our contract, we need to collect customer information we have marked as required and all payment information.
  • Compliance with a legal obligation: As explained above, we will sometimes have to process personal data in order to comply with a legal obligation imposed on us. Where those obligations are imposed by HK law, that law will provide us with a lawful ground for processing.
  • Legitimate Interest: We process the following categories of Personal Data when we believe it is in our legitimate interest to do so and we do not believe that your rights of freedoms will be unduly interfered with by our processing:
  • Device data is justified by our legitimate interest in maintaining a reliable and secure system, free from errors and external security threats.
  • Cookies.

All information about your health, which we would normally be forbidden from processing by the GDPR, is processed by Practice Better because you have consented to doing so.

7 Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. To submit a request to exercise any of these rights, or to ask for more information, please email us at hello@majorwellbeing.com

Some of the rights below apply only in specific circumstances. In other situations, we may not be able to fully comply with your request, for example if it would be impossible or would involve a disproportionate effort; or if it jeopardizes the rights of others; but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
    Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
  • Erasure: In some situations you may have a right to request that we erase some or all of your Personal Data from our systems.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Service.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

8.1 Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

  • The categories of Personal Data that we have collected about you.
  • The sources from which that Personal Data was collected.
  • The business or commercial purpose for collecting or selling your Personal Data.
  • The categories of third parties with whom we have shared your Personal Data.

8.2 Deletion

You have the right to request that we delete the Personal Data that we have collected about you.

9. How to contact us:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: hello@majorwellbeing.com