Privacy Policy

Last revision: October 22, 2020

​

By continuing to use our website and services, you are deemed to agree to our terms and conditions and this Privacy Policy for the collection and processing your personal data.  Please note that any consent that is given for the purposes of medical consultation or examination is a separate consent form that granted for the processing of your personal data.

This Privacy Policy sets out our use of any and all data collected by us in relation to your use of our website, www.heart-vibe.com and www.juliet-rose.com (“Website”). The Website is operated by Juliet Rose, Ltd. (” Juliet Rose”). Our Registered Office is Celovška cesta 128, 1000 Ljubljana and our Company Registration Number is 8702314000.

​

1 Data protection
 

Data protection is a matter of trust and your trust is important to us. We respect your private and personal sphere. The protection and legally compliant collection, processing and use of your personal data is, therefore, an important concern for us.

In order to make you feel safe when you visit our website, we strictly follow the legal provisions when processing your personal data and we would like to inform you about our collection and use of data here.

​

2 Collection, processing and use of personal data

2.1 Personal data

Personal data means all information about data subjects on the basis of which the identity of the data subject can be determined or determined. This includes name, IP addresses, etc. This does not include statistics that we collect, for example, when you visit our website or when you use our services and cannot be linked to a person.

​

2.2 customer account

If you have a customer account for this service or site, it is password protected. In this account, you can view and change information such as orders or customer information. You agree to treat personal access information confidentially and not to make it available to unauthorized third parties. We do not accept responsibility for incorrectly used passwords unless we are responsible for the misuse.

​

2.3 Collection, processing and use of your personal data

Data protection is very important to us, so compliance with data protection legislation is important to us.

We collect, store and process your data for the entire processing of all purchases, for our services, technical administration and our own marketing purposes. Your personal data will only be passed on to third parties if this is necessary for the processing of contracts or billing or if you have given your prior consent and only to the extent necessary for third parties. If there are exceptions, they will be mentioned in this text below.

The information provided may only be used by service providers to fulfil their task. Any other use of the information is not permitted.

Your personal data will be deleted when you exercise your right to delete, if the data is no longer necessary to fulfil the purpose for which it was stored, and if the deletion does not violate any applicable law or the deletion would be inadmissible.

We may collect and process the following information about you:

• Registration: information (such as your name, date of birth, email address, postal address, telephone number, profile picture and NHS number) that you provide by completing forms on the Platform, including if you register as a user of the Platform, subscribe to any of our services or those of a third party hosted on the Platform, upload or submit any material via the Platform or request information from us;

• Account sign-in: in connection with the account sign-in process, your password and log-in details;

• Payments and purchases: details of any transactions made by you through the Platform while logged into your account will be recorded;

• IP address and URL: your activity on our Website (automatically collected) when you use or log on to any of sites or Platforms and the site you exit to.

• When you contact us: communications you send to us, for example, to report a problem or to submit queries, concerns or comments regarding the Platform or its content;

• Research and surveys: information from surveys that we may, from time to time, run on the Platform for research purposes, if you choose to respond to them;

• Use of the Platform: details of your visits to the Platform, the resources you access and any data you download;

You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.

We will use the information you provide to:

• enable us to provide you with the services and information offered through the Platform and which you request from us, for example, to arrange a consultation. This may include sharing your data with one of our third-party service providers such as our consultants and HRv certified coaches and sharing limited data with our call centre operatives;

• provide and administer your access and to our website and your account with us;

• verify and carry out financial transactions in relation to payments you make online;

• verify your identity and your parental guardianship relationship with any child dependants;

• respond to communications from you;

• supply you with email, for example, newsletters alert that you might have subscribed to (you may unsubscribe or opt-out at any time by following our Unsubscribe instructions)

We need to use your personal information for those purposes to provide our services and to perform our contract with you.  In some cases, the collection of data may be a statutory or contractual requirement and we will be limited in the services that we can provide you with without your consent to Us to be able to use such data.

We also collect, store and use the personal information listed above to:

• audit the downloading of data from the Platform to improve our service;

• learn and improve the layout and/or content of the pages of the Platform and better customise them for users;

• identify visitors to the Platform;

• carry out research on our user demographics; and

• tailor the information we send to you on the basis of the health data that you submit using the Platform.

We have a legitimate interest in using your personal information for these purposes so that we can constantly improve our Platform and our services, and to ensure that we are only sending you information that is going to be useful or relevant to you. 

Finally, we use your personal information to:

• send you information we think you may find useful or which you have requested from us, including information about our products and services or those of carefully selected third parties (such as information on relevant treatment and care offered by third parties), provided you have consented to be contacted for these purposes;

• allow, with your consent, carefully selected third parties to send you information directly which you may find useful regarding their products and services.

You can tell us not to contact you with information regarding our products and services or those of third parties or to share your details with third parties so that they can send you information regarding their products and services, in your profile on the Platform or where you do not wish us to continue to use your information in this way by following the unsubscribe instructions on any communications sent to you. You can also exercise the right at any time by contacting us using the contact details at the end of this privacy policy.

​

2.4 Information shared with others

Information that identifies you: We will only share personal information, from which you can be identified, in certain limited circumstances as described below.

​

We may share certain basic identification information (such as name, date of birth, email and phone details) with our out-of-hours call centre [operated by a third-party provider] when you contact customer services in order to properly track and deal with whatever issues you have raised. These call centre operatives may be located outside the European Union but will be based within the EEA unless we otherwise inform you.

​

We may disclose aggregate statistics about visitors to the Platform, users and sales in order to describe our services to prospective partners, investors, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.

We will not disclose, sell or rent your personal information to any third party unless you have consented to this first.  If you do consent but later change your mind, you may contact us, and we will cease any such activity.  However, in the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.

We may also disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Platform or the rights, property or personal safety of any person.

​

​

2.5 Additional information

When you visit the Website, we may automatically collect additional information about you, such as the type of internet browser you use, the Website from which you have come to the Website and your IP address (the unique address which identifies your computer on the internet) which is automatically recognised by our web server. You cannot be identified from this information and it is only used to assist us in providing an effective service on the Website and to collect broad demographic information for aggregate use.

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users' experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

​

2.6 Use of your data for advertising purposes

In addition to processing in the purchase process at Juliet Rose, your data will also be used for advertising purposes. You can send the objection at any time to our contact address from point 1 "Responsible authority" by post or e-mail.

​

2.6.1 Newsletter

We only send newsletters when you sign up for them or if you accept our general terms and conditions. If you no longer wish to receive news later, you can unsubscribe from the newsletter at any time with the unsubscribe link included in each newsletter. You can send the complaint at any time to our contact address referred to in point 1 "Responsible Authority" by post or e-mail.

​

2.6.2 Individual advertising for you

In order to be able to continuously improve and customize our services, we use the information you provide from our services and websites. We use e-mail, information about computers and Internet connections, operating systems, or the date and time of your visit to our site for this purpose.
As far as technically possible, we use the data in the pseudo-anonymised form. By analyzing this data, we can continually improve our range of services. For example, this improvement allows us to make our advertising offer more targeted and to present only information that is relevant to your interest.

I agree that Juliet Rose uses the information I provide and other information stored about my client account, as well as pseudo-anonymized usage information, to represent customized advertising and/or special offers and services to me.

If you do not wish to receive personalized advertising, you may object at any time. You can send the objection at any time to our contact address from point 1 "Responsible authority" by post or e-mail.

​

2.6.3 Sweepstakes, market research and opinions

In the case of competitions, your data will be stored for the purpose of informing the winners. For details, see the conditions for participation in each competition. In the case of market research and public opinion, your data will only be stored in an anonymized form for statistical analysis. The information obtained will not be passed on to third parties or only with your permission in any case.

I agree that Juliet Rose processes and uses my personal data from competitions, market and opinion research for its own purposes.

You can object to this at any time. You can send the objection at any time to our contact address from point 1 "Responsible authority" by post or e-mail.

​

2.7 Cookies

Acceptance of cookies is not a condition for the use of our services and websites. However, we would like to point out that if you decline cookies, some services and websites may not work as needed.

​

2.7.1 What are cookies?

Cookies are small text files that are stored on your device when you use our services and website. For more information, visit the external information pages https://de.wikipedia.org/wiki/HTTP-Cookie or http://www.aboutcookies.org.

​

2.7.2 Which cookies does Juliet Rose use?

Juliet Rose’s services and websites use different types of cookies of all types. We also use comparable technologies such as Local Shared Objects. Most of the cookies used are so-called session cookies, which are deleted after the end of the browser session.

Other cookies are used to remember you when you return to the Website and will last for longer.

We use cookies to:

• remember that you have used the Website before (this means we can identify the number of unique visitors we receive and allows us to make sure that we have enough capacity for the number of Users we get);

• allow you to navigate the Website more quickly and easily;

• remember your login session so you can move from one page to another within the Website;

• store your preferences;

• customise elements of the layout and/or content of the pages of the Website for you; and

• collect statistical information about how you use the Website so that we can improve the Website.

All cookies used on our Website are set by us.
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note, however, that by blocking or deleting cookies you may not be able to take full advantage of the Website.

No personal information is stored in cookies stored by Juliet Rose.

Our cookies will be used for:

• Essential session management

• creating a specific log-in session for a visitor to the Website in order that the Website remembers that a visitor is logged in and that their page requests are delivered in an effective, secure and consistent manner;

• recognising when a visitor to the Website has visited before allowing us to identify the number of unique visitors we receive to the Website and make sure we have enough capacity for the number of users that we get;

• recognising when a visitor to the Website is a registered member;

• we may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of our services.

Functionality

• customising elements of the promotional layout and/or content of the pages of the Website for example by storing a country code and providing users with content relevant to their country.

• This essential session management and functionality cookies are necessary in order for us to be able to provide our Platform to you.

Performance and measurement

• collecting statistical information about how our visitors use the Website so that we can improve the Website and learn which parts are most popular to visitors.

We have a legitimate interest in using any personal information collected through performance and measurement cookies so that we can constantly improve our Platform and our services.

​

2.7.3 Foreign cookies (third-party cookies)

Juliet Rose’s services and websites also use the offerings of various partners for advertising and analysis. These partners store so-called third-party cookies. Although great importance is attached to compliance with data protection regulations when choosing Juliet Rose partners, this cannot be guaranteed, as we do not determine or process the data it contains. Data protection statements can be found in the list under point "2.6 Online analysis and external services". Also, read the data protection statements of the providers mentioned there.

​

2.7.4 Behavioral targeting

​

Behavioural targeting advertising is advertising that is tailored to the interests of a particular person. These interests derive from profiles that are created over a period of time by assessing user behaviour (multiple site visits, interactions, keywords, etc.). The technology used for this, commonly called "tracking", uses data from the user's browser or device. These are mainly so-called "tracking cookies", but other, similar technologies can also be used. The ad network operator stores a tracking cookie on the end device of the data subject when he or she first accesses the website displaying the ad from the network. A cookie is tied to a specific domain and contains information that can only be read later from that domain. Based on this information, we can identify the user when they revisit the same site or another website that also has a partnership with that ad network, and then we can create a profile. These cookies are not provided by Juliet Rose, but by third parties, which is why they are also called "third party cookies". At http://www.youronlinechoices.com/at/nutzungsbasierte-online-werbung you will find detailed explanations of the various options available to you and the options for unsubscribing from online advertising based on usage.

​

2.7.5 Re-targeting

Our services and websites use retargeting. This technology allows us to offer you our site, products or services on partner sites again. The technology is implemented on the basis of cookie technology, whereby personal data is not stored.

I agree that so-called cookies are used and that I collect, store and use usage data. I also agree that my data is stored in cookies after the end of the browser session and that, for example, I can access it again the next time I visit the website. I can revoke this consent at any time in the future by refusing to accept cookies in my browser settings.

​

2.7.6 How can I prevent the storage of cookies?

You can disable the storage of cookies in the web browser you are using. As browsers are constantly evolving, it is difficult for Juliet Rose to provide accurate instructions here. Please use the help of your web browser or visit an external website http://www.aboutcookies.org/how-to-delete-cookies/.

​

2.7.7 Log files

When you visit a website or service, your browser automatically sends usage data and saves it to so-called server log files.
These log files store the date, time, access page name, IP address, reference URL, amount of data downloaded, and browser data used (product and version).
Server log files are analyzed to troubleshoot and improve server performance. There is no collection or analysis of personal data.

​

2.8 Online analysis and external services

 

Juliet Rose attaches great importance to compliance with data protection guidelines when choosing web analytics tools and external services such as social plug-ins. Because these tools and services partially store personal information, and Juliet Rose can neither view nor verify that storage, it refers to the so-called exclusion process. With this method, you can request the deletion of your data from the appropriate tool and service providers. A list of mainly used tools and services can be found below.

​

2.8.1 Google Analytics

Google Analytics is a business service:
Google Inc.
1600 Amphitheater Parkway
Mountain View
CA 94043, USA

By using this website, you represent that you consent to the processing of data collected about you by Google and the data processing methods described above and the stated purpose.

You can disable the storage of cookies in the web browser you are using. Because browsers are constantly evolving, Juliet Rose cannot give precise instructions here. Please use the help of your web browser or visit an external website http://www.aboutcookies.org/how-to-delete-cookies.

To deactivate Google Analytics, you can download and install the browser plug-in provided by Google: http://tools.google.com/dlpage/gaoptout?hl=de

Learn more about Google Analytics and data protection at http://www.google.com/intl/de/policies/privacy/.

​

2.8.2 Facebook

We use plugins from the social network facebook.com.
Data protection statement: https://www.facebook.com/about/privacy/

​

2.8.3 Twitter

We use plug-ins from the social network Twitter
Privacy Policy: https://twitter.com/privacy

​

2.8.4 Youtube

We use plug-ins from YouTube
Privacy Policy: http://www.google.com/intl/de/policies/privacy/

​

​

3 External links

 

The Platform may, from time to time, contain links to external sites affiliated to us or run by independent third parties. Please note that this Privacy Policy applies only to the personal information that we collect through this website and we cannot be responsible for personal information that third parties may collect, store and use through their website and we are not responsible for the privacy policies or the content of such sites.  You should always read the privacy policy of each website you visit carefully.

​

​

4 Security

 

We place great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it from occurring.

You should bear in mind that submission of information over the internet is never entirely secure and whilst we take appropriate technical and organisational measures to safeguard the personal information you provide to use, we cannot guarantee the security of information you submit via the Platform whilst it is in transit over the internet and any such submission is at your own risk.

You should always close your browser when you have finished your user session to help ensure others do not access your personal information, particularly if you use a shared computer or a computer in a public place.

To improve your security, we use SSL (Secure Socket Layer) to transfer data to our services and to the website.

​

​

5 EU General Data Protection Regulation

​

For the purposes of the processing your personal data, we are the data controller as set out under EU General Data Protection Regulation 2016 (GDPR).  We are committed to protecting your privacy, both on-line and in the real world. We appreciate that you do not want the personal information you provide to us distributed indiscriminately and here we explain how we collect information; what we do with it and what controls you have over our processing of your information.

This Policy should be read in conjunction with our Terms and Conditions and New Member Agreement. We may amend or update this Privacy Policy from time to time as set out in the Terms and Conditions.

Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.  We will only process your personal data if at least one of the following basis applies:

• you have given consent to the processing of your personal data for one or more specific purposes;

• processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

• processing is necessary for compliance with a legal obligation to which we are subject;

• processing is necessary to protect the vital interests of you or of another natural person;

• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Unless otherwise specified, any processing of personal data undertaken by us or by one of our authorised subcontractors including doctors and pharmacists or our call centre operatives, relating to providing our healthcare services to a customer, an Authorised User of our Platform (or their dependents) is processed on the basis of our contractual relationship (or in anticipation of a contractual relationship). Where we do not have or are not anticipating, a contractual relationship with a data subject (for example where processing personal data relating to a child or other dependant), we will generally be processing that data on the basis of legitimate interests.

In addition, where the personal data that we will be processing is “special data” which should be given additional safeguards, such as health information, we will only process that information if there is a valid special condition for processing (as set out in Article 9 of the GDPR). 

If we are processing personal data for the purposes of marketing, we will only do so if we have the express consent of the data subject.

​

​

6 Your rights

 

You have a legal right to access the personal information we hold about you at any time.

You also have a right to ask us to: update and correct any out-of-date information or errors in that information free of charge; object to our use of your personal information for certain purposes; erase your personal information, and transfer to you or (where technically possible) another organisation a copy of the personal information about you that has been provided to us.   

Where we are processing your personal data on the basis of consent, You may withdraw your consent for Juliet Rose to use your personal data as set above at any time by contacting Juliet Rose using the details below, and subject to the regulatory and legal requirements for Juliet Rose to retain certain information on your medical history and your doctor consultation notes, you can withdraw your consent to our use of any of your personal information at any time, including any data sharing, using the settings in your Juliet Rose profile or by emailing info@juliet-rose.com.

You also have the right to lodge a complaint at any time about our treatment of your personal information with the relevant supervisory authority.

Automated Decision-Making and Profiling

In the event that Juliet Rose use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Juliet Rose.

The right described above does not apply in the following circumstances:

• The decision is necessary for the entry into, or performance of, a contract between Juliet Rose and you;

• The decision is authorised by law; or

• You have given your explicit consent.

Where Juliet Rose uses your personal data for profiling purposes, the following shall apply:

• Clear information explaining the profiling will be provided, including its significance and the likely consequences;

• Appropriate mathematical or statistical procedures will be used;

• Technical and organizational measures necessary to minimize the risk of errors and to enable such errors to be easily corrected shall be implemented; and

• All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

​

​

7 Contacting us

 

Please submit any questions, concerns or comments you have about this privacy policy or any requests concerning your personal information by email to info@juliet-rose.com or write to us at:
Juliet Rose, d.o.o.

Celovška cesta 128

1000 Slovenia