PRIVACY POLICY

OVERVIEW

This Privacy Policy explains what you can expect from us and what we need from you in relation to your personal data. Please read this carefully as this Privacy Policy is legally binding when you use our Services.


We want you to understand why and how Health Within Limited (“Minimal Habits”, “we”, “us” and/or “our”) collects, uses, discloses and or/processes your Personal Data (as defined below) under Hong Kong’s Personal Data Privacy Ordinance (Cap. 486) (the “PDPO”) and the European General Data Protection Regulation (the “GDPR”).


This Privacy Policy (“Policy”) applies to you and all Individuals (as defined below) who provide Minimal Habits with Personal Data or whose Personal Data is otherwise collected, used, processed, stored and/or disclosed by Minimal Habits in connection with and/or for the purposes of its operations.

This Policy supplements but does not supersede or replace any previous consent which you may have provided to Minimal Habits nor does it affect any legal rights that Minimal Habits may have regarding the collection, use, processing and/or disclosure of any Individual’s Personal Data.


Minimal Habits may from time to time update this Policy to ensure that it is consistent with our business needs or to accommodate amendments to applicable legal or regulatory requirements. All updates to this Policy will be published online at www.minimal-habits.com (the “Website”) on this page. You shall be deemed to have accepted the Policy as amended by continuing your relationship with Minimal Habits after any amendments have been published on the Minimal Habits Website.


This Policy forms part of the terms and conditions, if any, governing your specific relationship with Minimal Habits (“Terms and Conditions”) and it should be read in conjunction with the Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.


OUR PRINCIPLES OF DATA PROTECTION

Our approach to data protection is built around 2 key principles. They’re at the heart of everything we do relating to personal data.

a) User Sovereignty: You have full control over your data and you have the ability to make changes as required.

b) Transparency: We take a human approach to how we process personal data by being open, honest and transparent.


DEFINITIONS

Minimal Habits is committed to protecting your privacy online. This Privacy Policy describes the personal information being collected through this website at minimal-habits.com (the “Site”), or through all communication per email (info@minimal-habits.com), calls, video calls, Google documents or messaging apps, and how we collect and use that information.


The term “We” refers to the team at Minimal Habits, a company registered under Health Within Limited, Hong-Kong.


The terms “user,” “you,” and “your” refer to site visitors, customers, and any other users of the site, individuals or companies.


The terms “personal information” or "personal data" are defined as information that you voluntarily provide to us that personally identifies you and/or your contact information, such as your name, country, phone number, and email address, but also details about your lifetstyle, habits, health and more.


The terms “service” or “services” refer to the blog, podcast, digital or physical products, courses, private coaching, consulting and group programs, paid or free.


Use of Minimal Habits, including all materials presented herein and all online services provided by Minimal Habits, is subject to the following Privacy Policy. This Privacy Policy applies to all site visitors, customers and all other users of the site.


By using the Site or Service, you agree to this Privacy Policy, without modification, and acknowledge reading it.


PURPOSES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

We will only collect, use and disclose Personal Data from/or related to an Individual that is reasonably considered necessary for the relevant purposes underlying such collection, use or disclosure, which may include but is not limited to the following:


a) Facilitating our provision of products and services which are used by you and from time to time with newsletters, marketing or promotional materials and any other information that may be relevant to you;


b) Communicating with you to assist you with your enquiries;

c) Conducting market research and customer satisfaction surveys;


d) Any other purposes that we notify you of at the time of obtaining consent (collectively known as the “Purposes”).


COLLECTION OF PERSONAL DATA

Generally, we may collect Personal Data from you in one or more of the following ways or circumstances:


a) Information provided directly: You may be asked to provide Personal Data when you visit or use some parts of our websites and/or services. You do not have to provide us with your Personal Data; however, it could mean that you are not able to access some parts of our website or use our services.


b) Information collected automatically: Some information is collected automatically, such as an IP address and device type, when you visit our websites or use our services. This information is useful to us as it provides us with a better understanding of how you are interacting with our websites and services so that we can continue to provide you with the best experience possible.


c) Information from third parties: The majority of information that we collect is collected directly from you.

Where your Personal Data is collected from third parties, we will only use such Personal Data where you have provided your consent to the third party which would also cover our processing of your Personal Data or where Health Within Limited has a legitimate interest to use the Personal Data in order to evaluate the suitability of your relationship with us.

Some of the information we collect may include your personal data, such as your full name, contact information, telephone number(s), residential address, email address, product and service selections, and other data that may identify you, including personal details about your lifestyle and goals. We collect personal data about you at several different points, including but not limited to the following:

- when we correspond with you as a customer or prospective customer;

- when you visit our website or use the Platform;

- when you use our software or services;

- when you opt-in our newsletter program;

- when you decide to participate in a survey;

- when you voluntarily provide us with your information through our landing pages;

- when you fill-up forms, quizzes, questionnaires for life and goals assessments


PROCESSING OF PERSONAL DATA

Where we collect Personal data, we will only process it:


a) To perform a contract with you and deliver a service to you

b) Where we have your consent.


Please note that if you choose not to provide us with your Personal Data or choose not to consent to our processing of your Personal Data, we may not be able to provide some or all of our Services to you or respond to your other requests.


When your services are provided through Upcoach, the coaching platform used in some programs that Minimal Habits delivers, their Terms and Conditions and Privacy Policy apply for all your information stored on their platform, please refer to their website for further information.


SHARING INFORMATION OUTSIDE OF MINIMAL HABITS

We have no reason to share your personal data outside of our company. We respect your confidentiality and do not sell or give away our clients' private information.


CONSENT

Unless otherwise authorised under the PDPO, GDPR or any other applicable law, Health Within Limited will not collect, use or disclose your Personal Data without your knowledge and consent. We will highlight the Purposes relevant to you, by appropriate means, at the point or time of collection of your Personal Data.


We may obtain your consent by any of the following means:

a) via express provisions in a contract, application form and/or registration form to be signed with or submitted to us;

b) via notifications on our website;


In so far as any Purpose(s) are intrinsic to the relationship or provision of services, we reserves the right to decline to engage in the relevant relationship or to provide the relevant services to you if you do not consent to our collection, use or disclosure of your Personal Data for such purposes.


If you:

- voluntarily provide Personal Data to us for any specified purpose;

- use or access our website(s)

- attend or participate in events or programs organised by us

You will be deemed to have agreed and consented to the collection, use and/or disclose of your Personal Data in the manner and for the purposes set forth in this Privacy Policy.

If you provide us with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, you represent to us that you have obtained the consent of the relevant third party for us to collect, use or disclose such Personal Data for the relevant purpose.


REQUEST TO WITHDRAW CONSENT

You have the right to withdraw your consent to the collection, use and/or disclosure of your Personal Data in the possession of Health Within Limited by contacting us at any time.

We will process your request for the withdrawal of consent within a reasonable period of time from such a request being made. After that time, we will not collect, use and/or disclose your Personal Data in the manner stated in your request.

Your withdrawal of consent could affect the services that we are able to provide to you. Depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we are not able to continue with our existing relationship.


YOUR ACTIVITY ON THE WEBSITE

We may record information relating to your use of the Site, such as the searches you undertake, the pages you view, your browser type, IP address, requested URL, referring URL, and timestamp information. We use this type of information to administer the Site and provide the highest possible level of service to you. We may also use this information in the aggregate to perform statistical analyses of user behavior and characteristics in order to measure interest in and use of the various areas of the Site.


COOKIES

We may send cookies to your computer in order to uniquely identify your browser and improve the quality of our services. The term “cookies” refers to small pieces of information that a website sends to your computer’s hard drive while you are viewing the Site. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them). You have the ability to accept or decline cookies using your web browser settings. If you choose to disable cookies, some areas of the Site may not work properly or at all. The Site does not respond to Do Not Track signals sent by your browser.


THIRD PARTY LINKS

The Site may contain links to third party websites. Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you on our Site. Other sites accessible through our site via links or otherwise have their own policies in regard to privacy. We are not responsible for the privacy policies or practices of third parties.


SECURITY OF PERSONAL DATA

We maintain security measures to protect your personal information from unauthorized access, misuse, or disclosure. However, no exchange of data over the Internet can be guaranteed as 100% secure. While we make every effort to protect your personal information shared with us through our Site, you acknowledge that the personal information you voluntarily share with us through this Site could be accessed or tampered with by a third party. You agree that we are not responsible for any intercepted information shared through our Site without our knowledge or permission. Additionally, you release us from any and all claims arising out of or related to the use of such intercepted information in any unauthorized manner.


CHILDREN

To access or use the Site, you must be 18 years old or older and have the requisite power and authority to enter into this Privacy Policy. Children under the age of 18 are prohibited from using the Site.


VISITORS' GDPR RIGHTS

If you are within the European Union, you are entitled to certain information and have certain rights under the General Data Protection Regulation. Those rights include:

We will retain any information you choose to provide to us until the earlier of:


(a) you asking us to delete the information,

(b) our decision to cease using our existing data providers, or

(c) the Company decides that the value in retaining the data is outweighed by the costs of retaining it.


You have the right to request access to your data that the Company stores and the rights to either rectify or erase your personal data.

You have the right to seek restrictions on the processing of your data.

You have the right to object to the processing of your data and the right to the portability of your data.

To the extent that you provided consent to the Company’s processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.

You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.

We require only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.


UPDATING YOUR INFORMATION

If you opt-in to our mailing list, the option to unsubscribe will be included in every email. You may access and correct your personal information and privacy preferences by contacting us.


CHANGES TO THIS POLICY

You acknowledge and agree that it is your responsibility to review this Site and this Policy periodically and to be aware of any modifications. We will update this privacy policy by posting those changes on this page.


CONTACT

If you have questions about this privacy policy, please use the contact page.

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Copyright @2023 Health Within Limited | Terms & Conditions | Privacy Policy | Disclaimer