Privacy Policy

Definitions

Privacy Policy shall be referred to as the       “Policy”

Envol B.V. shall be referred to as       “Envol” and "our", us or "we"

The mobile app known as Envol shall be referred to as the        "App"

The URL: www.envol.app shall be referred to as the        "Site"

The App and Site are collectively called hereinafter as the        "Services"

A visitor or end user of our Services is referred to as        “you”, “your(s)” or “yourself”

Terms and Conditions of Service shall be referred to as the        “Terms”

This privacy policy defines how we manage information and data that identifies you, directly or indirectly (the “Personal Data”), when you use our Services. Please read the following carefully to understand our practices regarding your Personal Data.

In addition, the terms “collect”, “process”, “treat”, “use”, “share”, “disclose”, “divulge” and analogous words shall be referred to your Personal Data and other data collected from our visitors and end users.

Introduction & General Scope.

Welcome to this Privacy Policy. It is Envol’s policy to respect your privacy regarding any information we may collect while operating our Services. We respect your privacy and are committed to protecting Personal Data you may provide us through the Services. We have adopted this Policy in order to explain what information may be collected on our Services, how we use this information, and under what circumstances we may disclose the information to third parties.

This Policy applies only to Personal Data we collect through the Services and does not apply to our collection of information from other sources, such as links to third party web pages, as well as any data we may collect across partnered and unaffiliated websites too.

This Policy, together with the Terms, set forth the general rules and policies governing your use of our App and services. Depending on your activities when visiting our Services, you may be required to agree to additional terms and conditions.

This Policy is freely available for your review prior to registration, and if you do not agree to its terms, your remedy shall consist of not registering an account, exiting the web tab through which you visited us, and/or deleting our Services.

Services Offered.

Envol provides, operates and manages an online platform with functionalities that include, but are not limited to: (i) a personalized lifestyle tracker to help you reach your goals; (ii) a restorative toolbox including meditations and music; and (iii) daily inspirational messages.

Overall, the App focuses on connecting back to the naturally available nourishments the world offers to us all, along with the simple activities you can do to feel better. Hereby, we try to work on giving hope and motivation to people, being that people recovering from chronical illness, injuries, being not on top of their game or just people feeling healthy and that want to stay healthy.

User Agreement & Registration.

As a user of our Services, you may be asked to create a profile with us, or to click on the “I Agree” checkbox on the registration form, banner, box or other similar means. Through that action, you thereby acknowledge and agree to the terms of this Policy, which is and constitutes a legal, binding agreement between you and Envol.

Envol team does every possible effort to keep your trust; and thus, we adhere to these general privacy principles, in order to defend your privacy:

  • Envol does not rent or sell your Personal Data.
  • Envol does not divulge your contact information to third parties or other users without your consent.
  • Any Personal Data that you give to Envol will be protected by industry standard technology and codes of ethics.

For purposes of this Policy, the App shall be the initial point of contact between you and Envol, and will serve as initial point of collection of any personal data you may provide us.

Collection of Personal Information.

  • As a general rule, we collect both “Non-Personal Information” and “Personal Information” from our visitors and users.
  • Also, collected “Non-Personal Information” may include information that cannot be used to personally identify an individual person, such as anonymous usage data, general demographic information that we may collect, number of clicks, platform types, preferences you submit and preferences that are generated based on the data you submit.
  • Regarding “Personal Information”, visitors to the App may elect to interact with Envol in ways that require us to gather information that can be used to personally identify an individual person, such as: name (first and last), email address, password, phone number, geo-location coordinates, and personal picture. We will also ask visitors who sign up for the App to provide a username and email address.
  • Profile Data which includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data which includes information about how you use our website, products and services.
  • Marketing and Communications Data which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the App. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
  • We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
  • Third party credential data which allows you to open an account and login into our App or Site, along with other single sign on authentication services such as those provided by Facebook and Google, among others. Henceforth, if you elect to sign up using your social media credentials, by such action, we will collect your personal data as provided by such third-party platforms, but never more than the data such platforms can disclose according to your user agreement with them. If you close your social media account, or if you deauthorize our access, your access to our platform may be suspended. For more information, please read the terms and policies of such third-party platforms.
  • When you purchase a digital product subscription, we will collect your name and email address.

If you fail to provide some of the required Personal Data, where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Personal Information and data retention.

We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we will 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 you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Purpose of Personal Information Collection.

We will store your Personal Data for the purposes of managing your collaboration with other users and clients, improve your user experience, send newsletters and contact you about inquiries for our services. Overall, we use the collected Personal Data to provide and improve our services. Accordingly, we will generally collect, use and disclose your Personal Data to:

  • Provide, operate, maintain, improve, and promote our platform and our products and services.
  • Verify your e-mail address and other account notices.
  • To manage payment processing, charges, orders, shipments, refunds and complaints.
  • Develop, research, process, safeguard and improve our services.
  • Conduct research, analysis, and surveys, to the extent that you have provided consent to receive such communications under applicable law.
  • Offer promotions, newsletters, send service-related announcements and contact you about inquiries for our products and services, to the extent that you have provided consent to receive such communications under applicable law.
  • To notify you about updates or changes to product and service features and other content.
  • To identify groups of users by general geographic market (such as zip code, state or country).
  • To account for applicable sales taxes based on zip codes provided to our payment processors for purchases made through the App, as applicable.
  • To serve our advertisements to you through third party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent for such uses under applicable law
  • Investigate and prevent fraudulent transactions, unauthorized access to our services, and other suspicious activities.
  • Monitor and analyze trends, usage, and activities in connection with our products and services and for marketing or advertising purposes.

Envol will keep any collected Personal Data only as long as it is necessary, with regard to the purpose of its processing. Upon the case of Personal Data which is stored by our sub-processors, the data will be stored on their secure servers as indicated on their respective privacy policies from time to time.

Disclosure of Personal Information.

We, or our affiliates, clients, contractors, licensors, officers, agents and/or representatives, reserve the right to allow access to any of your Personal Data when we think it is reasonably important or when you violate the terms mentioned in this policy. Hereafter, we will have the right to disclose any or all gathered Personal Data and/or data, when the following circumstances arise: (i) if necessary under an applicable law; (ii) in reply to a legal demand or subpoena from an agency of the law ; (iii) to protect ourselves and our affiliates from any legal third party claims and procedures that may be brought to us (inclusive of takedown notices); and/or (iv) to prevent or cause cessation of any undertakings that may be construed by us as having the ability to be or cause a predicament or hazard to us.

In some circumstances, we may disclose Personal Data to a third party that offers and/or provides goods or services necessary for the purpose of enhancing our users’ experiences by offering you integrated or complementary functionalities, complementary services or other options.

For our service providers such as hosting, IT maintenance, market analytics, and payment service providers, we will disclose the necessary Personal Data in order for them to provide their services to Envol. Please rest assured that we require each of our service providers to agree to maintain the confidentiality and security of your Personal Data.

In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.

If our business is sold or merges in whole or in part with another business that would become responsible for providing the Services to you, we retain the right to transfer your Personal Data to the new business. The new business would retain the right to use your Personal Data according to the terms of this Policy as well as to any changes to this privacy notice as instituted by the new business. We will also retain the right to transfer your Personal Data if our company files for bankruptcy and some or all of our assets are sold to another individual or business.

With third parties, such as advertisers, in order to serve Envol’s advertisements on such third-party platforms, to the extent that you have consented to such practices under applicable law.

Third Party Tools and Personal Data Processors.

In order to provide our services, we use third-party platforms and tools. Please be aware that such platforms are governed by their own terms, policies and personal data collection practices and policies. Accordingly, by acknowledging your consent to this Policy, you are also acknowledging the applicable terms and conditions of such third-party platforms, which provide functionalities that include the creation of aggregated statistics. Envol may also collect aggregated statistics about the behavior of visitors to its Services, and may display this information publicly or provide it to others. Upon the case of any discrepancy or conflict among this Policy and the terms of them, the terms of the latter entities will govern.

For financial data, we not collect or process credit or debit card information. Apple and Google will collect such information with respect to in-app purchases made through the App. Such payment processors generally provide the option to allow for future purchases with one click or a short code number. Please read their own payment policies for more information.

We will keep a list of any sub-processors that will be involved in the processing of your Personal Data due to the provision of our service and will inform you of any intended material changes concerning the addition or replacement of sub-processors before such changes are effective, thereby giving you the opportunity to object to such changes.

Advertising, Opt-out Choice.

From time to time, we may use Google Analytics, Ad Words, Double Click and/or Ad Sense tracking codes, and other third-party software tools (such as remarketing codes) in order to collect information and marketing analytics about the manner in which you browse our platform and services.

Ads appearing on our App and Site may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Policy covers the use of cookies by Envol and does not cover the use of cookies by any advertisers.

The served ads (also called retargeting ads) will be targeted based on your previous browsing history, and may include retargeting codes. For example, third-party vendors may show you Envol’s ads on certain websites across the Internet, even after you leave our platform. The collected information is anonymized, meaning it cannot be tracked back to individuals. Using such tools, we learn how to optimize, and serve ads based on a user’s past visits, providing you with a better user experience.

We also collect data from your mobile device ID (i.e. the unique identifier assigned to a mobile device by the manufacturer) and/or Advertising ID (for App iOS 6 and later) instead of cookies in order to recognize you and track displayed web pages, along with their performance.

Like many site operators, we collect information that your browser sends whenever you visit us. This is called Log Data, which may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, sections of our Services that you visit, the time and date of your visit, the time spent on those pages and other statistics.

We do not currently offer “do-not-track” or similar mechanisms. Unlike cookies, device IDs cannot be deleted, but you can select to reset your Advertising IDs in the “Settings” section of your mobile device, among other.

You can learn more about how to opt-out by browsing Google’s opting-out and privacy pages located at www.google.com, or the Network Advertising Initiative website located at www.networkadvertising.org.

Service eligibility.

Envol does not generally provide its Services to persons under the age of eighteen (18). Users under the age of eighteen (18) may register an account with us, and in such case, they will need the express, unequivocal consent of their legal guardians.

Accordingly, we reserve the right to request any and all applicable proof of identification and consent proof from our users, at any moment, without prior notice, and at our sole and final discretion. Upon the failure to provide such proof of age, we reserve the right to immediately freeze, block or cancel the account, with no liability.

Newsletter Subscription.

Occasionally, we will ask you for express permission and approval to receive electronic messages in electronic format which are then sent to an electronic address and that contains a message asking recipients to participate in commercial activities such as newsletters, purchase of products, services and invitations to participate in surveys.

We will send you service-related announcements on occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, or a new enhancement is released, which will affect the way you use our services, we might send you an email. Generally, you may not opt-out of these communications, which are neither commercial nor promotional in nature.

If you no longer wish to receive email update and other commercial communications and messages via platforms such as ActiveCampaign or GetResponse, you may opt-out of receiving them by following the instructions included in each update or communication.

Safety of Collected Information.

All Personal Data will be stored on a secured VPS (virtual private server) using SSL certificates or analogous technology. All data uploaded by Envol containing user’s credentials will be stored in the MySQL database on our servers. The App will work mainly in ‘online’ mode, thus, continuous Internet connectivity is necessary in order to access the App. The section known as “The Toolbox” works also in offline mode.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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. The security of your Personal Data is important to us, but please remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

International Disclosure.

Your Personal Data may be accessed by us or our affiliates, agents, partners, advertisers or third-party service providers in the Netherlands, the United States and other regions. Henceforth, and you hereby consent to such access and transfer by simple disclosure. If you are accessing our platform, products and services from other regions, you ought to know that you are thereby transferring your Personal Data to such regions and, thus, you hereby consent to such transfer.

GDPR Notice and your Rights as Data Subject.

For the purposes of the GDPR, in the European Union, Envol is a “data controller” of the Personal Data you provide to us for the primary purposes of providing you with our services. For reference, Apple Google and our hosting service provider acts as our “data processor”.

For our European Union customers and users, by clicking the "I Accept" button or otherwise accepting the terms and conditions of our services through a clickable action or similar action, you hereby acknowledge, agree and unequivocally consent to the collection, process, management, treatment, transfer and authorized of your Personal Data by Envol, its affiliates and authorized third parties.

The section below covers the certain situations that you, as data subject, and we as a data controller, are most likely to see, but you should also carefully review the full list of data subject rights here: https://gdpr-info.eu/chapter-3/. You retain the right to access, amend, correct or delete your Personal Data where it is inaccurate at any time. To do so, please contact support@envol.app.

  • Right to be Forgotten: You can request us to be “forgotten”; that is, to have your entire Personal Data removed from our service. If we are asked to do this, we will remove any Personal Data you we collected from you as requester. We will also need to contact any third parties that process your Personal Data on our behalf, such as our cloud service providers. To ensure that any personal data in Envol’s possession can be removed in a timely manner, you can relay any request to be “forgotten” to us by submitting a request.
  • Right to Data Portability: Under the GDPR, our users located in the EU may request Envol to send them any Personal Data in our possession. In this case, we will provide you with any Personal Data that you have in a commonly used, machine-readable format
  • Right to Data Access: As a data subject, you can ask Envol to confirm how and where your Personal Data is being stored and processed. You also have the right to know how such that data is shared with third parties by us.
  • Right to Data Rectification: As data subject, you have the right to obtain from Envol, without undue delay, the rectification of inaccurate Personal Data concerning you.
  • Right to be Informed: You have the right to be informed about the Personal Data we collect from you, and how we process it.
  • Right to Object: You have the right to object to us processing your Personal Data for the following reasons:
    • Processing was not based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
    • Direct marketing (including profiling);
    • Processing for purposes of scientific/historical research and statistics; and
    • Rights in relation to automated decision-making and profiling.
  • Automated Individual Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
  • Right to Complain: You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the GDPR. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.

Your privacy request must include, at the least, the following information: (i) your complete name, address and/or e-mail address in order for us to notify you the response to your request; (ii) attached documents establishing your identity; and (iii) a clear and concise description of the Personal Data with regard to which you seek to enforce any of your privacy rights. If you request rectification, please indicate amendments to be made and attach documentation to back up your request.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Upon receipt of your privacy request, and after due review, we may then edit, deactivate and/or delete your Personal Data from our services within thirty (30) days. In case of secure databases under our control where deletion is impossible, we will make such information permanently inaccessible.

CCPA Notice and your Rights in California

If you are located in California, per the California Consumer Privacy Act (CCPA) you have the following rights in respect of your personal data that we hold:

a) Right of access. You may request access to the personal information that we have collected and maintained about you (along with information regarding its use and disclosure) over the past twelve (12) months upon appropriate verification of identity. You may only make such requests twice (2) per every (12) months.

b) Right to deletion. You have the right to request that we delete personal information collected and maintained about you, subject to certain exceptions. Once your request is verified and we have determined that we are required to delete that information in accordance with applicable law, we will delete your personal information accordingly. Your request to delete your personal information may be denied if it is necessary for us to retain your information under one or more of the exceptions listed in the CCPA. Please note that a record of your deletion request may be kept pursuant to our legal obligations.

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfil such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information, or a person authorized to act on your behalf (e.g. previous transactions of person to whom the request relates).

We will only use the personal information that you have provided in a verifiable request in order to verify your request. As stated above, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority. Please note that we may charge a reasonable processing fee or refuse to act on a request if the request is excessive, repetitive, or manifestly unfounded.

If you wish to exercise one of these rights, please contact us at support@envol.app and write in the subject line: “CCPA PRIVACY REQUEST – [INSERT NAME]”.

Pursuant to Section 1798.83 of the California Civil Code “Shine the Light” law on data privacy (a separate law from the CCPA), residents of California have the right to obtain certain information about the types of personal information that companies with whom they have established a business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those parties.

If you wish to exercise one of these rights, please contact us at support@envol.app and write in the subject line: “SECTION 1798.83 PRIVACY REQUEST – [INSERT NAME]”.

Governing Language.

From time to time, this Policy may be translated into other languages for your convenience. The English language version of each of these documents shall be the version that prevails and governs your use of App and our products and Services. Upon the case of any conflict between the English language version and any translated version, the English language version will prevail.

Amendments to this Policy.

Periodically, and at the final discretion of ourselves, we may update, change, suspend and/modify or our App, our Services, this Policy and/or our Terms, in whole or in part. We hereby reserve such right in order to operate our business and protect ourselves. Your use after any changes indicate your acceptance thereof and we will post a notice regarding such changes on our Services, and may also write an email to you or otherwise notify you.

Contact.

If you have any questions or comments about us, our App, our Site, our Services, our Policy or our Terms, please contact us at:

Envol B.V
Rotterdam, South-Holland, Netherlands
Email: support@envol.app
Telephone:

Date of last effective update is 27 July, 2020.

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