Privacy Policy

Why you Need a Privacy Policy


Privacy Policy applicable to Personal Data collected on the Website

This page was last updated on 11 March 2024.

Article 1. Introduction and scope

This Privacy Statement (the 'Statement') applies to Personal Data collected on the website https://www.healthoptimizationhub.com (the 'Website'), offered, owned and provided by:

Health Optimization Hub, a limited liability company under UAE law, with its registered office at media city, Sharjah, UAE; hereinafter "HOH", "we" or "us" HOH considers the protection of privacy very important and wants to inform, respect and give you - as a visitor to its Website - as much control as possible over what happens to your Personal Data and your privacy.

Article 2. Contact details

HOH is responsible for the Processing of your Personal Data that you make available through the Website and has the role of Controller for your Personal Data processed through the Website.

Article 3. Definitions

In the context of the service, "personal data" qualifies as all information we collect and process about our users that can be traced back to an identified or identifiable natural person. This term is to be understood broadly and includes, for example, your name, your date and place of birth, your mobile phone number, your address as well as other information related to your physical, mental, economic or cultural condition when these can be linked to you. Exactly which Personal Data is all collected and processed by us is further explained below.

The 'processing' of Personal Data means, inter alia, the automated operation or set of operations such as the collection, recording, organisation, structuring, storage, updating or alteration, retrieval, consultation, use, dissemination or making available by any means, assembly, combination, archiving, erasure or ultimate destruction of Personal Data

All capitalised indications not defined in this Declaration have the meaning defined in the AVG.

By visiting the Website, sharing your Personal Data and agreeing to this Statement, you expressly consent to the way HOH collects and processes your Personal Data as described in this Statement.

Article 4. Principles of data collection

The following principles will be observed when processing your Personal Data:

  • Personal Data will be obtained and processed lawfully, fairly and transparently.
  • Personal Data will be processed only for specified, explicit and legitimate purposes.
  • Care shall be taken to ensure that Personal Data is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
  • The Personal Data will be kept accurate and, where necessary, updated.
  • Personal Data will not be kept longer than necessary for the purpose(s) for which it was obtained.
  • Personal data is kept safe and secured.
  • We are responsible for and can demonstrate compliance with obligations under data protection legislation; and
  • Respond to requests from data subjects to exercise their data protection rights.

Article 5. What Personal Data are collected and processed?

HOH processes different types of Personal Data depending on the services you use on the Website. The Personal Data below are processed by HOH when you visit the Website:

Profile information
First name, last name, address, e-mail address, phone number, VAT number, company name, etc.
Financial information
bank account number, IBAN, etc.
Medical information
body substances (saliva, cheek mucosa.), raw physical and medical data (lifestyle data, i.e.: sleep pattern, sports, stress, eating habits, diet)
History and logs
browsing behaviour, date and time the Website was visited, date and time of registration on the Website, shopping basket information, etc.
Technical information
Data from computers, phones or other devices you use the Website with, your IP address, browser type, etc.
Cookies
For more information, see our Cookie Policy

Where Personal Data of a third party is disclosed through the Website or for the purpose of visiting the Website, the person transmitting the Personal Data warrants that he or she has informed that third party and obtained all necessary consents to share the Personal Data of that third party through the Website.

Article 6. What is the purpose and basis of processing your Personal Data?

The purpose and basis of processing your Personal Data depends primarily on the category of Personal Data in question. Below is an overview of the purpose and basis of the different Personal Data we process.

Profile information
Target
Profile data is collected when you create a profile on the Website, to process orders you place on the Website, to keep the Website functioning properly and to send e-mails regarding promotions, offers, products, etc.
Basic
Performance of the contract and legitimate interest
Financial information
Target
Financial information is collected by my fatoorah (the third-party, specialist provider and operator of payment services and payment platforms, as described in HOH Terms and Conditions) for the processing of orders you place on the Website, specifically payment processing, etc.
Basic
Performance of the contract and legitimate interest
Medical information
Target
Medical information is collected to conduct your DNA analysis and prepare the DNA report.
Basic
Explicit consent
History and logs
Target
Data related to history and logs are collected to ensure the proper functioning and personalisation of the website, for analysis and to send you emails to "continue shopping" when certain products remain in your shopping cart.
Basic
Legitimate interest
Technical information
Target
Technical information is collected to personalise the Website and for location-based services.
Basic
Legitimate interest
Cookies
For more information, see our Cookie Policy.

Below we describe in detail each basis for Processing that applies:

The legitimate interest as a basis is justified with regard to technical information and history and logs as it is important for HOH to adapt and improve its Website based on that information. The fact that HOH processes this information also ultimately benefits users.

For some specific processing activities, we request your consent. The consent you give is free at any time and you have the right to withdraw it at any time. A withdrawal of consent does not affect the processing of Personal Data (i) prior to such withdrawal and - in the case of Personal Data for which another processing ground is available - (ii) on the basis of a legitimate reason for processing Personal Data (iii) in the case of a legitimate interest in processing.

The above Personal Data may be provided directly by you, or may be collected by our business partners (e.g. contact details of healthcare companies) and/or customers (pseudonymised health and biometric data), or other third parties. The foregoing reasons may not be exhaustive and HOH has the right to process your Personal Data for any other legitimate reason at any time. In such cases, HOH will notify you of that reason as soon as possible and to the extent your consent is required, request your consent before commencing the processing. An update to this Statement may constitute such notice.

Article 7. Receiving and sharing personal data

HOH receives your Personal Data, including when:

  • you visit the website
  • you register on the Website
  • you contact HOH via the Website
  • you place orders via the Website
  • you provide medical data to HOH

HOH applies the principle of minimum data processing when processing your Personal Data and shares your Personal Data with third parties only when necessary for the proper functioning of the Website.

Processors and sub-processors of HOH always act under the responsibility of HOH. If HOH uses processors or sub-processors, this will always be done under a processor agreement that meets the requirements of the AVG and protects your Personal Data as much as possible. In doing so, HOH will ensure that the processors and sub-processors have taken the required technical and organisational measures for processing your Personal Data.

Furthermore, HOH refrains from sharing or disclosing your data with third parties except in the cases below:

  • Personal Data may be shared with third-party service providers to whom HOH has outsourced certain processing activities. In any case, they will be limited to processing your Personal Data in accordance with our instructions and a data processing agreement will be concluded, obliging them to comply with all obligations imposed by applicable data protection legislation
  • If required by applicable laws or regulations.

Your personal information may be shared or transferred to the following entities and for the following purposes:

Entity
Responsibility
Google Analytics
The Personal Data is transferred to optimise the Website. Personal Data is transferred to send direct marketing messages.
Robostore
Personal Data is transferred to process your order through the Website.
My fatoorah payments
Personal Data is transferred to process your order through the Website, including to process payment for your order. My Fatoorah Payments is considered responsible for processing your financial data. Personal Data is transferred to process your order through the Website, including to process the payment of your order. My fatoorah is considered responsible for processing your financial data.
Laboratories and (genetic) experts
The Personal Data is transferred to perform your DNA analysis and compile the DNA.

This list will evolve and be updated regularly. An updated version will be made available if any changes are made.

If you are redirected to another website, platform or application via the Website, different terms and conditions, privacy and cookie policies may apply. You should take into account the terms and conditions, privacy and cookie policies of those other applications, websites or platforms. We encourage you to read these terms and conditions, privacy and cookie policies of the other applications, platforms and websites you visit.

Article 8. Direct marketing

HOH may use your Personal Data for direct marketing purposes in accordance with the restrictions thereon in the AVG to the extent you have given your consent. This way HOH can keep you informed about its products, updates, events, etc. You may withdraw your consent at any time or object, free of charge, to the processing of your Personal Data for such marketing purposes.

For these direct marketing purposes, including profiling related to direct marketing, you have the right to object free of charge at any time by sending an e-mail to privacy@healthoptimizationhub.com.

Article 9. How will my personal data be stored?

HOH applies the following retention periods for your Personal Data:

Profile information
Maximum 5 years after you have made your Personal Data available on our Website, or a longer retention period if and as long as you do not delete your profile or HOH has a legitimate interest.
Financial information
The duration determined by Mollie and Shopify Payments.
Medical information
Maximum 5 working days after you send an email to HOH confirming that you have received your DNA analysis by HOH.
History and logs
A maximum of 5 years after you have made your Personal Data available on our Website, or a longer retention period if and as long as HOH has a legitimate interest or is required to do so pursuant to a legal provision.
Technical information
Maximum 5 years after you have made your Personal Data available on our Website, or a longer retention period if and for as long as HOH has a legitimate interest or pursuant to a legal obligation.
Cookies
For more information, see our Cookie Policy .

Article 10. How will my Personal Data be protected?

HOH has implemented appropriate technical and organisational measures and safeguards to process your Personal Data in accordance with applicable Belgian and European regulations, and in particular, without limitation, to protect your Personal Data against loss, misuse or unauthorised modification . HOH uses a team of technicians, automated systems and advanced technology such as:

  • Secure Socket Layer (SSL) technology protects information by using server authentication and data encryption;
  • Data is stored in a secure data centre;
  • All passwords are encrypted;
  • Credit card or bank account information is processed by Mollie in accordance with secure protocols and other security measures established by Mollie;
  • All transactions are processed through a gateway provider and are not stored or processed on our servers.
  • Entering into processor agreements with suppliers;

HOH makes all reasonable and appropriate efforts to maintain the confidentiality of your Personal Data.

Despite HOH's aforementioned measures, you should be aware that there are always risks associated with sending Personal Data over the Internet. The security and protection of your Personal Data can never be fully guaranteed.

Article 11. Amendments to the Declaration

HOH may amend this Statement at any time. The top right-hand corner of the Statement displays the date of the last amended version. Changes will be posted on the Website so that you are always aware of what information HOH collects, how HOH uses it and how HOH shares it.

Amended versions of this Declaration will come into force ten (10) days after publication on the Website and will be submitted for approval at any time, if necessary.

Article 12. Authorisation for release

acknowledge, confirm and expressly agree that HOH may disclose your Personal Data if required to do so by law or if HOH determines in good faith that such disclosure is required to:

1. comply with any ongoing judicial investigation, court order or legal process relating to the website; 2. respond to claims against HOH in relation to Personal Data that violate the rights of third parties; 3. protect the rights, property and safety of HOH, its employees, users and the public.

HOH may disclose your Personal Data to competent police or judicial authorities or other government agencies if necessary or required in the context of an investigation of fraud, intellectual property infringement or any other harmful activity, or if HOH reasonably suspects that such activity may expose HOH or yourself to liability.

Article 13. Liability

If HOH has lawfully provided your Personal Data to a third party (other than a Processor or Subprocessor), HOH will not be liable for any unlawful processing or use by that third party.

Under no circumstances does HOH accept responsibility or liability for any direct or indirect damage arising from any error or unlawful use of Personal Data by a third party (other than a Processor or Subprocessor).

Nor will HOH be liable if third parties process or use your Personal Data unlawfully and HOH has taken appropriate technical and organisational measures to prevent such unlawful processing or use

Article 14. Applicable law and jurisdiction clause

This Declaration shall be governed, interpreted and implemented in accordance with UAE law, which is exclusively applicable to any dispute.

The courts of Dubai, UAE, shall have exclusive jurisdiction to adjudicate any dispute that may arise from the interpretation or performance of this Declaration, subject to the right of the consumer to submit a dispute to the competent court on the basis of a mandatory provision of law.