1. Identity of Ultimate Health
Ultimate Health / Schnuppe UK Ltd
20 Sillwood Road
Phone: + 44 7931932017
E-mail: [email protected]
Our customers may submit inquiries regarding personal data protection, privacy and security matters to CEO Gregor Schnuppe, Ultimate Health.pro, [email protected]
2. What information do we collect?
You may visit our site anonymously.
If you choose to register on our website, four categories of data to and on behalf of you will be processed:
When you register for an account on our site, place an order, subscribe to our newsletter or respond to a survey, basic contact details are collected such as the e-mail address and name of your contact person, company name, address, phone number, VAT number, preferred language and currency, any purchase order number, any email address of invoice receivers and masked credit card or bank account details.
We collect your direct input to our cloud service WordPress (the “Service”) after login, like the domain name(s) of the website(s) where you implement the Service and configuration of the content, looks and behaviour towards website visitors (“End Users”).
“End User Data”
Data generated by End Users browsing your website(s) using the Service. When an End User submits a consent from your website(s), the following data are automatically logged at Ultimate Health:
- The End User’s IP number in an anonymized form (last three digits are set to ‘0’).
- The date and time of the consent.
- User-agent of the End User’s browser.
- The URL from which the consent was submitted.
- An anonymous, random and encrypted key value.
- The End User’s consent state, serving as proof of consent.
The key and consent state are also saved in the End User’s browser in the first party cookie “CookieConsent” so that the website can automatically read and respect the End User’s consent on all subsequent page requests and future End User sessions for up to 12 months. The key is used for proof of consent and an option to verify that the consent state stored in the End User’s browser is unaltered compared to the original consent submitted to Ultimate Health.
If you activate the Service feature “bulk consent” to enable consent for multiple websites by a single End User submission, the Service will also store a separate random, unique ID with the End User’s consent. If all of the following criteria are met, this key will be stored in an encrypted form in the third party cookie “CookieConsentBulkTicket” on the End User’s browser:
- You enable the bulk consent feature in the Service configuration.
- The End User allows third-party cookies through browser settings.
- The End User has disabled “Do Not Track” through browser settings.
- The End User accepts all or at least “preferences” types of cookies when consenting.
“System Generated Data”
The Service automatically creates and stores metadata on basis of the other types of data, e.g.:
- Subscription data, like start date, latest invoice date and the result of a mandatory VAT number validation. Issued invoices are stored so that you may access any issued invoices from within the Service Manager.
- Definitions of the cookies found when the Service has scanned your website(s), including reports on the result of each scan.
- Aggregated statistical data on End User consents.
You can issue instructions to Ultimate Health through configuration and/or execution of relevant functions offered by the Service from the Service Manager. If a specific instruction regarding personal data cannot be carried out through the Service Manager, you may send instructions to us through the help desk provided at [email protected]
You will be informed by Ultimate Health about relevant changes concerning the Service, such as the implementation of additional functions, by e-mail, if you subscribe to Ultimate Health’s newsletter from the home page of the Ultimate Health Website www.ultimatehealth.pro
3. What do we use your information for?
Any of the information we collect from you may be used for one or more of the following purposes:
4. Legal basis
4.1. EU General Data Protection Regulation (GDPR)
The processing of your data is either based on your consent or in case the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, cf. GDPR art. 6(1)(a)-(b).
If the processing is based on your consent, you may at any time withdraw your consent by contacting us using the contact information in clause 1.
In order to enter into a contract regarding the purchase of Ultimate Health Service, you must provide us with the required personal data. If you do not want to provide us with all the required information, it will not be possible to deliver the Service.
4.2. California Online Privacy Protection Act Compliance
Because Ultimate Health values your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We, therefore, will not distribute any personal information to outside parties without your consent except as stated in clause 7.
As part of the California Online Privacy Protection Act, all users of our website may make any changes to their information at any time by logging into their account and navigating to the “profile page”.
4.3. Children’s Online Privacy Protection Act Compliance
Ultimate Health is in compliance with the requirements of the Children’s Online Privacy Protection Act. We will not intentionally collect any information from anyone under 18 years of age. Our website, products and services are all directed at people who are at least 18Ult years old or older.
5. How do we protect your information?
Ultimate Health implements the following technical, physical and organizational measures to maintain the safety of your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized use, unauthorized modification, disclosure or access and against all other unlawful forms of processing.
The Service utilizes the extensive features of the cloud environment to ensure high availability, like full redundancy, load balancing, automatic capacity scaling, continuous data backup and geo-replication along with a traffic manager for automatic geographical failover on datacenter level disasters. All failover mechanisms are fully automated.
No personal data is stored permanently outside Ultimate Health’s cloud platforms. The physical security is thereby maintained by Ultimate Health’s subcontractors, see clause 7. Microsoft’s data centres comply with industry standards such as ISO 27001 for physical security and availability, e.g. by using security staff around the clock, two-factor access control using biometric and card readers, barriers, fencing, security cameras and other measures.
To ensure integrity, all data transits are encrypted to align with best practices for protecting confidentiality and data integrity. E.g. all supplied credit card information is transmitted via Paypal (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those who are authorized to access such systems and who are required to keep the information confidential.
All personnel are subject to full confidentiality and any subcontractors and subprocessors are required to sign a confidentiality agreement if not full confidentiality is part of the main agreement between the parties.
Whenever personal data is accessed by authorized personnel the access is only possible over an encrypted connection. When accessing the data in a database, the IP number of the person accessing the data must also be pre-authorized to obtain access.
On-premise devices storing personal data temporarily is at all times, except when not being actively used or relocated under uninterrupted supervision, locked in a safe. Personal data are never stored on mobile media like USB sticks and DVD’s.
Ultimate Health will at all times keep you informed about changes to the processes to protect data privacy and security, including practices and policies. You may at any time request information on where and how data is stored, secured and used. Ultimate Health will also provide the summaries of any independent audits of the Service.
All access to personal data is blocked by default, using a zero privileges policy. Access to personal data is restricted to individually authorized personnel. Ultimate Health’s Security and Privacy Officer issues authorizations and maintains a log of granted authorizations.
5.6. The ability to intervene
Ultimate Health enables your rights of access, rectification, erasure, blocking and objection mainly by providing built-in functions for data handling in AWeber, by offering the option to send instructions through Ultimate Health helpdesk and also by informing about and offering the customer the possibility of objection when Ultimate Health is planning to implement changes to relevant practices and policies.
Ultimate Health uses security reports to monitor access patterns and to proactively identify and mitigate potential threats. Administrative operations, including system access, are logged to provide an audit trail if unauthorized or accidental changes are made.
System performance and availability are monitored from both internal and external monitoring services.
5.8. Personal Data breach notification
In the event that your data is compromised, Ultimate Health will notify you and competent Supervisory Authority(ies) within 72 hours by e-mail with information about the extent of the breach, affected data, any impact on the Service and Ultimate Health’s action plan for measures to secure the data and limit any possible detrimental effect on the data subjects.
“Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of the Service.
See Ultimate Health’s Cookie Declaration at www.ultimatehealth.pro/cookie-declaration for information on the cookies we use.
7. Do we disclose any information to outside parties?
Ultimate Health does not sell, trade or otherwise transfer to outside parties any personally identifiable information.
This does not include trusted third parties or subcontractors who assist us in operating our website, conducting our business, or servicing you. Such trusted parties may have access to personally identifiable information on a need-to-know basis and will be contractually obliged to keep your information confidential.
We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property, or safety. Furthermore, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
7.2 Legally required disclosure
Ultimate Health will not disclose the customer’s data to law enforcement except when instructed by you or where it is required by law. When governments make a lawful demand for customer data from Ultimate Health, Ultimate Health strives to limit the disclosure. Ultimate Health will only release specific data mandated by the relevant legal demand.
If compelled to disclose your data, Ultimate Health will promptly notify you and provide a copy of the demand unless legally prohibited from doing so.
8. Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our website and welcome any feedback about these websites.
9. Where do we store the information?
No stored data will be transferred, backed up and/or recovered by AWeber and Hub4Mail.
9.1. Personal data location
All data are stored in databases and file repositories hosted in an AWeber data centre and Hub4Digital website supplier.
Databases are continuously backed up to enable restore to any point in time within a retention period of 35 days. Backups are stored on file storage at the same geographical location as the database.
A copy of the Account Data is also stored in Ultimate Health’s website hoster, Hub4Digital
10. Access, data portability, migration, and transfer back assistance
You may at any time obtain confirmation from Ultimate Health as to whether or not personal data concerning you are being processed.
11. Request for rectification, restriction or erasure of the personal data
You may at any time obtain without undue delay rectification of inaccurate personal data concerning you, cf. clause 5.6.
11.2. Restriction of processing personal data
You may at any time request Ultimate Health to restrict the processing of personal data when one of the following applies:
You may without undue delay request the erasure of personal data concerning you, and Cybot shall erase the personal data without undue delay when one of the following applies:
12. Data retention
12.1. Data retention policy
Account Data will due to tax regulations be retained for up to five full fiscal years from the cancellation of your Service account.
Configuration Data and System Generated Data will be erased immediately when you cancel the Service account.
End User Data will be erased on an ongoing basis after 12 months from registration, and immediately when you cancel the Service account.
12.2. Data retention for compliance with legal requirements
You cannot require Ultimate Health to change any of the default retention periods, except for the reasons for erasure pursuant to clause 11.3, but may suggest changes for compliance with specific sector laws and regulations.
Ultimate Health will cooperate with you in order to ensure compliance with applicable data protection provisions, e.g. to enable you to effectively guarantee the exercise of data subjects’ rights (right of access, rectification, erasure, blocking, opposition), to manage incidents including forensic analysis in case of security breach.
14. Terms of Service
Please also visit our Terms of Service section establishing the use, disclaimers, and limitations of liability governing the use of our website at www.ultimatehealth.pro/terms-of-service
15. Your Consent