Last Revised: April 30th, 2020
1. CONFIDENTIALITY & SECURITY
The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at firstname.lastname@example.org. Except as described under section 5 below “How We Use Your Data”, we do not provide your personal data to any third party without your specific consent, as defined by applicable law.
2. WHERE WE STORE YOUR DATA
All data you provide to us through FastHero is stored on our secure servers located in the United States. Any payment transactions will be encrypted using SSL technology; all payment data is stored with our payment processor and is never stored on FastHero’s servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of FastHero, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that you change your password frequently.
Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to FastHero; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.
3. SINGLE SIGN ON
You may be able to log-in to our Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal data (such as your name and email address) with us, and to pre-populate our sign-up form. Services like Facebook Connect give you to the option to post data about your activities on our Services or to your profile page to share with others within your network.
4. DATA WE COLLECT
We collect the following types of information as follows;
4.1 Information you provide us directly:
When you sign up to use FastHero, we may collect Personal Data about you such as: Full name or alias; Email address; and your intermittent fasting goals.
As you use FastHero, you may choose to provide personal information about your health such as: Weight; Waist/Hip; Sleep data, Exercise, Mood, Struggles, and Dietary inputs (e.g. IF Hacks such as cups of Coffee, Tea and other drinks throughout your fast).
These data sets are gathered from you in order to provide FastHero to you, or if you contact or interact with us. We may also retain any messages you send through FastHero, and may retain other information you voluntarily provide us with, including but not limited to your comments and other content. We use this information to operate, maintain, and provide to you the features and functionality of FastHero, and as further detailed below.
FastHero does not collect or process credit or debit card (“Payment Card”) data. Apple and Google collect Payment Card data with respect to in-app purchases made through the Apps, and our payment processor collects Payment Card data with respect to purchases made through the Websites. Such payment processors generally provide us with some limited data related to you, such as a unique, anonymous token that enables you to make additional purchases using the data they’ve stored, and your card’s type, expiration date, billing address, and the last four digits of your card number.
4.2 Information we may collect and/or receive from third parties:
We may receive information about you from third parties including third party social networking services. You should always review, and if necessary, adjust your privacy settings on third party websites and services before linking or connecting them to FastHero. You may also unlink your third party account from FastHero by adjusting your settings on the third party service. We also may collect information about you from third party business partners, publicly available sources and our subsidiaries and affiliates.
4.3 Mobile Analytics:
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record data such as how often you engage with FastHero, the events that occur within FastHero, aggregated usage and performance data, and where the Applications were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.
4.4 Cookies information:
When you visit our website or Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your device that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through FastHero (“Cookie”). A Cookie may also convey information to us about how you use FastHero (e.g., the pages you view, the links you click and other actions you take on FastHero), and allow us and/or our third party business partners to track your usage of FastHero over time. A persistent Cookie remains on your device after you close your browser. Persistent Cookies may be used by your browser on subsequent visits to FastHero. Persistent Cookies can be removed by following your browser's directions. A session Cookie is temporary and disappears after you close your browser. You can set your browser to refuse certain Cookies or to indicate when a Cookie is being sent. However, some features of FastHero may not function properly if the ability to accept Cookies is limited or disabled.
4.5 Log file information:
Log file information is automatically reported by your browser each time you access a web page or other content within FastHero. We may also receive log information relating to your device and your use of FastHero. When you use FastHero, our servers automatically record certain log file information (“Server Logs”). These Server Logs may include anonymous information such as your web request, Internet Protocol (IP) address, operating system, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on FastHero, domain names, landing pages, pages viewed, and other such information. The information contained in Server Logs is used to monitor, assess, manage, diagnose problems with, improve and otherwise administer FastHero.
4.6 Clear gifs/web beacons information:
“Clear Gifs” (also known as web beacons) are used to anonymously track the online usage patterns of our users. We also may use Clear Gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. You can disable the ability of Clear Gifs to track certain information by setting your browser to refuse certain Cookies. The information allows for more accurate reporting, monitoring and improvement of FastHero.
4.7 Device identifiers:
When you access FastHero by or through a mobile device (including but not limited to smart phones or tablets), we and/or our third party business partners may access, assign, collect, monitor and/or remotely store one or more unique device-specific identifiers, such as a universally unique identifier (UUID) (“Unique Identifiers”). Unique Identifiers are small data files or similar data structures stored on and/or associated with your mobile device, which uniquely identify your mobile device. A Unique Identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by us. A Unique Identifier may convey information to us about how you browse and use the FasHero application. A Unique Identifier may also be used to help you log in faster and enhance your navigation through FastHero.
4.8 Advertising identifiers:
We partner with third parties, such as Facebook and Google, to manage our advertising of FastHero on other sites or platforms as well as across your other devices based on your past visits to our Website. Our third party partners may use technologies such as cookies to gather data about your activities within FastHero to deliver such advertising to you, such as retargeting ads. We are not always able to respond to do-not-track signals. For more data about interest-based ads, including how to opt-out of having your web-browsing data used for behavioral advertising purposes, please visit www.aboutads.info/choices. Please note that this does not opt you out of being served ads. You may continue to receive generic ads on these third party platforms. You may also opt out of receiving ads across devices by adjusting your ad preference in your Google account.
We use third party trackers to let us know when users have visited FastHero by “clicking-through” our sponsored advertising or content hosted on third party platforms. FastHero use Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to FastHero and the volumes of usage of FastHero. This is done to ensure that FastHero are available when you want them and are fast. For more data on how Google Analytics processes this data, visit www.google.com/analytics.
We will acquire consent from you in order to use such trackers to the extent required by applicable law.
4.9 Location data:
When you access FastHero by or through a mobile device, we may access, collect, monitor and/or remotely store location data, which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device (“Location Data”). Location Data may convey to us information about how you browse and use FastHero. Location Data may be used to personalize and customize your experience when using the FastHero, facilitate the functionality of certain features within FastHero, and to improve FastHero. Some features of FastHero, particularly location-based services, may not function properly if use or availability of Location Data is impaired or disabled.
4.10 Commercial and marketing communications:
We use the information we collect or receive to communicate directly with you. We may send you electronic messages containing FastHero-related notices (e.g., account verification, purchase and billing confirmations and reminders, feature notifications, technical and security notices). We may also send you electronic messages containing product and/or service offerings, promotions, invitations and special offers. You can also stop receiving electronic messages (other than FastHero-related notices) from us by clicking on the "unsubscribe link" provided in such communications or by changing your account preferences or settings.
4.11 Use of certain service type information we collect:
4.12 Combining information we collect:
5. HOW WE USE YOUR DATA
We may use your information, including your Personal Data, for the following purposes:
- To analyze, operate, maintain and improve FastHero, to add new features and services to FastHero.
- To customize content and insights you see when you use FastHero.
- To suggest changes in your fasting protocol and ‘IF Hacks’.
- To provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders.
- To customize product and service offerings and recommendations to you, including third-party products and offerings (except data from Apple HealthKit).
- To send you technical notices, updates, security alerts and support and administrative messages.
- For billing (invoicing), account management and other administrative purposes, if applicable.
- To respond to your comments, questions and requests and provide customer service.
- To monitor and analyze trends, usage and activities in connection with FastHero.
- To link or combine with information we get from others or (and) from you to help understand your needs and provide you with better service (to use in training of neural networks, artificial intelligence, as well as for any other automated decision-making processing).
- To account for applicable sales taxes based on zip codes provided to our payment processors for purchases made through the Website.
- 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.
- To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of FastHero, our customers, or others. This includes exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- If you are an existing customer, we will only contact you by electronic means (e-mail or in-app communication) with information about products and services similar to those which were the subject of a previous sale to you, except if you opt-out to such communications.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- For scientific and academic research purposes.
We will not use the information gained through your use of the HealthKit framework for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers.
6. YOUR DATA RIGHTS
A recent European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users, including residents of the EU, Switzerland, and the United Kingdom to exercise those rights. As required under applicable law, the rights afforded to you are:
- A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof. We provide an easy-to-view snapshot of such data via the “Hero” tab in FastHero.
- A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, FastHero will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and FastHero may have legal or legitimate grounds for keeping such data.
- A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
- A right to data portability: you have the right to receive the personal data concerning you which you have provided to FastHero, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from FastHero. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
- A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of FastHero. FastHero may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by managing your privacy preferences by logging in to your FastHero account and following the instructions.
- A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about FastHero’s personal data protection practices.
- A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give FastHero instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email email@example.com.
- You may access your personal data to modify or update at any time via an online account, or by emailing firstname.lastname@example.org.
We will respond to your request in a reasonable timeframe in accordance with applicable law.
7. LEGAL BASES OF PERSONAL DATA PROCESSING
In accordance with GDPR, FastHero provides the following information regarding its legal bases for personal data processing:
The performance of the contract (FastHero Terms of Service) between you and FastHero for the data processing relating to your use of FastHero’s Services (including your orders and payments);
FastHero’s legitimate interest, more specifically:
- Our business interest in providing you with emails and push notifications for timely introductory materials and information about your FastHero account, FastHero features and updates, and offers to upgrade your free account to a PRO subscription account.
- Our financial interest in providing you with promotional offers and/or discounts with respect to paid subscriptions and special offerings.
- Our business interest in offering you particularized or adapted content based on your usage of FastHero.
- Our business interest in collecting data regarding your general usage activities for the purpose of improving the FastHero user experience.
- Our business interest in requesting that you partake in FastHero (in- app) surveys in order to better understand your needs and expectations.
- Our financial interest in providing you the opportunity to purchase FastHero subscriptions for the benefit of a third party through the FastHero “charity” program.
- Our business interest in providing you the opportunity to invite a “Hero” to FastHero and share information about your FastHero activities with your connected “Heroes”.
- Our business interest in providing you with customer service communications regarding your account, questions about our content offerings or your intermittent fasting practice, or any other matters directed to customer service staff, in order to have clear and easy communication with you and to respond to all your requests.
- Our business interest in collecting data related to unplanned downtime or errors in the FastHero mobile app or website.
- Our business interest in complying with our legal obligations, such as maintaining accurate financial records.
8. DATA RETENTION
The retention periods applied by FastHero comply with applicable legislation in effect on the date hereof, namely:
- For data relating to your account: such data will not be retained beyond your request that your account be deleted.
- For transactional data relating to your purchases: such data is kept for the entire period of the contractual relationship, then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not FastHero.
- For data collected based on your consent to receive our marketing communications: we will use such data until you withdraw consent or applicable law requires that such data is no longer used.
- When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.
- When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months.
Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.
9. LINKS TO THIRD PARTY SITES
FastHero may, from time to time, contain links to and from the products and services of our partner networks, scientific journals, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.
10.WITHDRAWAL OF CONSENT FOR DATA PROCESSING
To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing email@example.com.
11. SOCIAL MEDIA INTEGRATIONS
Our website and mobile app Services may include social media features, such as the Facebook Like button, and widgets, such as the “Share This” button, or interactive mini-programs. These features may collect your Internet protocol address, which page you are visiting on our Service, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing it.
12. AGE LIMITATION & CHILDREN’S PRIVACY
You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of FastHero. FastHero does not intentionally collect Personal Data from any person we actually know is under the age of 18. If you are aware of anyone under 18 using FastHero, please contact us at firstname.lastname@example.org and we will take required steps to delete such information and/or delete his or her account.
13. DATA POSTED ON FORUMS
FastHero users may have the ability to post content to one or more FastHero forums. All such users may request and obtain removal of such posted content by contacting FastHero at email@example.com and specifically identifying the content to be removed. Please be advised that any such removal does not ensure complete or comprehensive removal of all traces of the content posted on the FastHero forum(s).
BURN, LLCAttn: Compliance Officer30 N Gould, Ste RSheridan, WY 82801