PRIVACY

Last updated: 9th March 2023

Juniver Limited (”Juniver”, “we”, “us”, “our”) is committed to respecting and protecting your privacy,
and we are also registered with the UK Information Comissioner’s Office as a Data Controller (company reg. no 12614569).

This Privacy notice describes our practices regarding any personal information we collect from you when you use our services (”Services”), such as when you:

• Visit our website at www.joinjuniver.com, or any website of ours that links to this privacy notice,
• Download and use our mobile app (Juniver),
• Engage with us in other related ways, including any marketing or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you still have any questions or concerns, please contact us by email at hello@joinjuniver.com.


1. What information do we collect?

We may collect the following categories of information that may, alone or in combination with other information, constitute Personal Data:

Personal information that you disclose to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. It may include information like your name, username, email address and contact preferences. We also collect your gender.

When necessary, with your consent or as otherwise permitted by applicable law, we may also ask for information revealing race or ethnic origin. This data is not required to be provided in order to use Juniver.
We use this information that you provide to enable you access to our Services, such as the Juniver app, to communicate with you and to assist our interpretation of your eating problems, as symptoms can vary by age, gender and other characteristics.

Health information that you provide to us.
When necessary and with your consent, we may collect the following information about your health.

• Information about your eating habits (including, but not limited to frequency and type of binging and/or purging habits);
• Information about pre-existing medical conditions;
• General information about your mental and physical wellbeing.

We use this information that you provide to deliver a personalized program, and to ensure the safety and efficacy of our Services.

Application data that you provide to us.
If you use our mobile app, we also may collect the following information if you choose to provide us with access or permission:

Push notifications. We may request to send you push notifications regarding your account or certain features of the application. If you wish to opt out from receiving these types of communications, you may turn them off in the 'Settings' of your Juniver app or your mobile device.

Information automatically collected.
We automatically collect certain information when you visit, use, or navigate our Services. This information may, alone or in combination with other information, constitute Personal Data.

This information may not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Log and usage data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services, device event information (such as system activity, error reports) and hardware settings.
Device data. We may collect device data such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location data. We may collect location data such as information about your device’s location, which can be either precise or imprecise. You can opt out of allowing us to collect this information by disabling your Location setting on your device.

Cookies. Like many businesses, we also collect information through cookies and similar tracking technologies. A cookie is a piece of text stored on your computer or mobile phone by your web browser. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal experience. We use two broad categories of cookies:

• First-party cookies, served directly by us to your computer or mobile device.
• Third-party cookies, which are served by our partners or service providers on our app. This includes Google Analytics — for more information on their cookies, see the official Google Analytics page.

Example uses of these cookies include recognizing you when you return to our Services, maintaining data you’ve entered across multiple sessions, and storing information about your personal preferences.

Disabling cookies. You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals.

Non-identifiable information.
We may use Personal Data about you in aggregated data sets. Once aggregated, the information no longer constitutes Personal Data, and such aggregated data would be used for supporting generalized statements (e.g. “women under the age of 40 are more likely to restrict food”).


2. How do we process your information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. With your consent, we may also process your information for other purposes.

Specific reasons we process your information include: allowing you to create and log into your Juniver account (as well as keeping it in working order), in order to respond to your inquiries and solve any potential issues you might have with the requested service, to request your feedback on our Services or to better understand how they are being used so we can improve them.


3. What legal bases do we rely on to process your information?

We only process your information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so, including:

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. This consent can be withdrawn at any time.
Performance of a contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
Legitimate interests. We may process the information that you provide to us as well as automatically collected information when we believe it is reasonably necessary to achieve our legitimate business interests, and those interests do not outweigh your interests and fundamental rights and freedoms.


4. When do we disclose Personal Data?

Juniver prioritizes the confidentiality and safety of your Personal Data. As such, we have policies in place to help protect it from improper use and disclosure.
We follow a Minimum Necessary Access Policy so any required disclosure of Personal Data about you is minimized. The following categories describe the ways in which we disclose Personal Data to persons and entities outside of Juniver. We do not disclose this data to third parties for any purpose materially different from the purpose(s) for which it was originally collected. There are some uses and disclosures that may require your specific consent.

Disclosure at your request. We may disclose Personal Data relating to your use of the Services when requested by you. This disclosure at your request may require written authorization by you.
Third-party service providers. In connection with the Services, we may use third-party service providers. Examples of third-party services providers include accounting services, server hosting, and email delivery providers, business associates, software analytics vendors and other business partners and reputable companies who subcontract to us. We may disclose Personal Data about you to our third-party services providers so that they can perform the services.
Threat to health or safety. We may use and disclose Personal Data about you when necessary to prevent a serious threat to your health and safety, or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.
Legal obligations. We may use and disclose Personal Data where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Business transfers in the event that we buy or sell any business or assets. We may disclose or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.


5. How long do we keep your information?

We will only keep your Personal Data for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of your Juniver account.

When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it, or if this is not possible then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.


6. Do we collect information from minors?

We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such a minor dependent’s use of the Services.

If we learn that Personal Data from a minor has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us by email at hello@joinjuniver.com.


7. What are your privacy rights?

In some regions (like the EEA, UK and Canada), you have rights that allow you greater access to and control over your personal information. These may include:

(i) The right to view the Personal Data we have collected about you. In order to receive this information, please contact us by email at hello@joinjuniver.com. The first copy of this information is provided for free and in electronic form.

(ii) The right to correct Personal Data. If there is incorrect Personal Data within the Services that you are not able to change, please contact us by email at hello@joinjuniver.com and we will work directly with you to update your Personal Data.

(iii) The right to delete Personal Data. You can request your data to be deleted by closing your account in the ‘Settings’ section of your Juniver app. In any case where there may be a legal requirement to hold on to your data, we will notify you of this.

(iv) The right to withdraw consent to the processing of your Personal Data. Please note that without consent to process your personal or health information, we won’t be able to provide our Services to you. Contact us by email at hello@joinjuniver.com to withdraw your consent. We will consider and act upon any request in accordance with applicable data protection laws.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the email footer. You will then be removed from marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for administration and use of your account, to respond to service requests, or for other non-marketing purposes.

If you have questions or comments about your privacy rights, contact us by email at hello@joinjuniver.com.


8. Updates to this notice

We will update this policy as necessary to stay compliant with relevant laws. The updated version will be indicated by a revised “Last updated” date and the updated version will be effective as soon as it is published.

If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.


9. How can you contact us about this notice?

If you have questions or comments about this notice, you are always welcome to contact us by email at hello@joinjuniver.com. Data controller contact details: Juniver Limited, 1 Bolton Road, London, England, NW8 0RJ. Email: hello@joinjuniver.com.

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