KETAVIP PRIVACY POLICY

1. ABOUT OUR PRIVACY POLICY 

When you use KetaVIP, you trust us with your personal data. We’re committed to keeping that trust and protecting your personal data.  That starts with helping you understand our privacy practices. 

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.

Along with our Terms of Service and Cookie Policy, this policy explains how we (KetaVIP LLC) collect and handle your information across our website, mobile app and other services. We’ll review this policy from time to time to make sure it’s up-to-date. If we make changes, we’ll post the latest version here. When we make significant changes, we’ll let you know when you next access our services, or by other communications.

Learn more:

You’ll come across the term ‘personal data’ a lot in this policy. By that, we mean any information relating to you as an identifiable individual. For example, this includes information that may of itself identify you such as your name, contact details, internet protocol (“IP”) address, cookie strings or device IDs, as well as information that may not on its own identify you, but which we store alongside such identifiers, such as how you are using our services or the country you are in when you do so.

We can only speak for ourselves so this policy doesn’t cover the collection or use of your information by any of the service providers (let’s call them “Service Providers”) we feature. That means when you apply for treatments, your information will be processed by them in accordance with their own privacy policy and terms and conditions. But don’t worry, we’ll always find partners who also protect personal data.

How will we notify you of changes to this policy?

We’ll notify you before we make changes to this policy and give you the opportunity to review the revised policy before you choose to continue using our Services.

2. Why and how do we use your personal data?

We only use your information where you’ve given us your consent, where it’s necessary to deliver the services you’ve requested, where it’s necessary to exercise or comply with legal rights or obligations, or for normal business purposes of the kind set out in this policy.

How we use personal data:

  • Ensuring our services are accessible and usable by you on your specific device, for example by altering the way we display information to you based on your device type;
  • Generating results in response to your search queries, for example providing you with a list of the treatment options that best meet your requirements;
  • Contacting you with messages, notifications or alerts that are necessary in order to deliver our services and/or your treatments, such as confirmation emails or other essential communications like notifications about changes or updates to our services or to this policy, our Cookie Policy or our Terms of Service;
  • Responding to communications you have sent us, such as via our customer service help center or on social media;
  • Displaying reviews, images and any other content and media you submit or upload to KetaVIP (we’ll call this “User Content”), and providing you with the tools to manage and delete this User Content; 
  • Where you have created an account with us, maintaining and administering this and ensuring that it is kept up-to-date and accessible; and
  • To improve or optimize our services and to otherwise protect or further our legitimate interests. This includes pretty serious reasons like fraud prevention and security but also fun ones like product enhancement so we can keep making KetaVIP even better.

Our legitimate interests:

  • Security and fraud-prevention purposes, for example by storing your IP address to record where a request has originated from, or to protect our services against misuse of our APIs or from automated software agents. 
  • Providing customer service or help services to you in relation to any questions you raise or issues you might encounter while using our services. 
  • Understanding and evaluating how, when and why people are using KetaVIP for the purposes of delivering, evaluating, improving and optimizing the delivery of our services. For example:
    • a) monitoring the numbers of users who …..;
    • b) analyzing at an aggregate level what different groups of users may be viewing or clicking on within our services in order to better understand which features or functionality are more popular or helpful than others;
    • c) reviewing and moderating any User Content that you upload to KetaVIP;
    • d) running A/B tests that display alternate versions of our services to different groups of users, in order to evaluate the positive or negative impact of such changes on our users’ experience of our services. For example, we may change the prominence of a button, its color or its placement for different users visiting our site to help us understand how to make our service easier to use or to more effectively draw users’ attention to the most relevant and important information; and
    • e) measuring the effectiveness of our communications through recording and analyzing whether emails we have sent you have been opened. 
  • Personalizing your experience of our services in order to ensure your experience on KetaVIP is as helpful, efficient and relevant as possible. For example:
    • a) we will use cookies to remember your language and currency preferences and may also personalize your experience by highlighting or recommending certain information or treatment options that we believe are relevant to you based on your search history on KetaVIP and use of our services;
    • b) if you have asked us to send you newsletters or other marketing communications, we may tailor the timings or content of these to reflect what we believe will be of most interest to you;
    • c) we may use your location information to provide you services or information; 
    • d) displaying relevant advertisements to you about our services or other services that we think may be of interest to you;
    • e) personalizing your experience by creating a profile and timeline of your activity. However, we are careful to ensure that our activities do not involve undertaking any profiling or automated decision making that might have any legal or other significant effects on you; and
    • f) using your data to train our machine learning algorithms to help us personalize the services. We will not use directly identifying information such as your contact details for these purposes.
  • Informing strategic business decisions through creating aggregated datasets of anonymized data that allow us to generate helpful insights into patterns or trends within the labor industry.
  • Contacting you in order to invite you to participate in genuine market research.

Where we process your personal data based on a legitimate interest we will only do so where the processing is relevant, adequate and limited to what is necessary for the purpose for which it was collected. And of course, we’ll always ensure our legitimate interests don’t unfairly impact on your own rights and freedoms.

When we have your consent.

We will obtain your consent for purposes such as:

  • sending you emails for services you request such as new treatments;
  • sending you direct marketing communications via email, push notification or other means where you have consented to us doing so;
  • storing certain cookies on your device, where doing so requires consent; and
  • recording and evaluating feedback you give us.

Where we process your personal data based only on your consent, you can withdraw this consent at any time either by using the functionality provided within the appropriate product feature or by contacting us.

Where it’s necessary to exercise or comply with our own legal rights or obligations.

We may need to retain and use your information in connection with legal claims, or for compliance, regulatory and auditing purposes. For example, we may retain information where we are required by law, or if we are compelled to do so by a court order or regulatory body. Also, when you exercise any applicable legal rights you have to access, amend or delete your personal data, we may request identification and verification documents from you for the purpose of confirming your identity.

 

3. What personal data do we collect?

Everyone who uses our services will have bits and pieces of information about them collected, stored and processed. However, we don’t collect more information than we need.

We can’t help you find your dream treatment without information. So, when you use our services, we have to collect, keep and share some personal data and ask that you agree to that in line with this policy. We collect information in these ways:

 You give it to us voluntarily

Information you choose to give us might include personal data needed for you to find treatment. This includes name, surnames, contact details, etc.  It can also include content like reviews or to share with other clients, or chatting with others. Most importantly, it’s always up to you whether or not you choose to give us this kind of information.

We generate or collect it automatically

We generate or collect some information from your computer or device automatically as you use our services. This includes stuff like your IP address, information about the device and browser you are using to access our services, and the website URL you visited us from. It also includes details of the treatment requests you have made or treatments you have received via KetaVIP. We may also know your location from your mobile or your IP address. This helps us to improve your experience and make sure you receive the information that’s most relevant to you.

Our services are not intended for children under 18 years of age, and no one under the age of 18 should provide any information to, on or via our services. We don’t knowingly collect personal data from children under 18, and will delete any that we learn we have collected or received.

Depending on how you interact with our services, we may collect or process the following categories of personal data via the three different ways explained above.

  • Contact Information:
    • such as your name, address, email address, telephone number and other similar information.
  • Identification information:
    • such as a copy of your passport or other identity confirming documentation which may contain information like your name, address, gender, nationality and date of birth.
  • Background and treatment information:
    • such as your health background, prescriptions and treatment history.
  • Demographic Information:
    • your age, gender, location and preferred language when you use our services.
  • Device and Location Information:
    • generic details from your device such as your IP address, type, make, model and operating system of your device;
  • specific location data based on GPS data from your mobile device (when you grant us access to this information via your device settings); and
  • non-specific location based on your IP address.
  • Usage and Profiling Information:
  • your KetaVIP search history and treatment preferences; and
  • how you’ve interacted with our services, including time you spend on our site and/or app and the pages, features or functionality you have accessed.
  • Preferences Information:
  • selected preferences associated with your KetaVIP account including specific consents you have given or declined, email and push notification preferences and cookies containing your advertisement preferences.
  • Communications Information:
    • includes communications we receive from you such as feedback, help requests and queries via email and other electronic communication methods such as online chat, instant messaging or social media; and
    • metadata associated with those communications, such as time and date.
  • User Generated or Provided Content:
    • content you upload to our services including comments, photos, videos, recommendations, preferences and reviews and metadata such as the time and date associated with that content; and
    • any information you submit to us during the course of any correspondence you may have with us, such as signatures, photographs, opinions, and where you are applying for a treatment with KetaVIP, details of your treatment history, health background and other similar information.
  • Social Media Information:
    • email address is automatically collected by us from third party platforms you may use to log in to KetaVIP.

4. How long do we store your personal data?

We only keep your data for as long as we need it, or are required to for legal reasons. We’ll then either delete it or anonymize it so it doesn’t identify you. We treat data differently depending on what it’s used for, but you can ask us to delete your personal data at any time.

We keep your personal data only for as long as we need to. This depends on why it was collected, or if we have a continuing legal basis to do so (such as to fulfil a contract between us, perform a service you requested or for our legitimate interests). Rest assured, if we no longer have a reason or legal requirement to process your personal data, we will delete it or store it in a way so that it no longer identifies you.

We have different retention policies for different types of personal data, taking into account:

  • The purpose for collecting the personal data;
  • How long it will take to fulfill that purpose; and
  • Any specific reason or overriding legal obligation to retain the personal data for a specific amount of time.

Also, if you have an account with us, we will keep personal data such as your email address, name and other details so you can log in and access our services for as long as you have an account. We may keep other information indefinitely – such as site activity linked to an IP address – which we use to help us understand our clients, improve our services and protect our business interests.

We may also delete User Content, which may include personal data, in accordance with our terms of service and community guidelines.

No matter how long the retention period, you can ask us to delete your personal data in certain circumstances. Find out more about how you can manage your personal data in the What are your choices and rights section of this policy.

5.When is your information shared with or collected by third parties?

We share your information only where you ask us to, where it’s a necessary part of doing business with you and providing you with the services, or where we need to for legal reasons. KetaVIP Service Providers will collect your data in line with their own policies. Sometimes companies that advertise via our services may also collect your information (see Do we use cookies or other similar technologies). Finally, companies that help us deliver our services will also collect and use your data on our behalf.

Sharing personal data with third parties who process it only under our instruction

We share information relating to our users with selected third parties who provide us with a variety of different services that support the delivery of our services (let’s call them “Third Party Providers”). These Third Party Providers range from providers of services, technical infrastructure to customer service and authentication tools. We require any Third Party Provider which handles information on our behalf to do so pursuant to contractual terms which require that the information is kept secure, is processed in accordance with applicable data protection laws, and used only as we have instructed and not for that Third Party Provider’s own purposes (unless you have explicitly consented to them doing so).

Third Party Providers may be located in, or process your information, outside of the country in which you are based. Where our use of a Third Party Provider involves the transfer of personal data from within Europe to a location outside of the European Economic Area, we will put in place appropriate measures to ensure that the personal data is adequately protected in that location, most often by applying European Commission-approved standard contractual clauses alongside robust security checks.

The types of Third Party Providers we may share elements of your personal data with include:

  • Service Providers, who receive your treatment requests;
  • providers of email management and distribution tools – for example, if you sign up to receive KetaVIP newsletters or other marketing messages we will manage the delivery of these to you using a third party email distribution tool;
  • providers of security and fraud prevention services – for example, we use these providers to identify automated software agents that might disrupt our services or to prevent misuse of our APIs;
  • providers of data aggregation and analytics software services that enable us to effectively monitor and optimize the delivery of our services;
  • providers of tracking tools;
  • providers of software platforms that assist us in communicating or providing customer support services to you – for example, we manage and respond to any messages you send to us via our help center using a third party communications management tool; and
  • providers of online cloud storage services and other essential IT support services.|

Sharing your information with third parties, or allowing them to collect it, for processing outside of our control

If you are applying for a treatment from within our platform, any personal data you submit as part of the process will be shared with the relevant Service Provider and/or a third party contracted to provide services on their behalf, in order to enable the request to be processed. 

We may also share personal data with the Service Provider for their, or our, standard verification and fraud-detection purposes. In order to prevent and detect fraud, we may share information about you with the fraud prevention services providers we cooperate with (“Fraud Prevention Providers”).

Service Providers and Fraud Prevention Providers may be located in, or process your information, outside of the country in which you are based. The regulations in these countries may not provide the same level of protection of personal data as the regulations in your own country of residence.

We will share personal data with third parties where you expressly authorize us to.

Publicly accessible personal data included in User Content such as your name, likeness and the content of reviews and posts may be shared and/or made available to carefully selected third parties with whom we have a contractual relationship for the purpose of displaying this content for their similar services.

We may share and/or make available your publicly accessible personal data such as your name, profile picture, reviews to carefully selected third parties with whom we have a contractual relationship.

Find out more about how you can manage your personal data when it is shared in this way in the What are your choices and rights section of this policy.

Certain information may also be collected from you by third parties such as advertisers, marketing networks and affiliates (see the How do we advertise section below) using cookies and similar technologies. For example, your IP address and events relating to your activity like searches you have carried out or pages you have viewed on KetaVIP may be collected and transmitted to these third parties to allow them to serve relevant advertising to you. The information that is collected in this way will never include your name, contact details or other information that would enable you to be identified in the offline world. You can find out more about advertising in KetaVIP including how you can opt out of certain types of advertising in the How do we advertise section of this policy and in our Cookie Policy.

Disclosing information for legal and other reasons

We may disclose your information where necessary to enforce our Terms of Service or other agreements, or to a prospective or ultimate buyer if KetaVIP itself (or part of our business) is sold. We may also disclose your information if necessary to prevent, detect or prosecute illegal or suspected illegal activities, including fraud, or to prevent other damage or where necessary in response to legally binding requests, legal action against us, or to enforce our rights and claims.

6. How do we keep your personal data secure?

Your data is securely stored in data centers around the world – the exact location depends on where you are when you use KetaVIP. Your data will only be processed by suppliers who provide appropriate contractual safeguards for the information they process. Sometimes your data may be stored in countries with different levels of security to your own but we always make sure their standards meet ours.

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

 We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

We store the information we collect from you on secure servers in various locations, depending on where you are in the world when you access our site. Currently, we use servers that are located in the United States. These servers are provided and/or supported by third parties acting under our instruction (see When is your information shared with or collected by third parties? for more information).

Sometimes the countries that your data is transferred to, or stored in, may have different, or less stringent, data protection and security standards than your own. However, subject to the local laws in these countries, we’ll provide the safeguards needed to protect your data regardless of location. We do this through a combination of appropriate technical, organizational and administrative security measures, and by putting in place the necessary legal contracts to backup these requirements. For example, we will only store European users’ personal data outside the European Economic Area where a European Commission-approved method of validating the transfer has been put in place.

If you have a question about the steps we take to safeguard your personal data, please contact us using the details set out in this Privacy Policy (see Who are we and how can you contact us?).

7. Do we use cookies or similar technologies?

We use cookies and similar technologies to help deliver, optimize, personalize and analyze our services and for advertising purposes.

We use a combination of cookies and other technologies such as pixels/web beacons and tracking codes (explained below) to collect information for use in line with the purposes set out in this policy.

What is a cookie?

A cookie is a small data file that is stored on your computer or device. Cookies record things like your preferences and settings, helping to give us the information we need to provide you with the most consistent and relevant experience. We also use cookies to record information about experiments or new improvements we might test to track how you use our services and find out whether they were effective.

Cookies on our website may be set by us, third parties we’re working with, or independent third parties (such as advertisers).

What are web beacons and pixels?

Web beacons or pixels are small, transparent image files inside a web page or email. We use them to understand how you interact with our services, or if you’ve redirected to a Servie Provider’s website or app. We might use the pixel to confirm if you went on to book services with them, and what you booked. We also use pixels to gather information such as whether you’ve opened an email, so that we can improve our communications to you.

What are tracking codes?

Tracking codes are snippets of code placed in the page to measure things like visits and interactions. We use tracking codes to find out more about how you interact with our services, the adverts you see and more generally, how you use us.

Please see our Cookie Policy for more information and details of the types of cookies and similar technologies we use.

8. What are your choices and rights?

If you’ve got a KetaVIP account, you can access, edit, download or delete the key personal data associated with your profile at any time by going to your Profile. From here you can also manage your subscription and marketing preferences.

You also have rights in relation to the personal data we have about you, which we explain in more detail below. You can exercise these rights by getting in touch with us via our Help Center.

If you are a resident of California, Nevada or Vermont, learn more about your rights below. 

You have the right to ask us for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you have provided to us in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). 

Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to KetaVIP processing your data, this will not affect any processing which has already taken place at that time.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority.

Notice to California Residents

Effective January 1, 2020, the California Consumer Privacy Act (“CCPA”) allows California residents, upon a verifiable consumer request and subject to applicable exemptions, to request that we give you access, and (if technically feasible) in readily usable form, to the specific pieces and categories of personal information that we have collected or shared about you. California residents also have the right to submit a request for deletion of personal information under certain circumstances that KetaVIP is not otherwise entitled to maintain.  

A California consumer may, for no fee, make the following verifiable requests to a business collecting their personal information:

  • request to know categories of personal information collected and disclosed;
  • request to know specific pieces of personal information collected; and
  • request to delete their personal information.

To submit a request under the CCPA, please contact us by emailing KetaVIP at support@ketavip.com.  For your protection, we will need to verify your identity using the personal information associated with your account before fulfilling your request. Government identification may be required. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law, which may take up to 45 days following verification of your identity. Please note that the Gramm-Leach-Bliley Act and the CCPA allows us to keep certain forms of data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. In addition, there may be certain data that we may not allow you to review for legal, security, or other reasons.

Notice to Vermont Residents

We will not share information we collect about you with non-affiliated companies except as permitted by law, including, for example with your consent or to service your account. We will not share information about your creditworthiness with affiliated and non-affiliated companies except with your authorization or consent, but we may share information about our transactions or experiences with you with our affiliates and Service Providers.

Notice to Nevada Residents

We may contact our existing customers by telephone to offer additional services that we believe may be of interest to you. You have the right to opt out of these calls. To opt out of these calls, or for more information about your opt out rights, please reach us by emailing KetaVIP at support@ketavip.com. You are being provided this notice under Nevada state law. In addition to contacting KetaVIP, Nevada residents can contact the Nevada Attorney General for more information about your opt out rights by calling 702.486.3132, emailing aginfo@ag.nv.gov, or by writing to: Office of the Attorney General, Nevada Department of Justice, Bureau of Consumer Protection 100 North Carson Street, Carson City, NV 89701-4717.

KetaVIP will not discriminate against customers exercising their rights as mentioned above. Specifically, we will not deny you services, charge you different prices for services or provide you with a different level or quality of services.  

9. COMPLAINTS

To the extent that you’re unable to satisfactorily exercise any of these rights via your account, you can do so by contacting our Data Protection Officer by post at

KetaVIP
433 Plaza Real, Suite 275
Boca Raton, FL 33436

or electronically via support@KetaVIP.com.

We are committed to protecting your personal data but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the data protection authority of the country in which you are based. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

10.Who are we and how can you contact us?

KetaVIP is a company registered in the USA.

KetaVIP is the Data Controller of any information collected from you by us.

Our registered office address is:

433 Plaza Real, Suite 275,
Boca Raton, FL 33436

Please note! When you visit our app or website, download and use our services, apply for a treatment or service, or open or maintain an account with us, you signify acceptance to the terms of this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described above. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our services.