Privacy Policy

In this privacy policy we, Mewing.coach (“Company”, “we”, “us” or “our”), explain how we handle your personal data when you visit our website, use our mobile apps, contact us through our official social media pages or email, and/or use our services.

In case of any inquiries or if you would like to exercise any of your rights provided in this notice, you can contact us by email: [email protected].

All the definitions used in this privacy policy have the same meaning as prescribed in Company’s General Terms and Conditions unless expressly provided otherwise in this privacy policy. This privacy policy forms an integral part of Company’s General Terms and Conditions.

In the event this privacy policy is translated into other languages and if there are differences between the English version and such translation, the English version shall prevail, unless otherwise provided.

1. How Do We Use Your Personal Information?

Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event)?

NO.

Mewing.coach respects your right to privacy. Maintaining your privacy is very important to us. We do not store credit card details. All transactions are processed via our portal and are fully secure. When you visit the mewing.coach app, webpage or any pages or sub-pages related to our site, we collect information sent to us by your computer, tablet or mobile phone. The information sent to us includes your computer’s IP address, device identifiers, the operating system you’re using, your location, standard web logs or any other information available through web data. We also collect information related to our service, like contact information you submitted on our website such as your name, email, home address, phone number and other similar information.

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

1. Communicate with you;
2. Screen our orders for potential risk or fraud;
3.  When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our Customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

We may process information that you provide to us for the purpose of subscribing to our email messages and newsletters (“messaging data”). The messaging data is processed to send you the relevant messages and newsletters. The legal basis for this processing is your consent. Also, if we have already sold goods or provided services for you via our website and/or apps, and you do not object, we may also process messaging data on the basis of our legitimate interest, namely seeking to maintain and improve Customer relations.

In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Sometimes we may aggregate, anonymize or de-identify your personal data in such a way so that it cannot reasonably be used to identify you. Such data is no longer personal. We may use such data without restriction in any way allowed by law, including, but not limited to share such data with our partners or research institutions, share in articles, blog posts and scientific publications, aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users and evaluate or modify our services.

2. Personal Information We Collect

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:

1. Process your order;
2. Send you notifications about your transaction or shipment;
3. Improve our Customer support;
4. Customize, measure, and improve our services;
5. Design our website and app in consequence of the way visitors use it;
6. Deliver target marketing, service update notices, and promotional offers based on your communication;
7. Complete security checks related to the use of our services;
8. Contact you by email or by the method selected in your preferences;

When you visit our website or app, we collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse our website or app, we collect information about the individual web pages or products that you view, what websites or search terms refer you to the website or app, and information about how you interact with the website or app. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

• “Log files” track actions occurring on the website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

• “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the website.

Additionally, when you make a purchase or attempt to make a purchase through the website or app, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers and debit card numbers), email address, and phone number. We refer to this information as “Order Information”.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

3. Do Not Track

Please note that we do not alter our website or app data collection and use practices when we see a Do Not Track signal from your browser.

4. Sharing Your Data With Others

We may disclose your personal data to any member of our group of companies (including our subsidiaries, our ultimate holding Company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this notice. Such may include internal administration purposes as well as provision/sharing of IT, payment or marketing services or data centers in the group.

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We may disclose your personal data to our anti-fraud, risks and compliance providers insofar as reasonably necessary for the purposes of protecting your personal data and fulfilling our legal obligations.

We may disclose your personal data to our payment service providers. We will share service data with our payment services providers only to the extent necessary for the purposes of processing your payments, transferring funds and dealing with complaints and queries relating to such payments and transfers.

We may disclose your personal data to other service providers insofar as it is reasonably necessary to provide specific services (including, providers of servers and maintenance thereof, email service providers, service providers used for data analysis or marketing, call centers, Customer satisfaction surveys or market research). We take all the necessary measures to ensure that such subcontractors would implement proper organizational and technical measures to ensure security and privacy of your personal data.

In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Persons indicated in this Section may be established outside the European Union and European Economic Area. In case we will transfer your personal data to such persons, we will take all the necessary and in the legal acts indicated measures to ensure that your privacy will remain properly secured, including where appropriate, signing standard contractual clauses for transfer of data. To find out more information regarding appropriate safeguards you may contact us via email: [email protected].

5. How Long Do We Store Your Data?

Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. In any case it shall be kept for no longer than:

• account data will be retained for no longer than 5 (five) years following your last update on the account;

• service data will be retained for no longer than 5 (five) years following the end of provision of services;

• messaging data will be retained for no longer than 2 (two) years following the provision of consent or, in case, the messaging data is being sent to the present Clients in order to maintain and improve Customer relations, for no longer than 2 (two) years following the end of provision of the respective services, unless you respectively withdraw your consent earlier or object to such processing;

In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. I. e. device data will be retained for as much as will be necessary for the relevant processing purposes.

Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Behavioral Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt-out of targeted advertising by using the links below:

• Facebook: https://www.facebook.com/settings/?tab=ads

• Google: https://www.google.com/settings/ads/anonymous

• Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

• Safari: https://support.apple.com/en-us/HT202074

In case you consent, we will contact you via email or phone to inform on what we are up to with marketing communications

You may opt-out of receiving marketing communications at any time. You may do so by choosing the relevant link in any of our marketing messages or contacting us via means provided in our website.

Upon you having fulfilled any of the provided actions we will update your profile to ensure that you will not receive our marketing communication in the future.

In any case, the opt-out of the marketing communications will not stop you from receiving communication directly related to the provision of services.

7. Your Rights

The right to access data. You have the right to confirm as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

The right to rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data. Those circumstances include when: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing and there are no other legal basis to process data; (iii) you object to the processing under certain rules of applicable data protection laws; (iv) the processing is for direct marketing purposes; or (v) the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. Such exclusions include when processing is necessary: (i) ;for exercising the right of freedom of expression and information; (ii) ;for compliance with our legal obligation; or (iii) for the establishment, exercise or defense of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are when: (i) you contest the accuracy of the personal data; (ii) ;processing is unlawful but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data, however we will only further process such data in any other way: (i) with your consent; (ii) for the establishment, exercise or defense of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

The right to data portability. To the extent that the legal basis for our processing of your personal data is consent; or performance of a contract or steps to be taken at your request prior to entering into a contract, necessary to enter into such, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

In addition to specific measures provided in this section or the website you may also exercise any of the rights indicated herein by contacting us by email [email protected].

8. About Cookies

Cookies are small textual files containing an identifier that is sent by a web server to your web browser on your device (a computer or a phone) and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. We will ask you to consent to our use of cookies in accordance with the terms of this notice when you first visit our website.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use:

•Required cookies – used to ensure proper performance of the website, security of Customers and their data, provision of high-quality services;

•Functional cookies – used to enhance the website user experience, analyze the use of the system and in accordance to such improve the provision of services;

•Advertising cookies – used to observe user online behavior and optimize marketing campaigns according to such information.

Cookies used by our service providers. Our service providers use cookies and those cookies may be stored on your computer when you visit our website. We may use:

•Google Analytics cookies to observe our website traffic. Cookies used for this purpose help us detect website errors as well as measure website bandwidth.

•Youtube cookies to display in our website content uploaded in Youtube. Cookies used for this purpose help us maintain integrity, create informative and dynamic websites.

•Doubleclick cookies to control the display of ads to our users. Cookies used for this purpose help us distinguish users that already use our services and reduce or stop displaying our ads to such users.

•Facebook cookies to manage the display of ads to our users. Cookies used for this purpose help us distinguish users that already use our services and reduce or stop displaying our ads to such users.

•Google Tag Manager cookies to control advertising cookies. Cookies used for this purpose help us properly distribute ads to users.

•Hotjar cookies; to observe how users use our website. Cookies used for this purpose help us observe the performance of the website and analyze how we can improve our website.

•Mouseflow cookies; to observe how users use our website. Cookies used for this purpose help us observe the performance of the website and analyze how we can improve our website.

How can you manage cookies?

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via information provided in the relevant browser website, for example Chrome; Firefox; Internet Explorer; Safari.

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

Third party websites

 In the website you may find links to and from partner sites, information sources and related party websites. Please take note that such third party websites that you will visit by clicking on links have their own privacy policies and we take no responsibility regarding such privacy policies. We recommend familiarizing with privacy policies of such websites before providing any personal data to such.

9. Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Any changes to this notice will be published in the website and, in case of material changes, we may inform you about such via email or by other means which we will deem the most fitting in a particular case.

10. Minors

The Site is not intended for individuals under the age of 18.

11. Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected].

Last modified 5th Apr 2022