Privacy Policy

1 Data Controller Information

We are committed to protecting your personal data at the highest level. This document explains what personal data we process and for what purposes.

2 Contact Information

If you have any questions or concerns about data processing, please contact us:

• Email: [email protected]
• Location: Ho Chi Minh City, Vietnam

To request correction or deletion of your personal data, please email us at the address above.

3 Data Collection & Purpose

The scope and purpose of data collection depends on how you use our services:

Automatically Collected Data (Website Visitors)

To enable service delivery, protect intellectual property, and for statistical purposes, we process data characterizing how users interact with our website:

• IP address from which you connect
• Statistical information about pages viewed
• Device type, operating system, browser type
• Screen resolution, color depth
• Internet service provider
• Entry address to the website

This data is collected solely for statistical purposes and website optimization to ensure the best user experience, which constitutes our legitimate interest. This data is never combined with other personal data.

Newsletter Subscribers

If you provide your email address for this purpose, we deliver newsletter services containing health information and promotional content about our services. Providing this data is voluntary but necessary for newsletter delivery.

Legal basis: Legitimate interest in connection with your consent.

Email Communication

When you contact us via email, you provide your email address as the sender. Additionally, you may include other personal data in the message content. We may ask for additional information only when necessary to handle your inquiry.

Legal basis: Legitimate interest in connection with consent, consisting of the need to resolve the reported matter and potential claim defense.

Potential Clients

We process personal data of potential clients, including name, company name, and contact details for:

• Proposing our services - legal basis: legitimate interest
• Potential claim establishment, pursuit, or defense - legal basis: legitimate interest in protecting our rights
• Archival purposes - legal basis: legitimate interest in archiving offers for statistical and analytical purposes
• Taking pre-contractual steps - legal basis: actions at your request before contract conclusion

Clients, Partners & Contact Persons

If you are a client, partner, client representative, or designated contact person, we process your data for:

• Contract execution (including complaint handling) - legal basis: necessity for contract performance
• Legal obligations arising from tax and accounting regulations - legal basis: legal obligation
• Claim-related purposes and proper contract execution - legal basis: legitimate interest in protecting our rights
• Identification of authorized representatives for proper contract preparation - legal basis: legitimate interest
• Maintaining contact during contract execution - legal basis: legitimate interest

4 Health Information (Special Category Data)

Types of Health Data We May Collect

• Bloodwork results and laboratory test data
• Medical history relevant to health coaching
• Current health symptoms and concerns
• Health goals and lifestyle information
• Supplement and medication information
• Diet and exercise habits

Purpose of Health Data Processing

• Service delivery: To provide personalized health coaching and bloodwork analysis
• Progress tracking: To monitor your health improvements over time
• Protocol development: To create customized health protocols based on your unique data

Legal Basis for Health Data Processing

We process health data based on your explicit consent, which you provide when engaging our services. You may withdraw this consent at any time by contacting us.

Health Data Protection Measures

• Health data is stored separately from general personal data
• Access is limited to authorized personnel only
• All health data communications are encrypted
• We never share health data with third parties for marketing purposes

5 Data Retention

Data retention periods depend on the legal basis and purpose of processing. Generally, data is processed:

• For the duration of service provision
• Until consent withdrawal
• Until effective objection is raised
• Until effective data deletion request

Retention may be extended when processing is necessary for establishing, pursuing, or defending claims, and subsequently only if required by law.

6 Your Rights (GDPR Compliance)

We guarantee the exercise of all rights of data subjects, including the right to:

• Access your data - including obtaining a copy of your personal data
• Rectification - correction of inaccurate or incomplete data
• Erasure ("Right to be Forgotten") - deletion of your personal data
• Restrict processing - limitation of data processing in specific circumstances
• Data portability - receiving your data in a structured, machine-readable format
• Withdraw consent at any time (without affecting lawfulness of prior processing)
• Object to processing based on legitimate interests
• Lodge a complaint with relevant supervisory authority

For EU/EEA residents: You have the right to lodge a complaint with your local data protection authority if you believe your rights have been violated.

7 Data Sharing & Disclosure

Personal data may be transferred to data processors acting on our behalf based on appropriate agreements. Such entities process data exclusively according to our instructions, maintaining confidentiality and security. We retain the right to control how data is processed.

We Do NOT:

• Sell, trade, or rent your personal information to third parties
• Share health data for marketing purposes
• Transfer data to countries without adequate protection measures

We MAY Share Data With:

• Service providers: Website hosting, email services, payment processors - bound by data protection agreements
• Legal authorities: When required by law or to protect our legal rights
• Professional advisors: Accountants, lawyers - bound by professional confidentiality

In other cases, personal data may be disclosed only to entities authorized by law.

8 Cookies Policy

Our website uses cookies - small text files placed on your device via web browsers. These files allow storing certain information on your device and subsequent reading by the website that created them.

We Use Cookies For:

• Website customization: Adapting content to individual preferences and optimizing user experience
• Statistics: Understanding how users interact with our website to improve structure and content
• Marketing: Delivering relevant advertising content matching your preferences

Types of Cookies We Use:

• Necessary Cookies: Essential for basic website functionality - always active
• Analytics Cookies: Help us understand how visitors interact with our website
• Marketing Cookies: Used to deliver personalized advertisements
• Functional Cookies: Enable enhanced functionality and personalization

Managing Cookie Preferences

Your browser typically allows storing cookies by default. However, you can change cookie settings at any time. To modify cookie settings, please check your browser's help documentation.

If you don't agree to cookie placement, you can block them through browser configuration. However, we cannot guarantee proper website functionality with cookies disabled.

You can also manage your preferences through our cookie consent banner at any time by clicking the cookie settings button at the bottom left of the screen.

9 Third-Party Tools & Partners

To provide and improve our services, we use tools and services from other entities. These entities fulfill only the purposes we specify.

Booking & Scheduling

We use booking tools (such as TidyCal/Calendly) to schedule consultations. When you book a session, your name, email, and selected time slot are processed by these services.

Communication Tools

We may communicate via WhatsApp for client support. WhatsApp's privacy policy applies to messages sent through their platform.

Analytics

We may use analytics tools to understand website usage patterns. These tools use cookies and similar technologies to collect anonymous usage data.

Payment Processing

Payments are processed through secure third-party payment processors. We do not store complete payment card information on our servers.

10 Data Security

We implement appropriate technical and organizational security measures to protect your personal information, including:

• SSL/TLS encryption for data transmission
• Secure password policies
• Regular security assessments
• Limited access to personal data
• Staff training on data protection

However, no method of transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

11 Policy Changes

This Privacy Policy is regularly reviewed and updated as necessary. The current version was adopted and is effective from November 30, 2025.

We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date. For significant changes, we may also notify you via email.

12 Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have concerns about how we handle your data, please contact us: