Come On Now! PRIVACY POLICY

Company’s data collection practice

Information such as the computer's IP address, domain name (e.g., .com, .gov, or .edu), software details, and page visit information is often saved in cookies so that the organization may develop and store user profiles of website visitors. If a website uses cookies, the organization may be able to collect even more information, such as your browsing patterns, which include other sites you've visited.

Company’s user consent practice

For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether to offer you certain products and service. We will send marketing to you by SMS, email, phone, post and social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match).

Data access practice

When you use our sites or apps, we may also use cookies or similar technology to collect extra data, including:

• your IP address - a numerical code to identify your device, together with the country, region, or city where you are based
• your geolocation data- your IP address can be used to find information about the latitude, longitude, altitude of your device, its direction of travel, your GPS data, and data about connection with local Wi-Fi equipment
• information on how you interact with our services
• your browsing history of the content you have visited on our sites, including how you were referred to our sites via other websites
• details of your computer, mobile, TV, tablet, or other devices, for example, the unique device ID, unique vendor or advertising ID and browsers used to access our content

We will not collect special categories of data from you - such as personal data concerning your race, political opinions, religion, health, or sexual orientation - unless you have chosen to provide that type of personal data to us.

Data disclosure practice

To ensure, considering the state of the art, the costs of implementation, and the nature, scope, context, and purposes of the processing, as well as the risks of varying probability and severity for the rights and freedoms of natural persons, that he will apply adequate technical and organizational measures to ensure a level of security appropriate to the risk, including, where appropriate, among other things:pseudonymization and encryption of personal data.

• The pseudonymization and encryption of personal data.
• The ability of ensuring the confidentiality, integrity, availability, and resilience continued of the systems and services treatment.
• The ability of restoring the availability and access to personal data quickly in the event of a physical or technical incident.
• A process of regular verification, evaluation, and assessment of the effectiveness of the technical and organizational measures to ensure the safety of the treatment. When evaluating the adequacy of the security level, special account shall be taken of the risks presented by the data processing, in particular because of the destruction, loss or accidental or unlawful alteration of the personal data transmitted, stored, or otherwise processed, or the communication or access not authorized to such data.

Data security and protection

We do not sell, rent, or otherwise disclose personal information collected by our site to third parties in the ordinary course of business. However, certain third-party agents (ISP et al.) and other third parties performing services for the site sponsor (technical auditors, developers, order fulfillment operations) may have access to the personally identifiable information to do their jobs. You may browse our website at any time without giving us any personal information at all. Entry of any personal information is completely voluntary and is only requested from visitors that wish to receive additional information about our products and services. Personal information is defined as any information that may be used to identify you. This includes but is not limited to your name, title, employer, phone number, email address, and mailing address. Our marketing professionals may retain your personal information to keep you apprised of recent product developments or new product and service offerings. Any personal information you provide will be stored on a secure, internal server accessible only by The Health Care Group’s marketing staff. We will not sell or share this information with any other company. At any time, you may request that your personal information be removed from our marketing records, at which point you will receive no further contact from us. We will only disclose your personal information if required to do so by law or in the good faith belief that such action is necessary in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock or otherwise. We may also disclose your personal information to (1) conform to legal requirements or comply with legal process served on this website; (2) protect and defend the rights or property of our company and this website; (3) enforce its agreements with you, or (4) act in urgent circumstances to protect personal or public safety.

Retention period protocols

For all data and records obtained, used, and stored within the Company, we:

• Carry out periodical reviews of the data retained, checking purpose, continued validity, accuracy, and requirement to retain
• Establish periodical reviews of data retained
• Establish and verify retention periods for the data, with special consideration given in the below areas:
  • The requirements of the Company
  • The type of personal data and the purpose of processing
  • Lawful basis for processing the categories of data subjects
• Where it is not possible to define a statutory or legal retention period, as per the General Data Protection Regulation (GDPR) requirement, the Company will identify the criteria by which the period can be determined and provide this to the data subject on request and as part of our standard information disclosures and privacy notices.

Dormant accounts data deletion policy

If your account is dormant for up to 1 year, we shall automatically delete your data. We keep your personal data for only if we need to. How long we need your personal data depends on what we are using it for, as set out in this privacy policy. For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services. We may also need to keep your personal data for accounting purposes, for example, where you have bought a subscription. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. When you delete your account, we will keep your email address to authenticate and notify you of the account deletion. However, when you unsubscribe from marketing communications, we will keep your email address to ensure that we do not send you any marketing in future.

Your privacy and data protection rights with regard to the personal data that we hold about you

You have several rights regarding the personal data that we hold about you and you can contact us about the following rights in relation to your personal data:

• You have the right to receive a copy of the personal data we hold about you
• You have the right to correct the personal data hold about you
• Where applicable, you may also have a right to receive a machine-readable copy

of your personal data

• You also have the right to ask us to delete your personal data or restrict how it is used, consistent with the GDPR. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request
• Where applicable, you have the right to object to processing of your personal data for certain purposes
• Where you have provided us with consent to use your personal data, you can withdraw this at any time.

If we change this Privacy Policy, then we will opt-in all users (including all Medicare beneficiaries) to receive the updated Privacy Policy via your choice of an email or a pop-up screen within our platform. You may contact us with questions about this Privacy Policy via support within the platform or via email to info@comeonnow.io.