Privacy Policy

1. INTRODUCTION

This Privacy Policy applies to the Personal Data we collect about members and other consumers who interact with Anteprima Brands International or use our services, including visiting our websites or our social media pages, or using our mobile apps and devices (collectively, the "Services"). We are not responsible for the policies and actions of parties that are not under our control, whether they are companies or individuals, and we are not responsible for the information, products, or services of third parties that may be accessible through our services.

2. HOW WE COLLECT PERSONAL DATA

We collect Personal Data about you from:

⦁ Yourself, when you provide such information directly to us, such as when filling out your profile.

⦁ Our devices that you use.

⦁ Automatic data collection, such as cookies, local storage objects, web beacons, and other similar technologies in connection with your use of the Services.

⦁ Customers and partners, such as employers, insurance companies, or other organizations that interact with our Services.

⦁ Marketing and advertising partners, who may provide us with data related to your interactions with our Services, ads, or communications.

⦁ Social media platforms, accounts, connected devices, or features, if you interact with our social media pages, post content using the Services, access the Services through a third-party site or service, or otherwise connect accounts, devices, or features to your Predictia account.

⦁ Data providers, such as information services and data providers, when we integrate your data.

3. PERSONAL DATA WE COLLECT

We may collect the following types of Personal Data:

⦁ Contact Data, such as your first name, last name, email, mailing address, and phone number.

⦁ Profile Data, such as the username and password you use to create an account to use our services, as well as any photographs or information you choose to include in your profile.

⦁ Communications we exchange with you, including when you contact us via email, web app, or mobile app with questions, feedback, or reviews.

⦁ Data about your physical state, such as resting heart rate, heart rate variability, skin temperature, blood oxygen dissaturation level, and acceleration; metadata about workouts and sleep; type of physical activity performed and its duration; data reflecting exertion and recovery; physiological profile, including age, gender identity, weight, height, fitness/athletic level; and details you choose to send us related to your diet, medications, and women's health monitoring.

⦁ Payment and transaction data needed to complete your orders on the website or through the Services.

⦁ Marketing data, such as your preferences for receiving our marketing communications.

⦁ Data about your device(s), such as operating system, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type, IP address, unique identifiers, language settings, mobile operator, radio/network information, and general location information such as city, state, or geographic area.

⦁ Geolocation data, such as GPS, IP address, and movement on certain types of exercise if you give ANTEPRIMA BRANDS INTERNATIONAL permission to do so.

⦁ Online activity data, such as pages or screens viewed, time spent on a page or screen, website visited before ours, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.


4. COOKIES AND SIMILAR TECHNOLOGIES

ANTEPRIMA BRANDS INTERNATIONAL uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript
(collectively "Cookies") to enable our servers to recognize your web browser and tell us how and when you visit and use our Services, as well as to analyze trends, learn about our user base, and manage and improve the Services.


Use and Types of Cookies
Anteprima Brands International Ltd uses the following Cookies:

⦁ Essential Cookies: Essential cookies are necessary to provide you with functionalities or services you have requested. For example, some cookies allow you to access secure areas of our Services. Disabling these cookies may render certain features and services unavailable.

⦁ Functional Cookies: Functional cookies are used to record your choices and settings regarding our Services, maintaining your preferences over time and recognizing you when you return to our Services. These cookies help us personalize our content for you, greet you by name, and remember your preferences (such as your region).

⦁ Analytical/Performance Cookies: Analytical/performance cookies allow us to understand how users utilize our Services by collecting information on how often a user interacts with a particular feature of the Services. We use this aggregated data internally to improve the Services. Analytical/performance cookies also help us measure the effectiveness of our advertising campaigns to enhance campaigns and content for those who interact with our advertising.

⦁ Marketing Cookies: Marketing cookies collect data about your online activity and identify your interests so that we and our advertising partners can provide marketing that we believe is relevant to you.


Options for opting out of online tracking
There are a number of ways in which you can opt out of certain online advertising and tracking activities, which we summarize below: - Blocking cookies in your browser settings: Most browsers allow you to remove or reject cookies, including those used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings.
⦁ Blocking Ad ID use in mobile device settings: Your mobile devices may offer settings that allow you to make choices about the collection, use, or transfer of your Ad ID associated with your mobile device for interest-based advertising purposes.
⦁ Use of privacy plugins or browsers: You can block our websites from setting cookies for interest-based advertisements by using browsers with privacy capabilities, or by installing browser plugins such as Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third-party cookies/trackers.
⦁ Advertising industry opt-out tools: You can also use these opt-out options to limit the use of your information for interest-based advertising by participating companies: the Digital Advertising Alliance, Digital Advertising Alliance for mobile apps, and Network Advertising Initiatives.
Some opt-out features rely on cookies, which means that when you use these features, a "opt-out" cookie will be placed on your computer or device, indicating that you do not wish to receive interest-based advertising from certain companies. If you delete your cookies, use a different browser, or use a different device, you will need to renew your opt-out choice.
Opting out of interest-based advertising does not mean that you will no longer receive online ads. It just means that those ads will no longer be tailored to your specific browsing habits or interests. You may continue to see ads on and about the Service.


5. HOW WE USE PERSONAL DATA

We process Personal Data to manage, improve, understand, and personalize our Services. We use Personal Data for the following purposes:
⦁ Service provision, including to provide, manage, improve, develop, understand, and personalize the Services and our business. - Research and Development. We may create and use Aggregate Data, Anonymized Data, or other anonymized data from Personal Data we collect, including Wellness Data, for our business purposes.
⦁ Direct Marketing and Advertising. We may use data from the Personal Data we collect, including Health Data and certain data collected when you browse our website, to send you direct marketing offers or advertise the Services or other product offerings
ANTEPRIMA BRANDS INTERNATIONAL.
⦁ Interest-based advertising. We work with our advertising partners, including third-party advertising companies and social media companies, to advertise our Services. We do not share your Health Data with advertising partners.
⦁ Compliance and Protection, including to protect against or deter fraudulent, illegal, or harmful actions and maintain the security and integrity of our Services; comply with our legal or contractual obligations; resolve disputes; and enforce our Terms of Use and Terms of Sale.

6. HOW WE SHARE PERSONAL DATA

We may share your Personal Data with:
⦁ Service providers who provide services to us or act on our behalf.
⦁ Advertising partners who may collect information about our website through cookies and other automated technologies, including for the interest-based advertising purposes described above.
⦁ Professional advisors, such as doctors, lawyers, auditors, bankers and insurers, where necessary as part of the professional services they provide.
⦁ Authorities and other parties, including law enforcement, government authorities, and private parties, where we believe in good faith that it is necessary or appropriate to comply with the law or legal process.
⦁ Transferee parties, such as purchasers and other relevant participants in business transactions involving ANTEPRIMA
BRANDS INTERNATIONAL.


7. HOW TO EXERCISE PRIVACY CHOICES

You can exercise certain privacy choices, as described below:
⦁ Access, update or delete your data by logging into your account.
⦁ Privacy settings, such as searchability of your profile.
⦁ Geolocation Data, enabling or denying ANTEPRIMA BRANDS INTERNATIONAL the collection of such data from your mobile device settings.
⦁ Your Health Data, by disabling the collection of additional Wellness Data by unchecking your device's
Predictia association from your mobile device.
⦁ Marketing Communications, by unsubscribing or following the opt-out instructions in the marketing message.
⦁ Online Advertising and Tracking, by using the opt-out tools described in the Notice.

8. YOUR RIGHTS

You have the following rights regarding your Personal Data:

⦁ Right of access: You can request information about the Personal Data we hold about you and a copy of that Personal Data.
⦁ Right to rectification: You can request the correction of inaccurate or incomplete Personal Data we have about you.
⦁ Right to erasure: You can request the deletion of your Personal Data, within the limits permitted by law.
⦁ Right to object to processing: You can object to the processing of your Personal Data, within the limits permitted by law.
⦁ Right to restriction of processing: You can request the restriction of the processing of your Personal Data, within the limits permitted by law.
⦁ Right to data portability: You can request to receive a copy in a structured, commonly used, and machine-readable format of the Personal Data you provided to us, within the limits permitted by law.
⦁ Right not to be subject to automated decision-making: You can object to being subject to a decision based solely on automated processing, within the limits permitted by law.

To exercise your rights, you can contact us by writing to privacy@predictia.life. We will consider your request in accordance with applicable laws.

In responding to a request to exercise your rights, we may ask for information necessary to verify your identity and for security purposes. We may need to retain certain Personal Data to fulfill our legal or contractual obligations to you, as well as Aggregate Data or anonymized Data derived from or including your Personal Data that do not identify you.

9. STORAGE OF PERSONAL DATA

We will retain your Personal Data as long as necessary to fulfill the purposes for which it was obtained or to comply with our legal and regulatory obligations.
We will determine the appropriate retention period by considering the amount, nature and sensitivity of the Personal Data, the potential risk of harm from the unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes by other means, and applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use that information without further notice to you. Once the applicable retention periods have expired, your Personal Data will be deleted. Unless otherwise required by law, we will delete your Personal Data within a reasonable period of time upon your request.
HOW TO CONTACT US
If you have any questions about this Privacy Policy or wish to exercise your rights as above, you may contact us by e-mail:
privacy@predictia.life

10. OTHER SITES AND SERVICES
The Services may contain links to websites and other online services operated by Third Parties. Additionally, our content may be integrated into web pages or other online services not associated with us. These links and integrations do not constitute an endorsement or a statement of affiliation with any Third Party. We do not control the mobile applications, websites, or online services offered or operated by Third Parties and are not responsible for their actions. You can learn about and control how these Third Parties use and share your Personal Data by reviewing their privacy notices and exercising the privacy choices that the Third Party may offer.

11. SECURITY AND RETENTION OF PERSONAL DATA
We employ a variety of security measures designed to protect the Personal Data we collect. While we strive to protect the privacy of your account and other Personal Data in our possession, no security measure is perfect, and we cannot guarantee the security of your Personal Data.
We retain Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, as long as we have a business interest in doing so, or as required by law.

12. PERSONAL DATA OF MINORS
If you are under 18 years of age, please do not attempt to register for the Services or send us any Personal Data about yourself. If we become aware that we have collected Personal Data from a minor under 18, we will delete that information as quickly as possible. If you believe that a minor under 18 may have provided us with Personal Data, please contact us at privacy@predictia.life.

13. CHANGES TO THIS PRIVACY POLICY
We are constantly striving to improve our Services, so we may need to modify this Privacy Policy from time to time. We will communicate any changes by posting a notice on the Predictia website, sending you an email, and/or through other means. Your use of the Services after the publication of any changes to the Privacy Policy constitutes acceptance of those changes.

14. CONTACT US
For any questions or concerns about our privacy policy, please send us a detailed message at privacy@predictia.life or at the following mailing address.

Anteprima Brands International, Inc.
Attn: Legal Department
1 Ferris Building, St Luke street
PTA1020, Gwardamangia
Malta

15. PRIVACY POLICY FOR EUROPEAN RESIDENTS

If you are a resident of the European Economic Area, the United Kingdom, or Switzerland ("Europe"), you may have additional rights under the General Data Protection Regulation ("GDPR") or other European data protection legislation.

Data Controller and European Representatives
ANTEPRIMA BRANDS INTERNATIONAL, Inc. will be the data controller of your Personal Data processed in connection with the Services. Our contact details are as follows:

Anteprima Brands International, Inc.
Attn: Data Protection Department
1 Ferris Building, St. Luke Street
PTA1020, Gwardamangia
Malta
Email: info@predicti.life

Legal Bases for Processing

Use and Types of Cookies
Anteprima Brands International Ltd uses the following Cookies:

⦁ Essential Cookies: Essential cookies are necessary to provide you with functionalities or services you have requested. For example, some cookies allow you to access secure areas of our Services. Disabling these cookies may render certain features and services unavailable.

⦁ Functional Cookies: Functional cookies are used to record your choices and settings regarding our Services, maintaining your preferences over time and recognizing you when you return to our Services. These cookies help us personalize our content for you, greet you by name, and remember your preferences (such as your region).

⦁ Analytical/Performance Cookies: Analytical/performance cookies allow us to understand how users interact with our Services by collecting information on how often a user engages with a particular feature of the Services. We use this aggregated data internally to improve the Services. Analytical/performance cookies also help us measure the effectiveness of our advertising campaigns to enhance campaigns and content for those who interact with our advertising.

⦁ Marketing Cookies: Marketing cookies collect data about your online activity and identify your interests so that we and our advertising partners can provide marketing that we believe is relevant to you.

The "How we use Personal Data" section above explains how we use your Personal Data. We will only process your Personal Data if we have a legal basis for doing so. Legal bases for processing include consent, contractual necessity, and our "legitimate interests" or the legitimate interests of third parties, but will depend on the type of Personal Data and the specific context in which we process it. However, the legal bases we usually rely on for each category of processing activities are set out below.

⦁ Provision of services: processing is necessary to fulfill our contract or to take actions you request before using our Services.
⦁ Research and development: these activities constitute our legitimate interests.
⦁ Marketing and advertising: processing is based on your consent where such consent is required by applicable law.
⦁ Compliance and protection: if necessary to comply with a legal obligation, if it is necessary to protect the vital interests of the user or others, or if it is necessary for a task carried out in the public interest.
⦁ Consent: to the extent that the Wellness Data we collect is considered health data or another special category of Personal Data subject to the GDPR, we ask for your explicit consent to process such data.

Retention
To determine the appropriate retention period for your Personal Data, we consider the quantity, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether we can achieve those purposes through other means, as well as applicable legal, regulatory, tax, accounting, or other requirements.

Data Subject Rights
You have certain rights regarding your Personal Data, including:

⦁ Access: you can request more information about the Personal Data we hold about you and request a copy of that Personal Data.
⦁ Rectification: you can ask for the correction of inaccurate or incomplete Personal Data we have about you.
⦁ Erasure: you can request the deletion of your Personal Data.
⦁ Withdrawal of consent: if we are processing your Personal Data based on your consent, you have the right to withdraw that consent at any time.
⦁ Restriction of processing: you can ask us to restrict further processing of your Personal Data.
⦁ Data portability: you can request to receive a copy in a structured, commonly used, and machine-readable format of the Personal Data you provided to us.
⦁ Objection: you can contact us to let us know that you oppose further use or disclosure of your Personal Data for certain purposes.
⦁ File a complaint: you have the right to file a complaint about our Personal Data processing practices with the supervisory authority in your country or the EEA member state.

For more information about these rights or to submit a request, please email privacy@predictia.life. We will consider your request in accordance with applicable laws.


16. DEFINITIONS

We use some specifically defined terms in our Privacy Policy and when we communicate our Privacy Policy. We want to be clear about how the terms we use are defined to help you better understand our policies.

Aggregate Data
Cookies
De-identified Data
GDPR
IP Address
Personal Data
Services
Third Parties
Predictia Devices
Health Data

Aggregate Data: Aggregate Data is data that has undergone a process by which raw data is collected and expressed in a summary form for the purpose of statistical analysis. Raw data can be aggregated over a given time period, among multiple individuals, or both, to provide statistics such as mean, minimum, maximum, sum, and count. After the data have been aggregated, analysis can be performed to gain insights into particular data sets. When data are aggregated over a number of individuals, the resulting aggregation is considered anonymized such that it is no longer Personal Data.


Cookies: Cookies are small files stored on the user's computer. They are designed to hold a modest amount of data specific to a particular user and Web site and can be accessed by either the Web server or the user's computer.


Anonymized Data: Anonymized Data is data in which all personally identifiable information has been removed, anonymizing the data by removing information that would allow identification of the individual from the remaining data. Data are "anonymized" to protect the privacy and identity of individuals associated with the data. Anonymized Data is no longer Personal Data.


GDPR: The General Data Protection Regulation or GDPR is a data privacy and security regulation under European law that sets guidelines for the collection and processing of personal information from individuals living in the European Economic Area, Switzerland, and the United Kingdom.
IP Address: An IP address is a unique address that identifies a device on the Internet or on a local area network. It allows a system to be recognized by other systems connected through the Internet.


Personal Data: Personal Data is any data that identifies or relates to you as a specific individual, including information referred to as "personally identifiable information" or "personal information" under applicable data protection laws, rules or regulations.


Services: Services means, collectively, our websites and mobile apps, any software embedded in the Predictia device(s) and any features, content or applications offered, from time to time, by ANTEPRIMA BRANDS INTERNATIONAL in connection therewith.


Third Parties: As part of the relationship between ANTEPRIMA BRANDS INTERNATIONAL, Predictia users (our end users), and third parties, third parties are defined as entities or companies that are involved in an agreement, contract, transaction but are not one of the primary parties (i.e. ANTEPRIMA BRANDS INTERNATIONAL). We use third parties to enable us to provide services to our members, such as for transaction charging or data storage. Third parties also include advertisers who serve interest-based advertisements to visitors to our website.

Predictia devices: Your Predictia devices consist of sensors that, when used in combination with the Services, collect certain types of Personal Data.


Health Status Data: Health Status Data is (a) data collected by your Predictia device(s) and sent to the Predictia platform, including heart rate, heart rate variability, ECG Data, sleep duration, respiration rate, skin temperature, blood oxygen saturation level, and data such as the type of activity you engage in, the duration of your physical activity, and others; and (b) any additional information you enter while using our Services, such as information about your health and well-being, including information collected from accounts, devices, or features that you link with your Predictia account.

17. In-app purchases

(a) As of January 2020, the App does not offer in-app purchases; however, the App reserves the right to offer in-app purchases at a later time.
(b) The App may offer Content or Features to be used within it that are available in exchange for a payment of a sum of money.
(c) In-app purchases consumed while using the App cannot be transferred between Devices and can only be downloaded once.
(d) You must authenticate your Account before making in-app purchases, separately from any authentication required to obtain other Content.