Privacy policy

Initial Effective Date: May 1, 2019
Latest Revised Date: May 1, 2019

Introduction

This Privacy Policy provides guidance and information to users who make use of the Services (defined below) provided by Olive Health Technology LLC (“Olive”) regarding the processing of Personal Information by Olive. For the purposed of this Privacy Policy, “Personal Information” means any information related to an identifiable individual or that may be used to identify an individual.

Olive (“us”, “we” or “our”) is a company and registered in the United States (EIN 82-2561609) and having its registered office address at 16192 Coastal Hwy Lewes, DE 19958, USA. Olive is committed to protecting and respecting your privacy. This Privacy Policy describes how we collect, store, use and distribute Personal Information through our software, website, documentation, and related services (together, the “Services”).

Please read this Privacy Policy carefully to understand our treatment and use of Personal Information.

In this Privacy Policy, references to “you” means the person whose personal information we collect, use and process.

We will use your Personal Information only for the purposes and in the manner outlined below, which describes the steps we take to ensure the processing of your Personal Information is in compliance with the Data Protection Act 2018 and any subsequent data protection and privacy legislation, European Union law including Regulation (EU) 2016/679 (known as the General Data Protection Regulation or GDPR) and any subsequent amendments (collectively referred to as “Data Protection Legislation”).

Please note that by using our Services, you acknowledge that you have read, understood and agree to this Privacy Policy.

We seek to maintain the privacy, accuracy, and confidentiality of data (including your Personal Information) that we obtain during your use of the Services.

For the purposes of the European General Data Protection Regulation (the GDPR):

Olive is the Data Controller as a supplier of services, an employer, and where dealing with its suppliers;

Our representative may be contacted at admin@olivehealthtech.com.

All Olive Platforms

If you choose to create a user account, you will be asked to provide an email address so that we can identify you to comply with your potential request to delete or access your data. If you decline to provide your email address, your information is not linked to you in any identifiable way.
Conversations with Olive are not shared with any other company or service. We will never sell or give away your Personal Information or conversation history.

Facebook Messenger

Olive only sees your activity within the conversation. We receive basic information from Facebook: first name, locale, timezone, to personalize the experience. We do not access your Facebook profile, and do not have access to your news feed or friend list. We do not post anything to your Facebook wall or notify your friends that you are using Olive. If you choose to share a GIF, photo or video from your conversation with Olive, however, they may see that it’s from the Olive page.
Conversations with Olive within Facebook Messenger are subject to the Facebook privacy policy. Facebook can see that you are talking to Olive, and they can see the content of the conversations.
Facebook’s Privacy Policy can be found here: https://www.facebook.com/privacy/explanation.

Changes to our Privacy Policy

We may change this Privacy Policy from time to time. If we make any changes, we will notify you by posting a notice on our Website and/or contacting you, as appropriate. We encourage you to review this Privacy Policy each time you use our Website or our Services.

Processing of Personal Information

How and why do we process your Personal Information?
When you use the Services, we may collect and process different Personal Information about you. The Personal Information we process, the basis of processing and the purposes of processing are detailed below. Sometimes, these activities are carried out by third parties (see “Sharing of Personal Information” section below). 

We encourage you to supply only the information you are comfortable with.

Where does Olive obtain my Personal Information from?
Most of the Personal Information we process is obtained from you when, through the application you: register for an Olive account and exchange text or button messages with Olive. Other types of Personal Information may be obtained from third parties, including, for example, your name and timezone from Facebook. We do not obtain data from any other 3rd parties.

Sharing of Personal Information

1. Internally within Olive
Your Personal Information will be held by Olive’s team. Your Personal Information will only be shared internally with members of the team, managers and IT staff if access to the data is necessary for the performance of their roles. Olive takes appropriate steps to ensure that such personnel is bound to duties of confidentiality with respect to your Personal Information.

2. Service Providers
We use third party service providers who provide technical and support services to help us improve the product. In providing the services, these third party service providers may have limited access to databases of user information or registered member information solely for the purpose of helping us to improve the product and they will be subject to contractual restrictions prohibiting them from using the Personal Information of our members for any other purpose. Such agents or third parties do not have any rights to use Personal Information beyond what is necessary to assist us.
We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your Personal Information. We will have written contracts with them which provide assurances regarding the protections that they will give to your Personal Information and their compliance with our data security standards and international transfer restrictions.

3. Disclosure through Facebook Messenger with third parties
You may be able to share Personal Information with third parties through use of the Services. The privacy policies of these third parties are not under our control and may differ from ours. The use of any information that you may provide to any third parties will be governed by the privacy policy of such third party or by your independent agreement with such third party, as the case may be. If you have any doubts about the privacy of the information you are providing to a third party, we recommend that you contact that third party directly for more information or to review its privacy policy.

Users that access Olive via the Facebook Messenger platform are also subject to Facebook’s privacy policy.

Facebook’s Privacy Policy can be found here: https://www.facebook.com/privacy/explanation.

4. Disclosure to other third parties
In certain circumstances, we share and/or are obliged to share your Personal Information with third parties for the purposes described above and in accordance with Data Protection Legislation.

These third parties include:

  • administrative authorities (tax or social security authorities)
  • financial institutions
  • insurances
  • police, public prosecutors
  • external advisors

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Transfer outside the European Economic Area

Your Personal Information may be transferred, stored and processed in one or more countries outside the European Economic Area (“EEA”), for example, when one of our service providers use employees or equipment based outside the EEA. For transfers of your Personal Information to third parties outside of the EEA, we take additional steps in line with Data Protection Legislation. We will put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights, e.g. we will establish an adequate level of data protection through EU Standard Contractual Clauses based on the EU Commission’s model clauses.
For information about the adequate security safeguards that have been put in place, you can reach out to admin@olivehealthtech.com.

Securing of Personal Information

Olive operates and uses appropriate technical and physical security measures to protect your Personal Information.

We have in particular taken appropriate security measures to protect your Personal Information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, in connection with your job application.

Access is only granted on a need-to-know basis to those people whose roles require them to process your Personal Information. [In addition, our service providers are selected carefully to ensure they have an appropriate level of technical, organizational and security measures.]

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your Facebook password, and safeguard your user name, password and personal credentials when you are using the Services, so that other people will not have access to your Personal Information. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.

Storage of Personal Information

Your Personal Information will be encrypted and stored in our primary datastore for analytical processing.

We will keep your Personal Information for as long as it is necessary to fulfil the purposes for which it was collected as described above and in accordance with our legal and regulatory obligations. This may mean that some information is held for longer than other information. We will keep your information for no longer than is required or permitted.

Your rights

You may have various rights under data protection legislation in your country (where applicable).
These may include (as relevant):

1. The right of access enables you to check what type of Personal Information we hold about you and what we do with that Personal Information and to receive a copy of this Personal Information;

2. The right to object to processing of your Personal Information where that processing is carried out on the basis of our legitimate interests. We will stop using your Personal Information unless we can demonstrate an overriding legitimate ground for the continued processing of this Personal Information;

3. The right to rectification enables you to correct any inaccurate or incomplete Personal Information that we hold about you;

4. The right to erasure enables you to request that we erase Personal Information held about you in certain circumstances;

5. The right to restrict processing of your Personal Information by us in certain cases, including if you believe that the Personal Information held about you is inaccurate or our use of the Personal Information is unlawful; and 

6. The right to data portability enables you to receive your Personal Information in a structured, commonly used and machine readable format and to have that Personal Information transmitted to another data controller.

Where our processing of your Personal Information is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful. You may exercise any of the above rights by contacting admin@olivehealthtech.com. Where Olive is acting as the Data Processor, you should contact the Data Controller, i.e. the entity with which the User has a relationship, to exercise these rights.

If you are a resident of the European Union, you may also lodge a complaint with your local privacy commissioner or other Supervisory Authority with respect to our processing of your Personal Information. The local Supervisory Authority in each European country can be found here.

1. For website users:

Upon request of the data, the User will be emailed a link to a personalized dashboard page, hosted on our website protected by the User’s login information. On the dashboard, the User will find a button to request a copy of their data. Users who indicate that they would like to retrieve their data, will be sent an email that contains an individualized link to use to download a .zip file containing their data files. This link can be used one-time only and is only active for 60 minutes.

2. For Facebook Messenger users:

Currently there is no ability to wipe conversation history from messenger which prevents us from fully implementing our privacy process above. For this reason, Olive will not send data to Facebook Messenger users, however, they may retrieve it from Facebook by following their procedures outlined in their privacy policy.
If you wish to exercise any of the above rights, please contact us (see “Contact Us” below).

Contact Us

For further information or if you have any questions or queries about this Privacy Policy, please contact Olive’s representative, can be reached at admin@olivehealthtech.com