Welcome to Bello Privacy Policy (“Policy”). This Policy will explain how Olive Healthcare Inc. and Bello (“Olive”, “We”, “us”, “our”, “Bello”, or the “Company”) use the Personal Information (as defined below) we collect from you when you use our Services and Products (as defined in our Terms and Conditions). This Policy also explains the choices available to you regarding our use of your information and the procedures we take to protect your information. We suggest you read following carefully in conjunction with the Terms and Conditions. We may update this Policy periodically to reflect changes in our personal information practices with respect to the Services and the Products in applicable law. We will post a notice on our Services to notify you in advance of material changes to our Policy and indicate at the top of the Policy when it was most recently updated. If you have any questions or comments about this Policy, please contact us as specified in the Contact Us section of this Policy.

“Personal Information” is information that identifies you personally, or information from which you are identifiable, such as your name, address / country of residence, telephone number, email address, company name or in some cases your IP address and cookie IDs where this information can be combined with other information to identify you.

Topics:

• Who We are

• What data do we collect?

• How do we collect your data?

• How will we use your data?

• How will we share your data?

• How do we store your data?

• International transfer of data

• What are your data protection rights?

• How long we retain your information?

• What are cookies?

• How do we use cookies?

• What types of cookies do we use?

• How to manage your cookies

• Social Media Widgets

• Privacy policies of other websites

• Changes to our privacy policy

• Minor’s Privacy

• Notice to California Consumer Privacy Statement

• Do not track

• Your Choice

• How to contact us

• How to contact the appropriate authorities

• California Consumer Privacy Statement- Supplement

Who we are?

The company responsible for your Personal Information under this Policy is Olive Healthcare Inc. as the data controlled of your Personal Information. We are a healthcare services provider and manufacturer of Bello, a portable belly fact scanner. Our CEO is Mr. Sung-Ho Han.

What data do we collect and how do we collect your data?

We collect your Personal Information in a variety of ways.

1. Information you provide us directly

• When you create an account, you provide us with your nickname registered with social network services, gender, height, weight, waist size, birth year, email address and other basic information necessary for the Services to work.

• When you use our Services, you submit your user data to us and this user data is treated as Personal Data including your health data we collect from the Products. To the extent that information we collect is health data, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you pair your Product to your account, grant us access to your health or activity data from another service. You can withdraw your consent at any time, including changing your account settings, stopping use of a feature, removing our access to a third-party service, un-pairing your Product, or deleting your data or your account.

• When you complete your profile, you can share additional information such as your photo, personality, interests and other details about you.

• When you voluntarily complete a customer survey or other market studies, you provide us with your insights into our Services and responses to our questions.

• When you order our paid Services, you provide us with your name, address, contact information, email address.

• When you contact our customer services, we collect the information to verify your identity and the Services that you are inquiring about.

You can choose not to provide us with certain type of information (i.e. information that we request during your account creation/registration), but doing so may affect your ability to use some Services.

2. Information collected while you use our Services

When you use our Services, we automatically collect information about your use of our Services through software on your device and by other means. We collect

• Device Information- your hardware model, device hardware information, IMEI number and other unique device identifiers, phone number, serial number, sales code, access recording, current software version, MCC (Mobile Country Code), MNC (Mobile Network Code), MAC address, IP address, cookies, pixels, subscription information, operating system versions, and settings of the devices you use to access Services.

• Usage Information- how you use our Services and how you interact with other users

• Log Information- diagnostic, technical, error and usage information such as the time and duration of your use of the Service, search query terms you enter through the Services, and any information stored in cookies that we have set on your device.

• Location Information- your device’s GPS signal or information about nearby Wi-Fi access points and cell towers that may be transmitted to us when you use certain Services.

The Personal Information automatically collected is necessary to provide the Services as far as this is necessary to operate our Services (legitimate interest) with regards to our use of technical information to enhance our systems, make your usage of the Services more convenient or ensure the security of our Services. This is based on our legitimate interest as the data used for these purposes are stored for a limited period and do not allow us to personally identify a user.

Personal Information that is collected is deleted automatically after the above-mentioned purposes are fulfilled.

3. Information we receive from others 

• Other users and third parties may provide information about you if they contact us about you. Also, when you use your social media account to create and log into our account, you will share your information from your social media account with us.

• When you authorize  third party services to access your account on our Services, we may receive information about your use of such third-party services.

• We may receive information about you from our partners (i.e. embedded content providers, third-party advertisement providers, audience measurement companies, etc.)

How will we use your data?

We collect your data so that we can:

• Register you or your device for the Services;

• Provide the customized content and the Services you request and research and develop new services;

• Help protect the safety of Bello and our users, which includes blocking suspected spammers, addressing abuse, and enforcing terms and conditions and our other policies;

• Communicate with you about our Services by sending you technical notices, updates, security alerts, invoices, and other support and administrative messages;

• Provide you with customer service and respond to your request;

• Communicate with you about products, services, offers, promotions, and events, and provide other news and information we think will be of interest to you

• Monitor and analyze trends, usage, and activities in connection with our Services;

• Measure the effectiveness of ads shown on our Services;

• Personalize the Services, and provide and optimize advertisements, content, and features that match user profiles or interests; and

• Protect our rights and property and ensure compliance with legal obligations and regulatory requirements.

The reason we process your Personal Information is to perform the contract that you have with us (i.e. to provide you with the Services), to comply with legal requirements, to have our legitimate interests to do so (i.e. to manage our relationship with you).

From time to time, we may ask for your consent to use your Personal Information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Policy.

How will we share your data?

We may disclose your Personal Information with other users as per your privacy settings. We also may disclose your Personal Information to the following entities only to the extent necessary to perform the Services:

• Affiliates: your Personal Information may be shared among our affiliates related to Olive by common ownership or control for the purposes described in this Policy.

• Business partners: your Personal Information may be shared with our business partners including wireless carriers. These partners assist us with various tasks, including data hosting, maintenance, analytics, customer services, marketing, advertising, payment processing and security operations.

• Other parties: we also may disclose your Personal Information to other parties to comply with applicable laws and protect our legal rights and legal rights of our users and enforce our agreements with you.

We may ask for your consent to share your Personal Information with third parties. In any such case, we will make it clear why we want to share the information. We may use and share non-Personal Information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as Personal Information in hashed, non-human readable form, under any of the above circumstances.

[Disclosures For Residents of the United States]

We may also share all of the categories of information we collect with third party advertising entities, such as third-party advertising networks and/or data analytics providers, under circumstances that may be considered a “sale” under data privacy laws, such as the California Consumer Privacy Act.

Specifically, we share your Personal Information/Non-Personal Information with the following entities: [            ]

How do we store your data?

We use reasonable technical and organizational methods to safeguard your information, for example, by password protecting (via usernames and passwords unique to you) and using Endpoint Protector (https://www.endpointprotector.com/). Whilst we will use all reasonable efforts to safeguard your information, however, we do not promise, and you should not expect, that your Personal Information will always remain secure.

International transfer of data

Your use of Services will involve the transfer, storage and processing of your Personal Information outside of your country of residence to Korea consistence with this Policy. Also, your use of the Services may also involve the transfer, storage and processing of your Personal Information to other counties, based on your consent. For more information, please contact us as specified in the Contact Us section of this Policy.

[Disclosures For Residents of the European Economic Area and the United Kingdom]

International transfer of data

Your use of Services will involve the transfer, storage and processing of your Personal Information outside of your country of residence to Korea consistence with this Policy. Also, your use of the Services may also involve the transfer, storage and processing of your Personal Information to other counties including without limitation the United States of America, based on your consent. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring Personal Information, binding them to protect the privacy and security of your data. For more information, please contact us as specified in the Contact Us section of this Policy.

What are your data protection rights?

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request us for copies of your Personal Information. We may charge you a small fee for this service.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your Personal Information, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your Personal Information, under certain conditions.

The right to object to processing – You have the right to object to our processing of your Personal Information, under certain conditions.

The right to refusal – You have the right to refuse to provide and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your Personal Information at any time.

The right to take legal action – You have the right to take legal actions in relation to any potential breach of your rights regarding the processing of your Personal Information, as well as to lodge complaints before the competent data protection regulators.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us as specified in the Contact Us section of this Policy.

[Disclosures For Residents of the European Economic Area and the United Kingdom]

If you are a resident of EEA, in addition to the above, you have the following right:

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

How long we retain your information

We keep your Personal Information only as long as we need it for the purpose listed in this Policy and these are either for legitimate business interests, as required by law or as necessary to perform the Services to you. We may anonymize your Personal Information and retain this information for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so unless prohibited by applicable laws.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you use our Services, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

How do we use cookies?

We use cookies in a range of ways to improve your experience on our Services, including:

• Keeping you signed in

• Understanding how you use our Services

• Understanding which ads you have seen so that you do not receive the same ad each time you access our Services

• Providing you with relevant content and advertising by collecting information about your use of our Services.

What types of cookies do we use?

There are a number of different types of cookies, however, our Services uses:

• Functionality – we use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

• Advertising – we use these cookies to collect information about your visit to our Services, the content you viewed, the links you followed and information about your browser, device, and your IP address. We sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

• Essential Cookies- we use these cookies to enable you to order products and receive services from our Services.

• Performance Cookies- we use these cookies to enable us to analyze the performance and design of our Services and detect errors.

How to manage cookies

When you use an App or browser to access the Services, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. The operating system of your device may contain additional controls for cookies. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your device. The Services are not designed to respond to “do not track” signals received from browsers.

Please note, however, that some Services may be designed to work using cookies and that disabling cookies may affect your ability to use those Services, or certain parts of them.

Social Media Widgets

Our Services include social media features, such as the Facebook Like button, and widgets, such as the “Share This” button, or interactive mini-programs. These features may collect your Internet protocol address, which page you are visiting on or Services, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Products. Your interactions with these features are governed by the privacy statement of the company providing it.

Privacy policies of other websites

Our Services website contains links to other websites. Our Policy applies only to our Services, so if you click on a link to another website, you should read their privacy policy.

Minor’s Privacy

Our Services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect Personal Information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the Service.

Notice to California Residents

If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called California Consumer Privacy Statement section below.

Do not track

Your browser or App may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. The Services does not currently support Do Not Track requests.

Your Choice

We offer you certain choices in connection with the Personal Information we obtain about you.

To update your preferences, limit the communications you receive from us, or submit a request, please contact us as specified in the Contact Us section below.

The Services may offer choices related to the collection, deletion and sharing of certain information and communications about products, services and promotions that are unique to specific Services. You can access the relevant settings of each Service to learn about choices that may be available for that Service. If you decline to allow the Services to collect, store or share certain information, you may not be able to enjoy full use of all of the features available through the Services.

How to contact us

If you have any questions about our Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Olive Healthcare Inc.
Mr. Kim sangyun

Tel: +82 (2) 500 5719
Email: gdpr@olive-hc.com
Address: 12, Beobwon-ro 11-gil, Songpa-gu, Seoul, Republic of Korea

[Disclosures For Residents of the European Economic Area and the United Kingdom]

the Data Protection Officer:

Olive Healthcare Inc.
Mr. Kim sangyun
Tel: +82 (2) 500 5719
Email: dpo@olive-hc.com
Address : 12, Beobwon-ro 11-gil, Songpa-gu, Seoul, Republic of Korea

How to contact us
If you have any questions about our Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Olive Healthcare Inc.
Mr. Kim sangyun
Tel: +82 (2) 500 5719
Email: gdpr@olive-hc.com
Address: 12, Beobwon-ro 11-gil, Songpa-gu, Seoul, Republic of Korea

[Disclosures For Residents of the European Economic Area and the United Kingdom]

the Data Protection Officer:

Olive Healthcare Inc.
Mr. Kim sangyun

Tel: +82 (2) 500 5719
Email: dpo@olive-hc.com
Address : 12, Beobwon-ro 11-gil, Songpa-gu, Seoul, Republic of Korea

Our Representative:

Rickert Rechtsanwaltsgesellschaft mbH
Colmantstraße 15
53115 Bonn
Germany

Tel: +49 228 74 8980
Email: art-27-rep-olive-hc@rickert.law
Tel: +49 228 74 8980
Email: art-27-rep-olive-hc@rickert.law

[Disclosures For Residents of the European Economic Area and the United Kingdom]

How to contact the appropriate authorities

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact European Data Protection Supervisor via complaints wizard available at https://edps.europa.eu/data-protection/our-role-supervisor/complaints-wizard_en

[Disclosures For Residents of the European Economic Area and the United Kingdom]

How to contact the appropriate authorities

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact European Data Protection Supervisor via complaints wizard available at https://edps.europa.eu/data-protection/our-role-supervisor/complaints-wizard_en