1. Home
  2. /
  3. Privacy Policy
  1. Home
  2. /
  3. Privacy Policy
15 July 2020

Privacy Policy

Effective date: 21st December 2021

Welcome! Thank you for visiting our website epanafero.com or our dedicated pages on social media.  This website is owned and managed by Epanafero Ltd. (“Epanafero”, “Company”, “we”, “us”), a company registered in Jamaica that provides heart health and wellness membership, programs, coaching, retreats, and monitoring services as well as related cardiology consultations and heart health evaluations.  For clarity, we refer to our website and membership site as the “Website” and, collectively with our dedicated pages on social media as the “Site” in this document.

Please read this Privacy Notice carefully as it explains how we collect, use, retain and disclose your personal data so that you can make informed decisions when using our Site. 

By visiting and using our Site, you are deemed to have agreed to the provisions of this Privacy Notice. In all circumstances you acknowledge that you have been provided with this Privacy Notice.  If you do not wish to be bound by this Privacy Notice, then you should not access our Site.

This Privacy Notice is subject to and incorporated within our Terms and Conditions.

1.       Introduction

Through our Site, we aim to provide you with information about our company, our services, our team, and related developments including news and content about health and wellness.  Additionally, we aim to provide you with various channels to interact with us (contact forms, social media, questionnaires, surveys and quizzes, online diagnostic tools etc.) and for any questions and comments you may have.

Our purpose for collecting and using your Personal Information is to fulfil our commitment to providing you with the best possible experience when you interact with the Company.  We have created and adhere to this Privacy Notice to demonstrate our firm and continuing commitment to the privacy of information collected from all end users of our Site (“Users”), including those who purchase services from us (“Clients”, “Members”) as well as those who access our Site otherwise (“Visitors”). 

2.       Application of this Privacy Notice

This Privacy Notice applies to all our activities when you interact with us through our Site, in person, and when you communicate with us by telephone, email, text, direct message, live chat or any other means.  It also applies to the Personal Information about you that we receive from a third party, unless specifically covered by the third party’s own privacy policy.

Our Company’s Privacy Notice meets the requirements of the laws applicable to Epanafero Ltd. in its jurisdiction of incorporation concerning data protection, privacy, and the transfer of personal data.

Please note that this Privacy Notice does not apply to the practices of companies that we do not own or control, or to people whom we do not employ or manage.  Our Site may contain links to other websites belonging to third parties, which we provide solely for the information and convenience of our visitors. When you follow a link to another website, you automatically leave our Site and so are no longer covered by our Privacy Notice.  We urge you to read the privacy policy for any external websites before disclosing personal information.

3.       General Principles

The term “Personal Information” in this Privacy Notice refers to any information that can be used to identify you as an individual. It can include, among other things, your name, address, email address, phone number, identification number, location etc. 

As a visitor to the Site, you can engage in most activities without providing any Personal Information.  It is only when you register for services, seek to download resources, complete one of our online questionnaires, surveys and quizzes and/or request that we contact you that you are required to provide such information. 

We do not collect Personal Information about you unless you choose to provide such information to us. 

Here is a summary of how we collect and use your information:

  • Use of your information and the legal basis: We use your Personal Information to process your purchase of and registration for any of our Services; to provide you with individualized experience of our Services (including our heart health and wellness membership, programs, coaching, retreats, and monitoring as well as related cardiology consultations and heart health evaluations); to respond to your requests for information; to inform you about our services; and other purposes as set out in this Privacy Notice.  We may also use your Personal Information, anonymized and aggregated, for our health and wellness research activities.
  • Consent: We rely on your consent for some of our activities such as marketing our services to you, use of cookies, and the collection and use of your sensitive personal data.  You may withdraw this consent at any time.
  • Cookies: Our Site uses cookies and similar technologies to track visitors using the Site so that we may analyze trends and usage patterns for research and marketing purposes. You are not obliged to accept cookies.
  • Disclosure: We will not share or otherwise make available your Personal Information to third parties except as provided in this Privacy Notice.
  • Your rights: You have certain rights to your Personal Information under applicable laws.

It is our intention to give you as much control as possible over your Personal Information to preserve your privacy, while still allowing us to utilize your Personal Information to provide you with a valuable service.  At all times, you may choose whether to provide or disclose Personal Information.  If you choose not to provide the Personal Information requested, you may be unable to access certain services.

You understand and agree that we may collect, use, and share your Personal Information in accordance with this Privacy Notice. 

4.       Types of Information We May Collect

When you visit our Site, you may provide us with two types of information: Personal Information you knowingly choose to disclose that is collected on an individual basis; and Website Use Information that is collected on an aggregate basis as you and others browse our Site.

We do not collect Personal Information about you unless you choose to provide such information to us.  Non-personal information related to your visit to our Site, however, may be automatically collected.

The information we collect may vary by jurisdiction/region as well as by your preferred method of interaction with us.

4.1         Personal Information Voluntarily Submitted

Some of the information we may collect about you and store in connection with the provision and fulfilment of our services to you may include:

  • Contact and Identification Information such as your name, contact details (e.g. home or work address, mailing address, email address, phone numbers), business title, date of birth, birthday and special anniversaries, and country of residence.
  • Demographic Information such as your gender, age, marital status, employment, and profession;
  • If you participate in our heart health and wellness membership (“Member”), you have the option to upload a Profile Image that is viewable by other Members.  This is at your sole election, it is not mandatory for you to participate in the membership, and you may delete your profile picture at any time by logging into the membership and visiting your profile settings page;
  • Health-related Information including health and wellness concerns and priorities; lifestyle (e.g. dietary patterns,  physical activity, sleep, stress etc.); vital signs and physical characteristics (such as height, weight, Body Mass Index, waist circumference, heart rate, blood pressure, respiratory rate, and oxygen saturation); cardiovascular risk factors (such as hypertension, Diabetes Mellitus, high cholesterol, smoking, and family history); self-efficacy measures; and use of health technologies.

Please note that any personal medical information that you provide during an online Cardiology Consultation or Heart Health Evaluation or any in-person cardiology appointment with Dr. Edwin Tulloch-Reid will be protected under confidentiality laws that govern physician-patient communications.  This physician-patient relationship does not exist in the context of any of our other Services: Heart Health & Wellness Membership, Wellness Courses, Wellness Coaching, Wellness Retreats, or Wellness Monitoring; and as such, our collection, use, retention and disclosure of your personal medical information in the context of these Services are governed solely by this Privacy Notice. 

  • If you participate in our online and in-person events (such as webinars, calls or retreats), we may record and/or capture photographs, screenshots etc. of the event including of the event’s participants;
  • If you participate in one of our retreats, we may collect information related to your travel profile such as accommodation and travel preferences, booking history, dates of arrival and departure, dietary requirements, allergies, and special health accommodations;
  • Payment Processing Information: we use third party services to process payments for access to certain features and resources on our Site.  We do not see or have access to the information provided as part of those transactions, apart from your billing address, PayPal email address, and masked credit card information (for refunds).  The privacy policies of such third-party services apply to information you provide associated with those transactions. 
  • Marketing and Other Preferences including information, feedback or content you provide regarding your marketing preferences in response to our surveys, quizzes, questionnaires, contests or promotional offers, or to our Site and those of third parties;
  • Internet & Network Activity: we may collect the Internet Protocol (“IP”) address which is automatically assigned to your computer or device each time you interact with us online; and through your IP address, we may also collect your general location.  When you access the mobile version of the Site, we collect too your device’s unique identifier and your mobile network information. Additionally, we use cookies and related technologies to collect information related to how you interact with our Site.  Further details on how we use cookies and similar technologies are given in Section 6.1.
  • Social Media Accounts: in addition to information that we may collect from you directly, we may gather information associated with your social media account(s) if available to us. This may include your name, email address, profile information, and posted photographs.
  • Audio and Visual Information: if you contact us, we may record our customer service calls and these may include your voice and/or image.  We will additionally keep a record of any other associated communications and correspondence with you.
  • Feedback, Ratings and Testimonials including your Net Promoter Score (NPS), which we use as a proxy for gauging your overall satisfaction with us and your loyalty to our brand.  We may use testimonials and social media comments on our Site with your authorization, or anonymized.  If you wish to update or delete your testimonial, you can contact us at [email protected].  
  • Inferences: we may make inferences regarding what we believe to be your preferences and characteristics based on the composite of Personal Information we have.

Please note that some information listed above may be considered “Sensitive Personal Information” under the privacy laws of some countries or regions.  This includes, for example, your physical or mental health or condition, medical treatment, religious or similar beliefs, and information about your sexual life or sexual orientation.  We will only process Sensitive Personal Information if and to the extent permitted or required by applicable law.

You may always choose what (if any) Personal Information you wish to provide to us.  If you choose not to provide certain details, some of your experiences with us may be affected and/or we may not be able to perform the contract (e.g. to deliver goods or services to you).  If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

Your transmittal of your Personal Information shall constitute your acknowledgment and agreement to the terms contained in this Privacy Notice. 

If you submit Personal Information and later would like us to update, correct or remove it from our records, please contact us at [email protected]. Your email should include adequate details of your request.

This Privacy Notice also applies to the Personal Information about you that we receive from a third party, unless specifically covered by such third party’s privacy policy.

4.2         Site Usage Information Collected Automatically

When you browse our Site, we automatically collect and retain a variety of information about your visit through cookies and other technologies.  This may include:

  • Your IP address, which also may provide us with your location at the time of your visit
  • Your Internet browser characteristics
  • Domain you use to access the Internet
  • Your device characteristics and operating system
  • Your activity on the Site, including the date and time of your visit and purchases, duration of your visit, the pages and documents you access and the amount of time you spend on each, your search terms on the Site , your language preferences etc.
  • URLs of any websites that you visited before and after visiting our Site (including any advertisement that referred you to our Site)

We may receive website usage reports from our service providers or partners on an individual as well as aggregated basis.  We use the aggregated information from all visits for our Website analytics in order to improve our Site and provide a better user experience to our Users.  As such, we do not ordinarily associate this information with you as an individual.  However, to the extent that such web usage information is combined with identifying Information, we treat the combined information as Personal Information for the purposes of this Privacy Notice.

Our Site uses Google Analytics (including Demographics and Interests Reporting), Google Search Console, and Google Ads; and it may also provide the use of Google Maps, which you may enable to have access to your location to better specify the distance and/or routes to our locations.  For all Google services, we refer you to Google’s Privacy Policy to learn more about its collection and processing of such data: http://www.google.com/intl/en/policies/privacy/.

We use Local Storage Objects (LSOs) such as HTML5, Flash or Silverlight to store content information and preferences.  Third parties with whom we partner to provide certain features on our site, or to display advertising based upon your web browsing activity, may also use LSOs to collect and store information. 

Additionally, our system uses certain security plugins which protect our Site from attack and misuse.  Normal, non-damaging website accesses are usually not logged by the plugins. However, as soon as there is the suspicion that our system is subject to an attack, data relating to the visitor’s computer system are automatically logged and stored for forensic purposes; this includes the IP address, the data and time, the browser user and the reason for the suspicious activity.

Site usage data is deleted when it is no longer necessary to achieve the purpose for which it was collected.

5.       How We Use Your Personal Information

We may use the Personal Information you supply to us for the following purposes:

  • As required to conduct our business and pursue our legitimate interests, in particular:
    • To respond to your requests and enquiries, submitted via our Site or otherwise, and to deal with on-going matters relating to such requests and enquiries;
    • To provide you with better or more personalized customer support;
    • To fulfil contractual obligations to you, to anyone acting on your behalf and/or to vendors, or take steps linked to a contract, for example: to process a purchase of and registration for a Service, to verify your identity, to take payments, to provide your purchased Service(s) (including tailoring these to your health and wellness concerns and priorities), and communicating with you in relation our services to ensure that we meet your needs
    • To authorize your access to our Site, make its functionalities available to you, and customize its features for you based on personal characteristics or preferences where doing so we believe would improve your enjoyment and use of the Site.  This includes processing your account registration, including verifying your information is active and valid; and providing you with access to your account;
    • To present you with information relating to the Company, including content from our Site, in the way that we consider most effective;
    •  To conduct market research, statistical analyses, customer satisfaction and quality assurance surveys, including to enhance, develop and evaluate new services and Site features;
    • To communicate with you about your use of our Services and our relationship, such as updates to this Privacy Notice or other important legal or business changes;
    • To evaluate, analyze, and improve our Site, our services, and the Company;
  • Your health-related information, subject to your prior and explicit consent as may be required under applicable law, is used:
    • To tailor our programs to your health and wellness needs and concerns, to monitor your progress in achieving your wellness goals, and to fulfil your special requests;  
    • To enable you to take advantage of resources on our Site that may use health information you voluntarily provide that is not identifiable with your other Personal Information or otherwise individually identifiable health information; 
    • To conduct health and wellness research using health-related information, anonymized and aggregated, collected from our Site and through our Services (including our heart health & wellness membership);
  • Where you give us consent, to provide you with information and promotional details about services that may be of interest to you, as well as personalized mailings or other communications including in accordance with your health and wellness concerns and priorities.  This may include notifications, email or print marketing, telephone calls or text messages, and advertising on the Site.  You always have the choice to unsubscribe and not to receive marketing information, as described in Section 10;
  • To create a Member’s Profile page in our hearth health & wellness membership which may be, by default, set up to display information such as the Member’s display name, image, location (country), groups and discussion threads that the Member has joined, and optional information added by the Member.  Such Profile information is used by us primarily to be presented back to and edited by the Member when s/he accesses our heart health & wellness membership, and to be presented to others permitted to view such information within this membership. We may offer Members the ability to manage their profile preference settings, the functionality, and features of which are subject to change from time to time.  Notwithstanding the availability of profile preference settings, Members should be aware that these settings are for convenience only, may not employ complex data security protection, and may not be error free.  Further, other Members who have access may repost or otherwise make public such information or content. Accordingly, Members are strongly advised to exercise their discretion and good judgment when sharing information as part of their Members’ Profile;
  • To perform accounting, administrative and legal tasks, including to meet legal and regulatory requirements;
  • To investigate any complaints received from you or from others, about our Site or our services;
  • To prevent, investigate and/or report possible fraud, misrepresentation, violations of this Privacy Notice, security incidents, crime or other illegal activity, in accordance with applicable law;
  • To provide for the safety and security of our staff, partners as well as clients;
  • To verify your identity if you make requests regarding your Personal Information pursuant to this Privacy Notice.  The verification process may vary depending on the sensitivity and nature of your request;
  • To resolve disputes, troubleshoot problems, enforce our Terms and Conditions (when necessary to protect our intellectual property or proprietary rights, or those of a third party), to alert you to changes in our policies or agreements that may affect your use of the Site, or when we, in good faith, believe that the law requires us to do so.
  • In connection with other legal claims, compliance, regulatory and investigative purposes as necessary, for example to respond to requests by law enforcement authorities; and
  • If you choose to use our “Refer a Friend” feature to tell a friend about our Site, we will ask you for his/her name and email address. We will automatically send that person a single email inviting him or her to visit the Site.  We store this information for the sole purpose of sending this one-time email and tracking the success of our referral program.
  • If you wish to apply for an internship or employment with us, we and/or our recruitment partners, will use the information you submit in an application only for the purposes of evaluating and interacting with you for that specific job posting.
  • On other occasions, to fulfil other purposes which we explain at the time in accordance with applicable law or with your consent.

We use and retain your Personal Information for as long as is necessary to fulfil the purpose for which it is being processed, and in line with our legal and regulatory obligations.  This is further detailed further in Section 7.4.

6.       How We Collect Your Personal Information

We collect Personal Information from the following types of sources:

  • Directly from you: Much of the Personal Information we collect is what you directly and voluntarily provide to us while using our Site or in responding to a feature provided on the Site.  For example, you may provide us with information when you purchase our service(s) such as your initial registration); complete one of our Wellness questionnaires (which provide your health and wellness concerns and priorities, vital signs and physical characteristics, cardiovascular risk factors, self-efficacy measures, and use of health technologies) or Wellness Goal Setting/Completion forms (which indicates your health and wellness priorities and progress); register online and/or create a Member Account or Guest Profile; participate in a survey, quiz or customer research; fill out a form on the Website or by email that asks for your information; use any of our personal diagnostic tools; sign up to receive our newsletter and/or promotional e-mails; contact customer service; or contact us via email, text, or chat, over the phone, in person, or through third parties.  Whichever means you choose to correspond with us, we may collect and retain the content of your communications and our responses until the matter is concluded.

To access certain content and/or services, it will be necessary for you to register with the Website.  The registration form contains data fields that are necessary and obligatory for you to complete, marked with the * symbol.  If such fields are not completed, the registration will not be carried out and you will not be able to access the content and/or services.

We may record and/or capture photographs, screenshots etc. during our online and in-person events (such as webinars, calls or retreats) including of the event’s participants.  You consent to your name, words, voice, and likeness being used by us for promotional, business development, and marketing purposes, without compensation to you.  We will make reasonable effort to secure your written permission before using and distributing recordings, print materials, audio, or visual representations that refer to you.

If you apply for an internship or employment with us, we may collect Personal Information from your résumé and other employment-related submissions. 

  • From your devices and our networks: As detailed below, we use cookies and related technologies to automatically collect Personal Information from and across your devices when you interact with the Site, our emails, or other online content.

We may also collect your Personal Information when you click on one of the sponsored advertisements that we may now or hereafter provide for our Users to view while on our Site. 

  • From other businesses or individuals: We work with business and marketing partners and social media platforms that give us Personal Information about you that they have collected either directly or indirectly from you. We also use features that let someone else give us your Personal Information, for example when that person refers you or makes a booking on your behalf (for example, a family member or friend, or your employer in the case of corporate programs).
  • From social media: If you choose to follow, like, friend, comment or post to one of our dedicated pages on a social media site, certain Personal Information associated with your social media account (such as your profile and posts) may be made available to us based on your privacy settings in those websites.

Our Site uses cookies and other related technologies such as web beacons, pixels, tags and scripts.  These are small files which are placed by the Site onto the hardware of device (computer, smartphone, tablet) which you use to browse the internet and contain information about your visit to the Site.  The purpose of these technologies is to enable certain Site features to work (e.g. for the operation of videos, or to remember content of your shopping cart) and for our Site to remember you, and your browsing habits in order to deliver a better and more personalized visit (e.g. customize the Website according to your individual interests, speed up your searches, and recognize you when you return to our Website).  We also use cookies and related technologies to track the Site’s performance (including to test its design and content), for aggregate Site analytics (e.g. number of visitors and pages viewed), to track visitors’ movements around the Site over time and across third party websites, and to gather demographic information about our visitor base in its entirety. 

Our cookies do not contain any personally identifying information, although your computer is automatically assigned an ID number whenever you visit our Site.  This anonymous information is not matched to your Personal Information.

You may be able to configure your Internet browser to accept or reject all or some cookies or notify you when a cookie is set.  If you choose to have your browser refuse cookies, it is possible that some areas of our Site will not function as effectively for you.  You may delete previously stored cookies as well.  Please consult your browser to manage your cookie preferences.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish to have your online activities tracked over time and across different websites. Our Site does not support Do Not Track requests at this time, which means that we may collect information about your online activity while you are using and after you use the Site.

We may also place web beacons (also known as “transparent GIFs” or “tracker GIFs”) on our Site, in online advertising with third parties, and in our emails.  We use these beacons, in connection with cookies, to collect non-personal data on the usage of our Site, the performance of our online advertising, and the interaction with content in our emails.

6.1.1        Third Party Service Providers such as Google Analytics, Google Search Console, Google Ads and Other Advertisers

We use Google Analytics and Google Search Console, web analytics services of Google, to evaluate and provide us with information about the use of the Site including traffic sources, content viewing, demographics, and interests.  Google Analytics and Google Search Console use their own cookies and other tracking technologies as well as your IP address for this purpose.  You may opt out of Google Analytics by visiting the Google Analytics Opt-out page: http://tools.google.com/dlpage/gaoptout.

We may engage third party service providers (including Google Ads) either to display advertising on our Site or to manage our advertising on other sites.  These may use cookies, web beacons or similar technologies to gather information about your browsing habits to deliver advertising to you that is relevant to you and your interests, to help measure and research the advertisements’ effectiveness, or for other purposes.

The collection and use of your information by any of our third-party service providers are governed by their respective privacy policies and are not covered by this Privacy Notice.

6.1.2        Social Media

Our Site may contain plug-ins and other features that integrate third party social media platforms into the Site, for example the Facebook, Instagram, LinkedIn and Twitter buttons.  You will be able to activate them manually.  If you do so, these third-party platforms may use cookies and other technologies to identify you, determine how you use the Site , and they may link and store this information with your social media profile.  Your interactions with these social media platforms are governed by their respective privacy policies and are not covered by this Privacy Notice.

We may use Facebook Conversion Tracking and Custom Audiences using information from the Site.  Third parties such as Facebook may use cookies, web beacons or similar technologies to collect or receive information from the Site and elsewhere on the internet and use this to provide measurement services and target ads.

7.       Management of Your Personal Information

7.1         Our Company’s Commitment to Data Security

We understand the utmost importance of protecting the Personal Information that you share with us. The Company implements and maintains reasonable safeguards, including technical, contractual, administrative, and physical security measures, to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

For site security purposes and to ensure that this service remains available to all Users, we reserve the right to monitor all network traffic to the Site to identify and/or block unauthorized attempts or intrusions to upload or change information or cause damage to the Site in any fashion.  Anyone using this Website expressly consents to such monitoring.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure.  While we strive to protect your Personal Information, WE CANNOT AND DO NOT REPRESENT, WARRANT OR GUARANTEE THE SECURITY OF ANY INFORMATION YOU TRANSMIT TO OR FROM OUR SITE, AND YOU TRANSMIT ANY INFORMATION AT YOUR OWN RISK.  Where required under law, we will notify you of any such loss, misuse or alteration of Personal Information that may affect you so that you can take the appropriate actions for the due protection of your rights.  In the event of a data breach, or if we suspect a data breach, we will in addition notify the competent authorities in accordance with applicable law.

Whilst we strive to protect your Personal Information, we also urge you to take every precaution to protect your Personal Information while you are on the Internet. You are responsible for restricting access to your computer and ensuring that your computer is free from all types of malicious code, spyware, viruses, Trojans, etc. that may track any data you enter via this Website. To be prudent, please be sure to always close your browsers when you have finished making a transaction or completing a form on our Site; and please bear in mind that email communication is not secure.  As such, we recommend that you do not include any confidential information when using email; and we will not include any confidential information in our email responses to you.

Also consider that whenever you voluntarily make your Personal Information available for viewing by third parties online – including through any of the interactive features we may provide in conjunction with our Services, such as Community (including groups, discussion threads etc.), Forum, Chat, Online Events (such as webinars) and social media platforms – your information can be seen, collected and used by others besides us.  We cannot be responsible for any unauthorized third-party use of such information.

7.2         Who Has Access to Your Information Within Our Company

Within the Company, access to your information is limited to those designated persons who require access for the purposes outlined in Section 5.

As part of our commitment to your privacy, we have appointed an internal data protection officer (“DPO”).  Our DPO reviews our Privacy Notice periodically to make sure it remains compliant with key international legislation and monitors our Company’s activities for adherence to this Privacy Notice.   You may contact our DPO by email or letter using the addresses given in Section 14.

Please note that any personal medical information that you provide during an online Cardiology Consultation or Heart Health Evaluation or any in-person cardiology appointment with Dr. Edwin Tulloch-Reid will be protected under confidentiality laws that govern physician-patient communications.  This physician-patient relationship does not exist in the context of any of our other Services: Heart Health & Wellness Membership, Wellness Courses, Wellness Coaching, Wellness Retreats, or Wellness Monitoring; and as such, our collection, use, retention and disclosure of your personal medical information in the context of these Servicesare governed solely by this Privacy Notice.

7.3         How You Can Access and Correct Your Personal Information

We take reasonable steps to ensure that your Personal Information is kept accurate and up-to date for the purposes for which it was collected. 

If at any time you wish to update or access your Personal Information, you can do so by contacting our DPO via email ([email protected]) or by letter (Attn: DPO, Epanafero Ltd., Regal Plaza, 15 Old Hope Road, Kingston 5, Jamaica).

To protect your Personal Information, however, we require that you prove your identity to us at the time your request is made.  Depending on the nature of your request, you may need to submit it in writing and include a copy of a government issued identification and signature.  We may also require home and/or business address and phone numbers so we can check them with our files and satisfy ourselves as to your identity.  The above information is required to create an audit trail of how your request has been handled.  Where a request is made, any correspondence or application may be kept and added to your Personal Information.  We reserve the right to decline access to your Personal Information under certain circumstances. If your Personal Information will not be disclosed, you will be provided with the reasons for this non-disclosure.

7.4         Retention and Deletion of Your Personal Information

The Company retains your Personal Information only for as long as necessary to fulfil the purpose for which it was collected and/or we believe that we have reason to access it or refer to it, as well as to comply with our legal and regulatory obligations.  Personal Information may be maintained for longer periods if subject to a legal hold or specific country/region requirements.

From time to time, we may delete your Personal Information when we determine that you are no longer active within our system.  Should you withdraw your consent to have us collect and/or use your Personal Information, we will keep a record of this so that we can respect your request in future.

We may anonymize your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

When we have no ongoing legitimate business need to process your information, we will either delete or anonymize it.  Data whose retention period has been reached is automatically deleted.

You may request the deletion of your Personal Information at any time, subject to any retention obligations imposed on us.  Within 30 days of receiving your written request for deletion of your Personal Information together with proof of your identity, we will delete or destroy all copies of your Personal Information in our systems or otherwise in our possession or control.  We may retain de-personalized (anonymous) information after the deletion of your Personal Information.

8.       Disclosure of Your Personal Information

We do not sell or rent any information that we collect to third parties, nor do we share your information with third parties for commercial purposes in violation of the commitments set forth in this Privacy Notice.

We will share your Personal Information outside the Company, without prior notice to you, only in the following circumstances:

  • when it is required to provide you with the service(s) you have requested, in which case you will be considered to have implied your consent;
  • if your program is booked and/or paid for by a third party, in which case we will provide the booking and billing information to that party;
  • to enforce our Terms and Conditions or any other agreement between you and the Company, including to assist with collecting amounts owed to us; 
  • if needed to protect the rights, property and safety of us or a third party;
  • if we believe there is a serious and imminent threat to the life, health or safety of yourself or another person;
  • if needed to respond to the request of law enforcement in cases where we believe disclosure is required and/or in accordance with applicable law, regulation or legal process; or
  • if we suspect any unlawful activity is taking place, we may investigate and/or report our findings or suspicions to the police or other relevant law enforcement agency.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you (for example, we may feature aggregated results and/or testimonials on our Site or newsletter).

8.1         Our Partners, Service Providers, and Suppliers

We may outsource the processing of certain functions and/or information to third parties which support our business and manage or provide our services.

We use service providers in connection with operating and improving our Site as well as to assist with certain business functions, such as customer relationship management and support, fulfilling sales, payment processing, email and newsletter transmission, managing our ads, administering surveys, analytics, Site maintenance and data hosting, and technical support.  Using contractual or other arrangements, we will take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, and in a manner consistent with the principles of this Privacy Notice.

After registering for our Heart Health & Wellness Membership or booking a Wellness Course, Wellness Coaching, Wellness Retreat or Wellness Monitoring or Heart Health Evaluation or other prescribed service with us, you will be asked to complete Wellness Questionnaires at intake and periodically thereafter which inform us about your health and wellness concerns and priorities, vital signs and physical characteristics, cardiovascular risk factors, self-efficacy measures, and use of health technologies.  You may also be asked to complete Wellness Goal Setting & Accomplishment forms which inform us of your health and wellness priorities and progress.  Following your participation in any of our Services, we may also contact you to ask about your satisfaction with our programs as well as to follow up on your health and wellness status, concerns and priorities. 

We may share some of your Personal Information contained therein with our partners (e.g. our venues) and health and wellness service providers (e.g. our Medical Experts or Wellness Coaches) if they are involved in providing services to you within the context of your program.  In such cases, we would provide them only the minimum information necessary to provide their specific service, and we would ensure that they are contractually obligated to keep strictly confidential any such information that we share with them.  If you do not wish for us to share your Personal information with our partners and service providers in this way, please advise us after you have received your order confirmation by sending an email to: [email protected].  

Please note that any personal medical information that you provide during an online Cardiology Consultation or Heart Health Evaluation or any in-person cardiology appointment with Dr. Edwin Tulloch-Reid will be protected under confidentiality laws that govern physician-patient communications.

We reserve the right to disclose information about you to third parties if we believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or audits.  We may also disclose information about you if we believe that your actions are inconsistent with our Terms and Conditions or related guidelines and policies, or if necessary to protect the rights, property, legitimate interests, or safety of, or prevent fraud or abuse of, the Company or others in compliance with applicable laws.

8.3         Change in Business Control or Sale

As we continue to develop our business we may buy or sell various assets.  In the unlikely event that we sell some or all of our assets, or that the Company or substantially all of our assets are acquired, your Personal Information, or control of such information, may be one of the transferred assets.  As such, we may share your Personal Information with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.

You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

8.4         Our Participant Lists

For our group courses and retreats, the Company may prepare a list with each participant’s name, location(city and/or country), and profession.  This may be included in each participant’s welcome kit which will be shared at the start of the course or upon arrival at the retreat.  If you do not wish for your name to appear on such as list, please let us know and we will be happy to remove your name.

9.       International Transfers of Personal Information

In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. 

Please note that your information will be stored and processed on servers in Jamaica and in jurisdiction(s) other than Jamaica.  Additionally, some of the third parties to which we transfer your Personal Information (as described in Section 8.1) may be based in these and/or other locations. The jurisdictions where your information will be stored or processed may have lower standards of data protection and privacy than in your home country.

By using our services and agreeing to this Privacy Notice, you are, to the extent required and permitted under your local law, granting your consent to such a transfer of your Personal Information.  If you do not consent to this transfer, then please do not register on our Website as we will be unable to provide you with our services.

10.   Choice and Opting Out

You can always choose whether to receive any or all communications from us, other than communications regarding your bookings and billing and administrative emails such as updates to our Privacy Notice or Terms and Conditions if we choose to provide such notices to you in this manner.

All emails from us will have a clear “From” field that identifies us as the sender and will contain our address for contact purposes.

You may review, change, or delete your email preferences or the name you provided us for email services.  To do so, please click the “unsubscribe” or “change your preferences” or “manage your preferences” link in the footer of one of our informational or marketing emails.  You may also opt out by sending an email to [email protected] and stating that you would like to opt out of email communications from the Company.  We will remove you from our mailing list as soon as technically feasible.  In such cases, your contact details will be “suppressed” rather than deleted in order to ensure that your request is recorded and retained unless you provide a later consent that overrides it.

11.   Your Rights as Regards to the Processing of Your Data

In accordance with applicable laws, you may have rights in relation to your Personal Information. These include:

  • You have the right to know whether and which of your Personal Information is processed by us and for what purposes.
  • You have the right to request a copy of your Personal Information, and to request that it be rectified (corrected or completed) or deleted.
  • You have the right to data portability, whereby your Personal Information be moved to you or another controller whom you designate in a structured, machine-readable format.
  • You can object to the processing of your Personal Information, request that its processing be restricted, or opt out of receiving informational or marketing communications.
  • You have the right to withdraw any express consent that you have provided to the processing of your Personal Information at any time without penalty.  This does not affect the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.
  • You have the right to present a compliant to your local data protection authority should you have unresolved concerns about our collection and use of your information.

These rights may be limited, for example if fulfilling your request would reveal Personal Information about another person, where they would infringe the rights of a third party (including our rights), or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.  We will inform you of relevant exemptions in applicable data protection laws that we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, please send us a written request by letter or email to the addresses given in Section 14.  We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws.  We will take reasonable steps to verify your identity prior to responding to your requests.  The verification steps will vary depending on the sensitivity of the Personal Information and whether you have an account with us. 

12.   Children’s Privacy

The Company and its services are not directed at persons under the age of 18, and we do not knowingly solicit or collect or maintain information of any kind from such persons without prior verifiable parental or guardian consent. 

Protecting the privacy and safety of minors online is very important to us. If we become aware that we have inadvertently received personally identifiable information from a minor, we will delete such information from our records.  In addition, if a parent or guardian becomes aware that a child has submitted personal information, that parent or guardian should contact us via email at [email protected] and we will delete the child’s information from our records.

13.   Changes to Our Privacy Notice

The Company reserves the right to change this Privacy Notice, without notice, at its own discretion.  When we do, we will post the changes to this Privacy Notice on the Site and update the Effective Date at the top of this page.  The changes will apply to the use of the Site after such notice.  We will notify you any material changes by an announcement on the Site’s home page or using the email address you have provided upon registration.  It is incumbent upon you to review the Privacy Notice thereafter to become aware of the changes, revisions, or modifications.  

Where permitted by law, if you use the Site after the date on which the changes come into effect, you will be deemed to have accepted the Privacy Notice as modified.  Please be assured that we will always handle your Personal Information in accordance with the Privacy Notice that was in effect at the time of collection except as may be required by law.

14.   Questions, Complaints, and Request for Access to Personal Information

If you have any questions about this Privacy Notice, or any concerns or complaints with regard to its implementation, or if you would like to submit a request to exercise your rights in relation to the Personal Information that we maintain about you, please contact our Data Protection Officer:

By email: [email protected]

By letter:  Attn: DPO, Epanafero Ltd., Regal Plaza, 15 Old Hope Road, Kingston 5, Jamaica

When we receive formal written complaints, it is our policy to contact the person regarding his or her concerns.  We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints that cannot be resolved between the Company and the individual concerned.