Asset Health Global Challenge
(AH Global) Privacy Policy
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Apple Health /
HealthKit Integration
Before we begin, it is important that you know Asset
Health Global Challenge (AH Global) integrates with AppleHealth.
We request access to read your steps walked, calories burned, flights climbed (where
available on certain iPhone models), in order for you to participate in the
challenge. We do not write new data to your AppleHealth storage, we do not
share any of your AppleHealth data with any third parties and we take your
privacy very serious. We simply use your step and flight data to feature you on
the challenge leaderboard.
Health Connect
Integration
Asset Health Global Challenge (AH Global)
integrates with Health Connect. We request access to read
your steps walked data, in order for you to participate in the challenge. We do not share any of your
Google Fit data with any third parties and we take your privacy very seriously.
We simply use your steps walked data to feature you on the challenge
leaderboard. You may want to also familiarise yourself with the finer details of the Health Connect privacy clauses in AH Global:
a. Collection and Usage of Health Data:
We value the privacy and security of our users. Our mobile application requests access to health-related permissions, specifically the ability to read steps information. This data is collected for the sole purpose of enhancing the user experience and providing features related to health and fitness.
b. Purpose of Health Data Access:
Our app utilizes health-related permissions to track daily steps. This data is processed locally on the user's device and is not shared with any third parties.
c. User Consent:
By using our app, you explicitly consent to the collection and usage of health-related data for the purposes outlined in this privacy policy. You have the option to grant or deny these permissions within the app settings at any point. You can go to Health Connect, find AH Global and revoke permissions at any point.
d. Security Measures:
We implement robust security measures to protect the confidentiality and integrity of health-related data. This includes encryption and secure storage.
e. Data Retention:
We retain health-related data only for as long as necessary to fulfill the purposes outlined in this privacy policy. Users can request the deletion of their data by
opening the AH Global app, going into the menu and selecting "Delete my account". You can also revoke access to AH Global at any point - you are in control of your data.
f. Third-Party Services:
Our app does not share health-related data with any third-party services, advertisers, or external entities. We do not engage in the sale or exchange of user data.
GoogleFit
Integration
Asset Health Global Challenge (AH Global)
integrates with GoogleFit. We request access to read
your steps walked data, in order for you to participate in the challenge. We do
not write new data to your GoogleFit storage, we do not share any of your
Google Fit data with any third parties and we take your privacy very seriously.
We simply use your step and flight data to feature you on the challenge
leaderboard.
Fitbit
Integration
Asset Health Global Challenge (AH Global)
integrates with Fitbit. We request access to read your steps walked data, in
order for you to participate in the challenge. We do not write new data to your
Fitbit storage, we do not share any of your Fitbit data with any third parties
and we take your privacy very seriously. We simply use your step and flight
data to feature you on the challenge leaderboard.
Asset Health Global Challenge (AH Global)
integrates with Garmin. We request access to read your steps walked data, in
order for you to participate in the challenge. We do not write new data to your
Garmin storage, we do not share any of your Garmin data with any third parties
and we take your privacy very seriously. We simply use your step and flight
data to feature you on the challenge leaderboard.
Huawei Health
Integration
Asset Health Global Challenge (AH Global) will soon
integrate with Huawei Health in the Huawei version of AH Global – only available
from the Huawei App Gallery in territories in the world where Huawei Application
Services are permitted (outside of the US and certain other territories). We will then
request access to read your steps walked data, in order for you to participate
in the challenge. We do not write new data to your Huawei Health storage, we do
not share any of your Huawei Health data with any third parties and we take
your privacy very seriously. We simply use your step and flight data to feature
you on the challenge leaderboard.
Asset Health
Global Challenge (AH Global) is committed to meeting the provisions of this
privacy policy in all aspects of its business operations.
We respect your privacy. Asset Health Global
Challenge (AH Global) (referred to as Asset Health Global Challenge (AH
Global) or We in this Privacy Policy) have developed this Privacy
Policy to inform you of how we protect the Personal Information that we
Collect, Use, Disclose and keep secure in our capacity as a data controller. It
also covers how Asset Health Global Challenge (AH Global) makes the Personal
Information it holds available for access to and correction by you. This
Privacy Policy has been drafted having regard to Asset Health Global Challenge
(AH Global)'s obligations under the Privacy Act 1988, the Privacy Amendment
(Enhancing Privacy Protection) Act 2012 which includes the South African
Privacy Principles (collectively, the Privacy Act and POPIA), and also under
the relevant state legislation governing health records such as the Health
Records Act 2001 (Vic, Australia), which includes the Health Privacy Principals,
and the GDPR European framework for data protection laws. There are a number of defined terms in
this Privacy Policy, which are explained more fully in the Glossary (section
11).
This Privacy Policy is a public document and has
been prepared in light of South African Privacy Principles - Open and
Transparent Management of Personal Information. By using a
Asset Health Global Challenge (AH Global) Online Platform, or by receiving
notification from Asset Health Global Challenge (AH Global) of how you may
access this Privacy Policy, whether by phone, email or otherwise, you are
consenting to the Collection, Use and Disclosure of your Personal Information
as set forth in this Privacy Policy. This Privacy Policy applies to the
services and products provided by Asset Health Global Challenge (AH Global) and
binds all our employees and health professionals. Asset Health Global Challenge
(AH Global) employees are required to sign an agreement that includes a
confidentiality clause on commencement of employment. Third Parties such as
subcontractors that collect information on behalf of Asset Health Global
Challenge (AH Global) are bound by this Privacy Policy. Asset Health Global
Challenge (AH Global) does not provide your Personal Information to your
employer unless it has been properly de-identified. This de-identified
(anonymous) data will allow for the analysis and identification of overall
company health risks and for planning structured wellness initiatives across
your organisation. For the Asset Health
Step Challenge you are enrolling in, no health information will be collected or
shared with your employer. This Privacy
Policy is available on any Asset Health Global Challenge (AH Global) Online
Platform and can also be accessed via links included in newsletter email
communications as well as in the Asset Health Global Challenge (AH Global)
mobile app during registration. Please read this Privacy Policy carefully.
1. COLLECTION OF YOUR INFORMATION
1.1 Asset Health Global Challenge (AH Global)
Collects Personal Information, including Sensitive Information and Health
Information about individuals who use its services where this collection is
reasonably necessary for, or directly related to, one or more of its functions
or activities. The Personal Information may be collected through our Health
Assessment (HA), a Asset Health Global Challenge (AH
Global) Online Platform or otherwise. In
the event of a standard Asset Health Global Challenge (AH Global) Step
Challenge, nor Health Information is collected, and only a limited amount of
Personal Information may be collected as deemed necessary by your
employer. The number of Personal
Information fields collected during registration may vary from challenge to
challenge based on the pre-requisites of your employer.
1.2 The kinds of Personal Information we collect from
you depends on who you are and your interaction with us. As a provider of
health solutions products and services, Asset Health Global Challenge (AH
Global) may collect the following types of Personal and/or Sensitive
information about you for the Asset Health Step Challenge:
1.3 When Asset Health Global Challenge (AH Global)
collects Health Information from you, we will first obtain your consent, unless
the collection occurs in the context of a Permitted Health Situation. We may
obtain your consent by alerting you to the existence of this Privacy Policy and
providing you with a means to access it, and informing you that the collection
of your Health Information is to be done in accordance with this Privacy Policy. For a standard Asset Health Global Challenge
(AH Global) Step Challenge, no Health Information is collected. For other products and apps offered by Asset
Health Global Challenge (AH Global), Health Information may be collected and
you will be alerted and made aware of this in-app with the option to opt out or
in.
1.4 At or before the time, or, if that is not
practicable, as soon as practicable after, we Collect your Personal
Information, we will notify you of the matters required as per the Collection
of Personal Information, by providing you with this Privacy Policy, or by
notifying you of how you may access this Privacy Policy. Notification may be
effected, in part or in whole, by alerting you to the existence of this Privacy
Policy and providing you with a means to access it.
1.5 Asset Health Global Challenge (AH Global) will
not Collect Personal Information secretly or in an underhanded way and will not
sell or share your Personal Information to any third party.
2. HOW WE USE YOUR INFORMATION AND WHEN
WE MAY DISCLOSE IT
2.1 Asset Health Global Challenge (AH Global)
collects and holds Personal Information which it has Collected to Use and/or Disclose
for its Primary Purposes of providing you with health services/healthy living,
including but not limited to:
1. providing you with products and
services via a Asset Health Global Challenge (AH
Global) Online Platform; these are usually connected with assisting you in
assessing your health risks and goals – health risks and goals are disabled by
default and your challenge may not have this module available unless
specifically requested by your employer; 2. sending you push notifications and
other personalised push communications regarding your progress in the
challenge, target achievement and related matters; 3. answering your inquiry or
responding to complaints, access and correction requests 4. sending you
additional info relating to Asset Health Global Challenge (AH Global) and
services that may be of interest to you or improve your performance in the
challenge; 5. providing you with effective customer service in regard to wellness
services provided to you; and/or 6. for the Asset Health Step Challenge, no
health related information will be collected or shared with your employer.
2.2 Asset Health Global Challenge (AH Global) also
holds Personal Information which it Uses and/or Discloses for purposes other
than its Primary Purposes (Secondary Purposes). By providing Personal
Information to Asset Health Global Challenge (AH Global), you are consenting to
us using your Personal Information for the following Secondary Purposes:
1. business planning and product
development; 2. providing you with relevant information about the products and
services of Asset Health Global Challenge (AH Global) – for example, when a
photo challenge feed opens up, new activities are added to the activities list,
new podcasts are released etc; 3. enabling us to better understand your needs
and interests; 4. improving the content, functionality and usability of our
programs and services; 5. billing and account management; 6. for any other
purpose identified in any other agreement between Asset Health Global Challenge
(AH Global) and you; 7. issues, news or other information relevant to your
dealings with Asset Health Global Challenge (AH Global), or about Asset Health
Global Challenge (AH Global) generally, or the industries in which you or Asset
Health Global Challenge (AH Global) operates; and 8. as otherwise described in
this Privacy Policy.
2.3 Asset Health Global Challenge (AH Global) may
also Use and/or Disclose your Personal Information for any Secondary Purposes
not included in this Privacy Policy if:
1. the Secondary Purpose is directly
related to a Primary Purpose; and 2. you would have a Reasonable Expectation
that we would Use the information for that Secondary Purpose.
2.4 Asset Health Global Challenge (AH Global) will
never disclose your Personal Information to third party organisations outside
of Asset Health Global Challenge (AH Global) in order to deliver the services
you require.
3. ENSURING INFORMATION IS ACCURATE AND
UP-TO-DATE
We take reasonable precautions to ensure that the
Personal Information we collect is complete, relevant and up-to-date. However,
the accuracy of that information depends to a large extent on the information
you provide. That's why we recommend that you:
4. HOW WE PROTECT YOUR INFORMATION /
DATA RETENTION
4.1 Asset Health Global Challenge (AH Global)
manages and secures the Personal Information it collects by using reasonable
physical, technical and administrative safeguards and procedures. These safeguards
and procedures include but are not limited to:
1. use of appropriate encryption,
password, and other protections for information held electronically; 2. only
providing necessary personnel access to personal information; 3. regularly
providing staff training on privacy issues; 4. implementing various procedures
to assist employees in alerting customers to potential privacy issues before
personal information is collected; 5. regularly reviewing its privacy
compliance; and 6. appointing privacy officers within Asset Health Global
Challenge (AH Global) organisations to monitor privacy compliance.
4.2 Asset Health Global Challenge (AH Global) will
take reasonable steps to protect your Personal Information from misuse,
interference, loss and unauthorised access or disclosure. This may include
taking reasonable steps to destroy or permanently de-identify Personal
Information once it is no longer needed for any purpose for which it may be
Used or Disclosed in accordance with privacy principle laws, subject to the
exceptions contained therein.
4.3 Asset Health Global Challenge (AH Global) will
not attempt to match de-identified or anonymous data Collected through surveys
or such online devices as "cookies", with information identifying an
individual, without the consent of the relevant individual.
4.4 Asset Health Global Challenge (AH Global)
requires employees and contractors to perform their duties in a manner that is
consistent with Asset Health Global Challenge (AH Global)' legal
responsibilities in relation to privacy, including those in this Privacy
Policy.
4.5 Asset Health Global Challenge (AH Global) will
take reasonable steps to ensure that Personal Information is only accessible by
people who have a genuine "need to know" as well as "right to
know."
4.6 This Privacy Policy only governs the collection
and use of any data obtained through the Asset Health Global Challenge (AH
Global) mobile app.
4.7 Your personal data will be retained for the
period of the challenge you have enrolled in plus 45 days.
4.8 The reason we keep your personal data a bit longer beyond
the actual challenge end date is to respond to any queries that may arise
at the end of the challenge.
4.9 All your personal data will be disassociated and
removed from the Asset Health Global Challenge (AH Global) platform on the date
stipulated in point 4.7 above. You may also execute your Art. 17 Right to
Erasure ("Right to be forgotten") and send a formal request to Asset
Health Global Challenge (AH Global) to delete all your personal information by
making use of our EU representative contact details. You will be required
to provide your username or email address (whichever you used during
registration) when making the request, so that your account can be identified
and removed. Asset Health Global Challenge (AH Global) may request
additional information from you to verify your account and make sure you are
the owner of the account, before removal.
5. HOW YOU CAN ACCESS OR CORRECT YOUR
INFORMATION
5.1 Asset Health Global Challenge (AH Global) will
permit its records containing your Personal Information to be accessed by you
when required by the Privacy Act. We may, however, refuse to provide you with
access to your Personal Information if one or more of those matters contained
in the Access to Personal Information laws applies, including but not limited
to instances in which:
·
giving access to the information would
have an unreasonable impact on the privacy of any other individual;
·
your request for access is frivolous or
vexatious or giving such access will be unlawful.
5.2 If Asset Health Global Challenge (AH Global) is
satisfied that:
1. having regard to the purpose for
which the information is held, the information is inaccurate, out of date,
incomplete or irrelevant or misleading; or 2. you (as the person to whom the
Personal Information relates) request that we correct the information; we will
take reasonable steps to correct our records containing your Personal
Information as soon as practically possible in accordance with the Privacy Act.
5.3 If we have refused to grant you access to your
Personal Information in accordance with Point 5.1 above, we will still take all
reasonable steps to provide you with access to your Personal Information in a
way that meets both your needs and our needs.
5.4 If you:
1. wish to lodge a request to access
and/or correct your Personal Information; or 2. have been refused access to
your Personal Information by us for any reason described in this Privacy Policy
and you wish to challenge that refusal; you may do so by contacting the office
of Asset Health Global Challenge (AH Global) Privacy Officer as per the details
in Point 12.
5.5 Asset Health Global Challenge (AH Global) will
not charge a fee for processing an access request unless the request is complex
or is resource intensive. Asset Health Global Challenge (AH Global) does,
however, reserve the right to charge an administration fee if an individual
requests access to their Personal Information more than once in a three month
period.
5.6 Where Asset Health Global Challenge (AH Global)
offers online account management facilities, customers can use this capability
to control aspects of their account, including amending or updating certain
Personal Information in the Asset Health Global Challenge (AH Global) mobile
app.
6. OPENNESS
6.1 The office of the Asset Health Global Challenge
(AH Global) Privacy Officer will be the first point of contact for inquiries
about privacy issues. If you wish to make an inquiry or complaint regarding
privacy you should do so by contacting this office as per the details in Point
12.
6.2 You will find that all Asset Health Global
Challenge (AH Global) Online Platforms contains a copy of this Privacy Policy
7. STAYING ANONYMOUS
7.1 Asset Health Global Challenge (AH Global) will
not make it mandatory for visitors to its Asset Health Global Challenge (AH
Global) Mobile App to provide Personal Information unless such Personal
Information is required to answer an inquiry or provide a service. Asset Health
Global Challenge (AH Global) may however request visitors to provide Personal
Information voluntarily to Asset Health Global Challenge (AH Global) (for
example, as part of a competition or questionnaire) – only where this has been
explicitly approved by the employer or challenge host.
7.2 Asset Health Global Challenge (AH Global) will
allow its customers to transact with it anonymously or by using a pseudonym
wherever that is lawful, reasonable and practicable.
8. TRANSFERRING INFORMATION OVERSEAS
8.1 If we send Personal Information overseas, Asset
Health Global Challenge (AH Global) will take steps which are both reasonable
and practicable to ensure that such transfer is in accordance with applicable
law and that the overseas recipient handles such information in accordance with
the Privacy Act.
8.2 Asset Health Global Challenge (AH Global) may
disclose Personal Information to an overseas recipient without complying with
9.1 if:
8.3. you are Expressly Informed of the
intended disclosure of your Personal Information to the overseas recipient, and
you provide consent accordingly; or 2. we reasonably believe that the overseas
recipient is subject to a law or a binding scheme that has the effect of
protecting the information in a way that, overall, is at least substantially
similar to the way in which the Privacy Act seeks to protect same and you can
access mechanisms to enforce the protection of your Personal Information under
that law or that scheme; or 3. the Disclosure is required or authorised by an
South African court or tribunal or under South African law.
8.4 For challenges configured in the Asset Health
Global Challenge (AH Global) EU Domicile, any information collected from you
will be stored in the Asset Health Global Challenge (AH Global) Netherlands
Data centre.
8.5 For challenges configured in the Asset Health
Global Challenge (AH Global) USA Domicile, any information collected from you
will be stored in the Asset Health Global Challenge (AH Global) US East Coast
Data centre.
8.6 For all other challenges configured in
domiciles other than point 8.4 and 8.5, you need to speak to your Asset Health
Global Challenge (AH Global) representative to configure your domicile as per
your local governing law.
9. CHANGES TO THE PRIVACY POLICY
Asset Health Global Challenge (AH
Global) may, in its sole discretion, update this Privacy Policy at any time and
from time to time. Any changes will be effective when posted on the Website and
updated in the Asset Health Global Challenge (AH Global) Mobile App. Your
continued use of the Website or Asset Health Global Challenge (AH Global)
Mobile App will indicate your acceptance of any changes to the Privacy Policy.
All Personal Information, Collected both before and after any changes take
effect, will be subject to the terms of the then current policy, for which you
will be taken to have provided consent, unless you indicate otherwise by
contacting the office of Asset Health Global Challenge (AH Global) Privacy
Officer as per the details in in Point 12. We encourage you to refer back to
this page and especially prior to providing us with any Personal Information.
10. COMPLIANCE WITH THE HEALTH PRIVACY
PRINCIPALS
Where applicable, the collection and use of any
Health Information obtained by Asset Health Global Challenge (AH Global) will
be in compliance with the Health Privacy Principals found in the Health Records
Act or in any other relevant state legislation governing health records.
11. GLOSSARY
Collect means gather, acquire or obtain by a lawful
and fair means, information in circumstances where the individual is
identifiable or identified.
Disclosure generally means the release of
information outside Asset Health Global Challenge (AH Global), including under
a contract to carry out an "outsourced function."
Express Consent Consequences includes the fact that
that we will not be accountable under the Privacy Act and you will not be able
to seek redress under the Privacy Act in the event that you provide consent to
the disclosure of your Personal Information by us to an overseas recipient and
the overseas recipient handles your Personal information in breach of the
Privacy Act.
Expressly Informed means the circumstance where we
have provided you with a clear statement (either verbal or in writing) of the
Express Consent Consequences.
Health Information means personal information
regarding the physical, metal or psychological health of an individual or other
information as defined pursuant to the Health Records Act.
Newsletters means regular email communications sent
by Asset Health Global Challenge (AH Global) which deliver personalised,
high-impact health and wellbeing information via HTML email – only if this was
approved as a communication medium by the employer.
Opt Out means an individual's expressed request not
to receive further communication from Asset Health Global Challenge (AH Global).
Personal Information means information or an
opinion (whether information or an opinion forming part of a database), whether
true or not and whether recorded in a material form or not, about an individual
whose identity is apparent, or can reasonably be ascertained from the
information or opinion. This includes, but is not limited to, an individual’s first
name, last name, or email address. It may also include, depending on the
circumstances, Sensitive Information.
Primary Purpose is the main reason for the
Collection of any Personal Information.
Reasonable Expectation means an individual's
reasonable expectation that their personal information might be Used or
Disclosed for the relevant purpose.
Related Body Corporate is given its meaning in the
Corporations Act 2001 (Cth).
Secondary Purpose means a purpose of Use or
Disclosure other than a Primary Purpose. Sensitive Information is given its
meaning in section 6(1) of the Privacy Act 1988 (Cth) and includes Health
Information.
Services means those services provided through a Asset Health Global Challenge (AH Global) Online Platform
Use means the handling of Personal Information within Asset Health Global
Challenge (AH Global) using the Asset Health Global Challenge (AH Global)
Mobile App.
12. CONTACTING Asset Health Global
Challenge (AH Global)
If you have general questions concerning this
Privacy Policy, please contact us on:
Our EU GDPR Representative is:
Rickert Rechtsanwaltsgesellschaft mbH
Asset Health Global Challenge (AH
Global), a division of NyxTek Development Studios (Pty) Limited
Colmantstraße 15
53115 Bonn
Germany
You can contact the Asset Health Global
Challenge (AH Global) EU GDPR Representative on the following email address:
(this address will soon be confirmed and made available).
This Privacy Policy was last updated on
27 Dec 2023.