PRIVACY POLICY

Your privacy is important to Dr. Eve Gabrielyan, (“Healing Cove,” “we” or “us”). To better protect your privacy, we provide this notice (“Privacy Policy”) explaining what information we collect, how we might use that information and the choices you can make about the way your information is collected and used at www.healing-cove.com, through which you are accessing this Privacy Policy (the “Website”). The effective date of this Privacy Policy is December 5, 2020, and this Privacy Policy was last updated on the date set forth on the last page hereof.

The operator of the Website is Healing Cove. You can inquire about this Privacy Policy by contacting us at: eve@healing-cove.com. Please include the words “Privacy Policy” in the subject matter of your email.

By using the Website, you agree to the collection and use of information in accordance with this Privacy Policy.

The Website is not intended for use by individuals under the age of 18 and we do not knowingly collect personally identifiable information (relating to an identified or identifiable individual) (“PII”) from anyone under the age of 18.

In the European Union (“EU”), the processing of personal identifiable data is governed by the General Data Protection Regulation 2016/679 (“GDPR”). Under the GDPR, personal identifiable data is defined as: “Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.” Healing Cove complies with its obligations under GDPR by keeping PII up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting PII from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect PII. The legal bases for Healing Cove’s processing activities include processing such information as necessary to comply with our contractual obligations, compliance with our legal obligations, protecting the safety of our employees, guests and others, for our legitimate business interests, and pursuant to your consent.

“CCPA” means the California Consumer Privacy Act.   If you are a resident of California, under the CCPA you have the following rights:

The right to notice. You must be properly notified which categories of personal data are being collected and the purposes for which the personal data is being used.

The right to access / the right to request. The CCPA permits you to request and obtain from the Healing Cove information regarding the disclosure of your personal data that has been collected in the past 12 months by Healing Cove or its subsidiaries to a third-party for the third party’s direct marketing purposes.

The right to say no to the sale of personal data.  The CCPA also gives you the right to ask Healing Cove not to sell your personal data to third parties.  Healing Cove has determined that it will not sell personal data to third parties at this time.  If Healing Cove were to determine that it might sell personal data collected in the future to third parties, Healing Cove would first establish a “Do Not Sell My Personal Information” section or web page for you to request that it not do so in accordance with the CCPA.

The right to know about your personal data. You have the right to request and obtain from Healing Cove information regarding the disclosure of the following:

· The categories of personal data collected

· The sources from which the personal data was collected

· The business or commercial purpose for collecting or selling the personal data

· Categories of third parties with whom we share personal data

· The specific pieces of personal data we collected about you

The right to delete personal data. You also have the right to request the deletion of your personal data that has been collected in the past 12 months.

The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your rights, including by:

· Denying goods or services to You

· Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

· Providing a different level or quality of goods or services to You

· Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

· Exercising Your CCPA Data Protection Rights

Authorized Agent. You have the right to designate an authorized agent to make a request under the CCPA on your behalf. Please note that you must provide your authorized agent written permission to so act on your behalf, and your authorized agent must provide us with a copy of this document.

If you are a California resident, in order to exercise any of your rights under the CCPA, you can email us at eve@healing-cove.com.  Please include the words “CCPA Data Protection” in the subject matter box of your email. The business will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

1.      The Information Collected

At the Website, you can subscribe to one of our services (e.g., our online information services or our E-Newsletter), express an opinion, and connect to third-party web sites to order services and products. We collect PII that you provide to us. The types of PII that may be collected on the Website include, without limitation: your name, address, e-mail address, telephone number, fax number, and information about your interests in and use of various services, programs, and products. At times, we might request you provide to us your age or gender. We also may collect information you provide as part of a User Submission (as defined in our Terms of Use). All of this information is referred to in this Privacy Policy as “PII.”

Our servers also may automatically collect information about you, your online behavior and your computer, mobile or other device. The information collected may include, without limitation, the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of you and/or your computer, mobile or other device, as well as date/time stamp, IP address, pages visited, time of visits, content viewed, ads (if any) viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data.

If you choose to access, visit and/or use any third party social networking service(s) that may be integrated with the Website, we may receive PII and other information about you and your computer, mobile or other device that you have made available to those services, including information about your contacts on those services. For example, some social networking services allow you to push content from our Website to your contacts. Your decision to use a social networking service in connection with our Website is voluntary. However, you should make sure you are comfortable with the information your third party social networking services may make available to our Website by visiting those services’ privacy policies and/or modifying your privacy settings directly with those services. We reserve the right to use, transfer, assign, sell, share, and provide access to all PII and other information about you and your computer, mobile or other device that we receive through third-party social networking services in the same ways described in this Privacy Policy in respect of all of your other information.

“Do Not Track” Technology – Some newer web browsers have a “Do Not Track” preference that transmits a “Do Not Track” header to the websites you visit with information indicating that you do not want your activity to be tracked. We currently do not respond to browser “Do Not Track” signals.

However, some third party websites (which may include websites you access through links on the Website) do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser. Your use of third party websites including through links on the Website makes you subject to the terms of use and privacy policies of such other websites.

1.      Use of the Information

We use the PII you provide about yourself to administer your account, fulfill your requests for and provide you with access to our services, programs, and products, to respond to your inquiries about our offerings, and to offer you other services, programs, or products that we believe may be of interest to you. We also may use this information to communicate with you when we make changes to our subscriber agreements, to fulfill a request by you for an online newsletter, or to contact you about your account with us. In addition to the foregoing, we use the information you provide in connection with our social, community, and public discussion areas or as part of a User Submission to provide an interactive experience on the Website. For example, we may use this information to write e-mails, to publish submissions, to offer suggestions to and share stories with our readers or to offer you services, programs, or products.

We will not sell, transfer or otherwise disclose your PII to third parties, except as follows: (i) we may use third parties to perform specific functions on our behalf and we may disclose such information to help those parties perform their services; (ii) we may disclose such information in response to a legal process, order or investigation (for example, a subpoena or court order); (iii) we may disclose PII where disclosure is necessary to protect our legal rights or to protect us or others (for example, in order to reduce the risk of fraud or illegal activities); (iv) we may share or choose to sell such information with companies related to ours, and our affiliates, subsidiaries, business partners and advertisers for the purpose of marketing products, programs and services to you or for any other purpose related to our or their businesses; and (v) we may acquire, merge with or be acquired by another company or we might sell some or all of our assets, and, in such a case, we may sell and/or disclose your PII to another company.

We may use the information we collect about you, your online behavior and your computer, mobile or other device to improve the design and content of the Website and to enable us to personalize your Internet experience. We may also use this information in the aggregate to analyze site usage, as well as to offer you services, programs, or products. In addition, we reserve the right to use this information, which may at times be able to identify you, for any lawful business purpose, including without limitation to help diagnose problems with our servers, to gather broad demographic information, analyze trends, track users’ movements around the Website, and to otherwise administer the Website. In addition to all of the foregoing, we reserve the right to use, transfer, sell, and share aggregated, anonymous data about our users as a group for any lawful business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, and customers. Healing Cove may combine information we receive online with outside records to enhance our ability to offer information or market to you those services or products that may be of interest to you.

For more information regarding our use of information you submit to us, please review our Terms of Use.

III. Age

This Website is not intended for anyone under the age of 18, and no one under the age of 18 is allowed to register for the Website or provide any PII or use our social, community, and public discussion areas. If you are under the age of 18, do not, under any circumstance, submit any PII to us. By accepting the Terms of Use for the Website, you confirm that you are 18 years of age or older and are fully able and competent to enter into the terms, conditions, obligations, affirmation, representations and warranties set forth therein, and to abide by and comply with the Terms of Use and any applicable laws, statutes, ordinances, rules and regulations, including, without limitation, privacy laws, intellectual property laws, internet and anti-spam laws, and other applicable general business laws or regulatory requirements.

1.      Cookies and Other Technologies

The Service may place and/or store code or other types of information and/or devices (e.g., “cookies”) on your computer, mobile or other device (“Local Device Storage”). We may use Local Device Storage for any lawful business purpose, including without limitation to customize your visitation and shopping experience, to deliver content consistent with your stated interests, to provide you with custom-tailored content, to save your password in password-protected areas, to determine which of our messages have been opened by recipients so we can gauge the effectiveness of marketing campaigns, to control the display of ads, to track usage patterns, the movements of individual users, and your geographic location, to help diagnose problems with our servers, to gather broad demographic information, to analyze trends, to conduct research, to deliver editorial content, to record registration and personalization information, and to otherwise administer the Website. Most browsers are initially set to accept cookies. If you would prefer, you may be able to set yours to refuse cookies or to alert you when cookies are being sent. However, it is possible that some parts of the Website will not function properly if you do so. Cookies, by themselves, do not tell us your e-mail address or other PII unless you choose to provide this information to us. However, once you choose to furnish the Website with PII, this information may be linked to the data stored in the cookie.

In addition to Local Device Storage, we may use web beacons, also known as clear gifs, pixel tags, or web bugs (collectively, together with Local Device Storage, the “Tracking Technologies”). We may use Tracking Technologies for many of the purposes described above, in addition to allowing our service providers to track visitor traffic and actions on our Website. Third party service providers, including Instagram, may use Tracking Technologies to collect or receive information from our Website and elsewhere on the internet and use that information to provide measurement services and targeted advertisements.

1.      Security

We take precautions and have implemented certain technical measures intended to protect against unauthorized access to, loss of, disclosure of, and unlawful interception of PII submitted via the Website. We also limit internal access to PII to a select list of our personnel on a “need-to-know” basis. However, because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the information you send to us or the security of our servers, networks or databases. Your communications containing PII may be unlawfully intercepted or accessed by third parties and/or the Website may be subject to network attacks or malfunctions. Accordingly, we cannot and do not guarantee that your PII or any other information is completely secure and safe from any risk, and you provide information to us at your sole risk. By using the Website you agree that we are not responsible for any inadvertent loss of such information or the consequences thereof.

1.      Links to/from Other Sites

The Website contains links to other web sites that are operated by third parties. With prior permission, other sites may also reference or link to the Website. To obtain permission, send an e-mail to eve@healing-cove.com. The services or products described or advertised on the Website are generally sold by other parties on other sites. Healing Cove is not responsible for the privacy practices or the content of those other sites. Healing Cove makes no representations concerning any effort to review the content of sites to which it may be linked and has no control over information submitted to other sites. Visitors should consult the other sites’ privacy notices prior to submitting any information to those sites, as we have no control over information that is submitted to, or collected by, these third parties.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

VII. Your Access to Your PII

If you would like to know the types of information that Healing Cove collects from visitors to the Website, please contact us. If you would like to know whether Healing Cove has collected PII about you, please send us the activities that you participated in on our Website which requested PII; after reviewing the relevant databases, we will confirm whether we have collected such information about you. You may review PII about you in our records at any time provided you first give us proof of your identity via email, such as a copy of a valid driver’s license with your name and address. You will have the ability to update your personal information in your user profile page, and, if you request, we will change any inaccuracies in the PII we have that pertains to you, and/or end any direct communications with you, or even delete your PII altogether. Even after such modification or deletion, however, there may be residual information that will remain within our databases that may or may not contain PII. This residual information will not be given to any third party or used for any commercial purpose. The Website shall comply with any state privacy laws with respect to collection of personal information, including, but not limited to, the California Shine the Light Law.

VIII. Revisions

We may modify or supplement this Privacy Policy at any time without notification to you. The current version of this Privacy Policy will be posted to the Website. You are encouraged to review this Privacy Policy from time to time. Changes to this Privacy Policy are effective when they are posted on this page.

1.      Disputes

This Privacy Policy is governed by the internal substantive laws of the State of California, without reference to its conflict of laws principles. All disputes shall be resolved as described in Healing Cove’s Terms of Use.

Last Updated: December 5, 2020