Bowhead Health PTE and its affiliates (“Bowhead”, “we” or “us”) are committed to protecting the privacy of all individuals who (“you”):
To make this policy easier to read, we may refer to any or all of the Website, Transactions, Registrations, the Subscriptions, and the Uploads, as the "Offerings". When we talk about “Personal Information”, we mean information relating to you or another individual but only to the extent that such information can uniquely identify you, or its use can give rise to a high likelihood of identification, whether used alone or in connection with other associated or connected information that is either public or stored and/or acquired in association with the Offerings. For example, gender on its own may not be considered Personal Information, but it would be if, in addition to gender, information relating to, for example, age and postal code, were associated with one another as relating to the same person. Personal Information may include but is not limited to your name, mailing address, telephone number, e-mail address, and social insurance number.
Personal Information does NOT include information that has been anonymized or aggregated, nor does it include certain business contact information used for the purpose of communicating or facilitating communication with you, as an individual, in relation to your employment, business or profession and which cannot be used to identify you outside of such employment, business or profession. For example, a business email comprising of your name may be considered Personal Information, whereas a telephone number for contacting a place of business may not be. Please note that for the purposes of this Privacy Policy, anonymized or aggregated information will include any information that cannot be used to alone or in combination with other information about you that we collect from you via the Offerings to uniquely identify you.
Personal Information may or may not include certain Health Information or Financial Information; for example, if such information does not on its own, or in combination with other associated information relating to the same person, give rise to a high likelihood of identification, it will not be considered Personal Information. Health Information means any information relating to health, race, ethnicity, biology, medical history, and health treatment. Financial Information means any information relating to finance, money, banking, commercial transactions, value, or credit history.
Bowhead respects your privacy and the privacy of all users of the Offerings. This privacy policy respecting our treatment of Personal Information collected by Bowhead (the “Privacy Policy”) has been established to help you understand our commitment to protecting your privacy and personal data, and the steps we take to ensure it.
Bowhead reserves the right, at any time, to modify or replace the Privacy Policy. The most recent version of the Privacy Policy is available at www.bowheadhealth.com/#/privacy. Please check the Privacy Policy periodically for changes, although we will also notify you via email or other direct electronic communication method of any changes that materially impact your use of the Offerings or the treatment of your Personal Information, provided that we have that information and that you have given us consent to do so. While we will endeavor to re-obtain your consent after any such changes, we will, subject to your exercising your right to correct or delete your Personal Information (see below) as well as our Storage Policy (see below), maintain your Personal Information for the purposes of contacting you for the purposes of obtaining such consent upon any such changes.
Bowhead Tokens comprise encrypted technology using a distributed ledger technology (“DLT”). Blockchain is an example of a DLT. Bowhead Tokens may incorporate encrypted Personal Information, including Health Information. Transactions involving your Bowhead Tokens may be publicly visible due to the public nature of DLTs. Through the use of DLTs, by virtue of having control over your own private keys associated with Bowhead Tokens you control transactions relating to your own Bowhead Token, the information that is stored in association with your Bowhead Token, and who can use, access, or acquire your Bowhead Token and the incorporated personal information. Bowhead has no control over your Bowhead Token (subject to you granting control to Bowhead to your Bowhead Tokens and/or your private keys associated therewith). Accordingly, you retain all means to manage your own Personal Information and Bowhead has no ability to use, or indeed protect, any Personal Information associated with your Bowhead Tokens.
Subject to you transferring control, only you can control your own Bowhead Token. But you are able to sell, transfer, or provide access to the information in your Bowhead Token. You are also able to determine what Personal Information is associated in your Bowhead Token, and whether and how much of that information is accessible and/or transferrable. As such, Bowhead Tokens provide you with significant control but also significant risks. Bowhead, accordingly, takes no responsibility for any disclosure or use of the Personal Information associated with your Bowhead Tokens.
By attempting earn Bowhead badges or prizes, participating in Bowhead games, you consent to the granting of disclosure of certain Health Information, which may be Personal Information depending on what kind access is required for most if not all Bowhead badges or prizes. No Personal Information from this activity is used for any other purpose than to assess progress or other health criteria, and it is not collected or disclosed, unless it is rendered, through aggregation or other anonymization, non-personal information. Any such aggregated or anonymized data is the property of Bowhead health.
In general, Bowhead exchanges, collects, and uses information relating to Bowhead Tokens. The identity of the Bowhead Token holder is encrypted and unknown to Bowhead, as is any information associated with a Bowhead Token. Accordingly, unless you should grant Bowhead, or any other person or entity, access to your identity or your Personal Information associated with your Bowhead Token, this information remains encrypted, Bowhead will not and cannot access, use, or share any such Personal Information.
Bowhead may, however, collect and use Personal Information if you inquire about our services or Bowhead Tokens and we collect and use your information in order to respond to you and to keep you updated with respect to Bowhead policies via email or applications. In both cases, we typically request your name and email (which may or may not constitute Personal Information) in order to respond to requests or to provide you with requested Reports. We may also collect certain demographic and/or non-personally identifying information which is anonymized and/or aggregated and then stored separately from, and without linkage to, any Personal Information. We may collect such information through our Websites, Subscriptions, or Uploads, however, we may also collect information at trade shows, direct communications, etc.
We will never collect such information via a Bowhead Token (or indeed any Personal Information, unless you transfer your Bowhead Token, or some degree of control thereover to Bowhead). We will always collect your Personal Information by fair and lawful means (for example, by requesting such information when you request or inquire about a report on our web site; register to receive general, market, or commercial information, such as our Reports or product information; or if you register for or inquire about an event or web seminar hosted or made available by Bowhead).
For Personal Information collected after May 25, 2018, we will obtain your opt-in, informed consent for any non-Token collection as set forth herein. A record of such collection shall be maintained by Bowhead. For all Personal Information collected before or after May 25, 2018, whether or not such consent has been obtained, Personal Information may be used by Bowhead in connection with Bowhead’s Legitimate Interests.
These Legitimate Interests include creating and maintaining value of Bowhead Tokens, and supporting a transactions system for the use and exchange of such Bowhead Tokens for one or more third parties.
We will generally identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We may use your Personal Information for the following secondary purposes (for clarity, the term Purposes, as defined above, shall include these secondary purposes):
We have no ability to access or disclose information relating to any Bowhead Token, including the owner of said Bowhead Token and/or the Personal Information that may be incorporated therewith. Only the authorized owner or transferee of rights of the Bowhead Token may do that.
We will not sell, rent, lease, share or otherwise disclose to third parties any Personal Information provided to us, unless (1) consent is given to the disclosures in accordance with this Privacy Policy, having had prior access to this Privacy Policy, or in accordance with another specific request for consent, or (2) the information is first rendered anonymous, including but not limited through aggregation, encryption, obfuscation, hashing or other means, or (3) disclosure is required by law.
From time to time, we may share Personal Information and other information that we have collected about you:
Please note that we may send Personal Information outside of the country for the Purposes, generally for, but not limited to, reasons relating to processing and storage by our service providers. For example, we may have cloud storage providers with data storage facilities in the US, Canada, Europe, or other countries. Please note that data that is transferred to such other jurisdiction is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
We further note that information that is anonymized, aggregated, or otherwise rendered non-identifying to any data subject may be used in Reports. These Reports will be disclosed to third parties, as they are made available upon request, and shall remain available indefinitely.
We grant you the following privileges with respect to your own Personal Information that we have collected or stored in accordance with this Privacy Policy:
Exercising these privileges is easy. Send a request to our Privacy Representative at privacy@bowheadhealth.com with your name, email, and your request as relates to one of the four privileges outlined above.
Of course, any Bowhead Token owner has and has always had these privileges with respect to their own Personal Information associated with their own Bowhead Tokens – unless of course they have already transferred ownership or other rights therein.
We have implemented reasonable physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. Only Bowhead representatives with a business ‘need-to-know’ or whose duties reasonably require such information are granted access to your Personal Information.
No transmission over the Internet or electronic storage can be guaranteed completely. As a result, while we strive to protect personal information, we make no warranty or guarantee. You can help protect the security of your personal information. Bowhead requires as a condition of the use of the Offerings that you keep any user identifiers and/or passwords that you may use in association with the Offerings secure and do not share the use of your account with other individuals. Should we become aware of a breach of our security involving your personal information, we will take steps to notify you in a timely manner and shall comply with all other legal requirements.
Personal Information incorporated in Bowhead Tokens are encrypted in accordance with the applicable DLT technology. Moreover, transactions with respect to such Bowhead Tokens and such encrypted information, including access, disclosure, and deletion, are validated constantly in accordance with the applicable DLT technology.
There is no fixed period for storage of your non-Bowhead Token Personal Information that may be stored by Bowhead.
We will, however, delete such Personal Information upon occurrence of any of the following:
The storage period for any aggregated or anonymized information this is not Personal Information is indefinite, particularly if that information is used in any Reports, or research used for or intended to be used for Reports.
In addition to a request regarding the four privileges above, you may opt out of marketing communications sent by Bowhead by following the unsubscribe instructions included in each marketing email or by contacting us via email (support@bowheadhealth.com). Bowhead may use a third-party email distribution service to manage and distribute our communications (e.g. Mailchimp).
Our services are directed to sophisticated investors and not intended for children 18 or under, or any other person lacking the capacity to contract.
A “Cookie” is a small file placed on your device when you visit our Websites to provide Bowhead certain information about you and your interactions without Websites during subsequent visits; we use the term “Cookie” in this Privacy Policy to refer to cookies, pixel tags, web beacons, and other such files or programs that may be installed on your device for similar purposes. We associate a Cookie with information that may identify you (or your device) as a prior user of our Website, as well as certain attributes or actions that you have made in the past in association with the Website, and/or they may track your behaviour (in non-identifying ways) while you visit our Website. We may also use Cookies to improve and customize your experience with the Offerings, to help us recognize you across the Offerings, as well as to measure and analyze use of the Offerings.
Our server logs collect information about visits and system capabilities as you access and use the Offerings. We do not routinely associate such data with user-identifiable information except for investigative purposes as specifically described below. You may disable or block any by using the tools available in most browsers.
If you are registering for our websites, you may choose whether to activate automatic recognition of your computer based on the placement of a persistent cookie that identifies your computer. If you choose not to accept that persistent cookie, or to delete it at any time, you may be asked to re-enter certain information each time you access the website and or other information affecting your use of the Websites, for example, language and jurisdiction.
All comments, questions, concerns or complaints regarding your Personal Information, this Privacy Policy or our privacy practices, should be forwarded to our Data Protection Officer as follows.
E-mail: support@bowheadhealth.com
Or
Attn:
Data Protection Officer
Bowhead Health
support@bowheadhealth.com
