Last updated in SEP 2023

Thank you so much for visiting the R3NEWAL website.

1. GENERAL INFORMATION 

1.1 DEFINITIONS 

1.2 IDENTIFICATION OF WEBSITE OWNER AND CONTROLLER. 

1.3. Minimum age requirement to access and using website information. 

2. DATA PROTECTION CONTACT 

3. PERSONAL DATA PROCESSED BY VISITING AND USING RENWAL WEBSITE 

4. Legitimacy for data management 

4.1. Consent forms 

4.2. Testimonials and Personal Data 

5. COOKIES 

6. INTERNATIONAL DATA TRANSFER and DATA LOCATION (RECIPIENTS) 

7. DATA RETENTION 

8. YOUR RIGHTS AS A DATA SUBJECT 

8.1 PROCEDURE 

8.2 RESPONSE PERIOD 

8.3 DENIAL OF REQUESTS 

9. PRIVACY POLICY EXTENSION 

10.DISCLOSURE OF YOUR PERSONAL DATA 

11. GOOGLE ANALYTICS 

12. SOCIAL MEDIA 

13. LINKS TO OTHER WEBSITES

14. SECURITY MEASURES IN PLACE FOR PROCESSING YOUR DATA

15. CHANGES TO REN3WAL PRIVACY POLICY

 1. GENERAL INFORMATION 

Part of Br3athe success is the company attention to global data privacy: At BR3ATHE GROUP (hereinafter ‘Br3athe’ or ‘the company’) have hired a best-in-class Data Privacy Consultant that taught the company team with advance knowledge in this rapidly evolving area, ensuring the compliance and risk management. BR3ATHE is committed to user privacy and invest in the customer trust.

This Privacy Policy (hereinafter ‘Policy’) outlines how BR3ATHE collect, use, disclose, process and security your personal data during your interacting with REN3WAL website as well during the use of the company platform and services.

All focusing in being in accordance with the relevant data protection legislation, especially the European General Data Protection Regulation (hereinafter GDPR) EUR-Lex – 32016R0679 – EN – EUR-Lex (europa.eu) 

The objective of this Policy is to explain exactly what is entailed in this process in further detail below.

 1.1 DEFINITIONS   

Adequacy Decision – A decision issued by the European Commission that a country or region or a category of recipients in such country or region is deemed to provide an “adequate” level of data protection.

Confidential Information – means any information disclosed by either party to the other party, either directly or indirectly, in writing, orally or by inspection of tangible objects (including, without limitation, documents, prototypes, samples, plant and equipment), which is designated as ‘Confidential,’ ‘Proprietary’ or some similar designation by the Company.

Controller – refers to the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by EEA/EU.

Customer – shall mean any person, private organization, or government body that purchases, may purchase, or has purchased an Br3athe product or service.

Data Concerning Health – means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.

Data Protection Officer (DPO) – means an independent data protection expert who has numerous responsibilities regarding data processing in the Company, such as: (i) monitoring an organization’s data protection compliance; (ii) informing the Company about and advising it on its data protection obligations; (iii) providing advice on data protection impact assessments (DPIAs) and monitoring their performance; and (iv) acting as a contact point for data subjects and the relevant data supervisory authorities.   

Data Protection Law – shall mean the provisions of mandatory law of an EEA country containing rules for the protection of individuals with regard to the Processing of Personal Information including security requirements for and the free movement of such Personal Information.

European Union (EU) and European Economic Area (EEA) countries – The area set up by the EEA agreement, comprising the 27 Member States of the European Union and the three countries of EFTA (the European Free Trade Association), which are bound by the Agreement on the European Economic Area (EEA). The 27 Member States are Austria, Belgium, Bulgaria, Croatia, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden. The three EFTA countries which are also bound by the Data Protection Directive, through being part of the EEA, are Iceland, Liechtenstein and Norway.

GDPR - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Individual – shall mean any Customer, Supplier or Business Partner (employee of or any person working for) and any other person whose personal Information Br3athe processes in the context of the provision of its services.

Information/data – shall refer to knowledge communicated or received via materials and/or data produced by, procured by, or obtained for Br3athe that can be in electronic or physical (e.g., printed or written on various physical media) form.

Personal Data – refers to any information relating to an identified or identifiable natural person (‘data subject’); 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.

Processor – means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.  

Sensitive Information – shall mean personal data that reveals an Individual’s racial or ethnic origin, or philosophical beliefs, membership in a professional or trade organization or union, physical or mental health including any opinion thereof, disabilities, genetic CSB Information, biometric CSB Information, addictions, sex life, criminal convictions or offenses, or social security numbers issued by the government. Sensitive information encompasses a broader category of personal data, including not only health data but also other sensitive attributes like mentioned before.

Supplier – shall mean any Third-Party that provides goods or services to BR3ATHE (e.g., an agent, consultant, or vendor), including Third-Party Processors.

Third Country - Any country other than the EU and EEA Member States.

 1.2 IDENTIFICATION OF WEBSITE OWNER AND CONTROLLER.  

Pursuant to the GDPR and Spain´s Personal Data Protection and Digital Rights Laws BR3ATHE may be as well considered a CONTROLLER of your personal data. By acting as a Controller, BR3ATHE can determine the purposes and means by which the processing of your personal information is collected. However, before collecting your information the Company will request your consent during registration, as it is required by legislation before the continuation of registration.  

 1.3. Minimum age requirement to access and using website information.  

REN3WAL services are intended for individuals who are at least 18 years old. By accessing or using REN3WAL website the data subject represents and warrant that he meets the minimum age requirement and that he have the legal capacity to give digital consent and to use the information available in this website. If you are accessing or using REN3WAL services on behalf of a minor, you further represent and warrant that you are the parent or legal guardian of the minor and have the authority to bind them to these terms.

BR3ATHE at REN3WAL website do not collect, process or maintain personal data of individuals under the specified minimum age. If the data subject do not meet these age requirements or do not have the necessary legal representation, he must not access or use REN3WAL webservices.

 2. DATA PROTECTION CONTACT 

REN3WAL as part of BR3ATHE GROUP has a Data Protection Officer based in Europe who is well versed in European Data Protection Regulations. Users may contact them at the following email address dpo@br3athe.es.

If you have any questions or concerns regarding this Policy, please don’t hesitate to contact REN3WAL DPO.

 3. PERSONAL DATA PROCESSED BY VISITING AND USING RENWAL WEBSITE 

When the data subject visit REN3WAL website and/or use REN3WAL services the visit will be logged, and the following data may be collected:

∙ Date and time

∙ IP address currently used by your device

∙ Browser type and operating system of your device, and pages accessed

∙ The time the data subject spend on those pages

∙ Device identifiers and other assessment data. You can review REN3WAL Cookie Policy here.   

Similarly, the data BR3ATHE request from the data subject in the forms on REN3WAL website is appropriate and strictly necessary for the following purposes:

∙ To provide and maintain REN3WAL service, including to monitor the usage of the company service.

∙ To manage data subject account: to manage the data subject registration as a user of the service. The personal data provide by the data subject can give him access to different functionalities of the service that are available for registered user.

∙ For the performance of a contract: the development, compliance and undertaking of the purchase contract for the services that the data subject has purchased or of any other contract with REN3WAL through the service.

∙ Handling and responding to data subject contact, query and/or complaint requests.

∙ Send to data subject communications that include relevant information about the contracted service.

∙ For the download of REN3WAL Free booklet.

∙ For booking the RESIDENTIAL DETOX PROGRAM or the REMOTE PROGRAM

∙ The communication by chatbot where REN3WAL can assist the data subject during your visit or related with the services that the company provide.

∙ Registering for REN3WAL webinars.

The processing is legally based on legitimate interest, i.e., it is in BR3ATHE legitimate interest to protect REN3WAL website and to improve the quality of the company services. The purpose of collecting this data is optimizing and improving REN3WAL website as well REN3WAL services.

The personal data provided by the data subject in the registration form will only be processed to respond to his/her request and further support in using the company services. Filling out and submitting the contact form indicates an affirmative action by which you, as data subject, have given the consent for the data processing.

The following personal data will be collected:

∙ Full name;

∙ Phone number;

∙ Email;

∙ Company;

∙ Role (optional);

∙ Details about your health condition; and

∙ IP address.

∙ The data subject can also let BR3ATHE know the areas of interest and can leave a message with suggestions or questions. Note: In this field, please do not provide additional personal data, only those listed above in the appropriate fields.

∙ In some specific situations, with previous specific and freely given consent, Br3ath collect testimonials to showcase the benefits of the programs and the positive experience of the clients, that includes photo, name, age, nationality, and experience, to be displaying on Ren3wal website and social medias.  

The data subject personal data will only be recorded until he cancels the subscription. If him proceed with the cancelation, the personal data will be deleted without undue delay except where BR3ATHE are legally obliged by law to further store the data subject information and data. Please, note that after that the data subject will no longer be able to use the customer account after it has been deleted. In case of changing your mind later, please proceed with a new registration.

The company collect and process sensitive information data solely for the purpose of providing to the data subject, REN3WAL REMOTE DETOX PROGRAM and RESIDENTIAL DETOX PROGRAM, with an advanced individual program tailored to the specific needs. The information collected may include but is not limited to medical records, test results, treatment plans used and introduced so far, and any other data relevant to the data subject health history, that him understand pertinent for BR3ATHE to know.

BR3ATHE use this sensitive information data to:

∙ Develop personalized actions plans tailored to your specific needs.

∙ Monitor and track of your progress.

∙ Ensure the highest standard of care and safety throughout the process.

∙ Comply with legal and regulatory requirements related to services.

REN3WAL, as part of BR3ATHE GROUP, employ strict technical, physical, and administrative measures to protect your sensitive information data from unauthorized access, disclosure, alteration, or destruction. BR3ATHE medical staff is trained to handle sensitive data with the utmost confidentiality and is bound by strict confidentiality agreements and BR3ATHE may share your sensitive information or data with trusted third-party service providers who assist us in delivering the company services, medical professionals involved in your care, and regulatory authorities as required by law. Before sharing your data, BR3ATHE ensure that these entities have appropriate data protection measures in place and are compliant with relevant laws. The sensitive information will not be used for marketing or advertising purposes.

 4. Legitimacy for data management 

Regarding the processing of data subject by BR3ATHE it will be legitimated by the explicit consent given by the interested party for the processing of his/her personal data with the intended purposes. The unequivocal and independent consent for each processing purpose is manifested when accepting the Privacy Policy.

By interacting with REN3WAL chatbot, the data subject acknowledges and consent to the collection, use and disclosure of the information provide during the conversation. This includes but is not limited to personal information, chat logs, and any other data generated through the interaction. The company may share this information with BR3ATHE affiliates, service providers, and third parties as necessary to fulfill the purposes outlined in REN3WAL Privacy Policy, which may include providing customer support, improving the company services, or complying with legal obligations. BR3ATHE will handle your information in accordance with applicable privacy laws and take reasonable measures to protect its confidentiality and security.

Furthermore, by using the company services and providing your personal information, including but not limited to sensitive information such as health-related information or biometric data, the data subject expressly consents to the collection, storage, and processing of such information by BR3ATHE. The company only use this sensitive data for the purposes of providing and improving REN3WAL services, conducting research, complying with legal obligations, and as otherwise described in this Privacy Policy.

 4.1. Consent forms  

Several consent forms are used to obtain permission from the data subject before collecting or processing their personal data. For example: for the download of the Free Booklet or to book one of the programs.

Each consent form will have a different scope of information to be authorized the collection of data so on each one will have a different form to allow free consent to be given. The company understand that it is an essential part of ensuring compliance with data protection laws.  

The data requested by BR3ATHE from the data subject in the forms on REN3WAL website is appropriate and strictly necessary for the purposes mentioned above at Section 3 of this Privacy Policy.    

 4.2. Testimonials and Personal Data  

Additionally, as explained before, in case of displaying testimonials on Ren3wal website or social medias to provide prospective customers with insights into the positive experiences of Ren3wal current and past customers BR3THE will collect consent of the individuals involved (data subjects) obtaining permission to use and disclosure their private data and information, such as full name, photo, age, nationality, testimonial text and video/audio.  

Individuals whose testimonials are displayed on our website have the right to access, rectify, or request the deletion of their personal data and testimonials according with the procedure established on this Privacy Policy item number 8.1.

Br3athe retain testimonials and associated personal data only for as long as necessary to fulfill the purpose for which they were collected. When the purpose no longer exists, we securely delete or anonymize the data, following the internal policies.

They can do so by contacting dpo@br3athe.es.

 5. COOKIES 

When someone visit REN3WAL website, the company use ‘cookies’ to make the visit more enjoyable, in addition to allow the person to access and use certain functions, in accordance with GDPR and the ePrivacy Directive (Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002).

Cookies are small text files that websites store/place on the data subject device (such as laptop or smartphone) when visiting a website. These files contain information about the user’s interactions with the website, preferences, and other data. They are processed and stored by the web browser. Cookies serve various purposes, including improving the experience, enabling website functionality, and providing analytics to website owners. Don’t forget that the data subject can generally easily viewed and deleted the cookies.

Some of the cookies BR3ATHE use are deleted after the browser session ends. However, other cookies can remain on the user device and enable the company or BR3ATHE partner companies to recognize the browser o the next visit. It is possible to configure the browser so that can be informed about all kinds of cookies that are in use. In this way, the data subject can individually allow access to certain cookies while excluding the other ones. If you do not accept certain types of cookies, it is possible that certain functionality on REN3WAL website will be limited.

To find out more, see the help function of your internet browser. Additionally, you can know how REN3WAL use cookies accessing REN3WAL Cookies Policy by clicking on: Cookies Policy.

In addition, for more information about your rights under the ePrivacy Directive click on the following link: EUR-Lex – 32002L0058 – EN – EUR-Lex (europa.eu) 

 6. INTERNATIONAL DATA TRANSFER and DATA LOCATION (RECIPIENTS) 

Third party service providers who process your personal data may be located in countries within and outside the European Union (EU) and the European Economic Area (EEA). Whenever possible, BR3ATHE aspire to ensure that these providers have an adequate level of data protection, even if personal data is transferred to a country outside the EEA for which there is no EU Commission Adequacy Decision.

Please note that transfers of personal data to other recipients are not carried out, except when the company are required to do so by law. Your data may also be disclosed to public authorities or other organizations for the purpose of meeting Br3athe legal obligations.

If you need more information about appropriate safeguards for the international data transfer or a copy of them, please contact Br3athe DPO, that can be contacted through the channels provided above on item 2.

BR3ATHE would like to emphasize that your information is processed and stored only in the EEA and the UK in the company’s internal system.  

BR3ATHE emphasize that we have a hosting for the website, however no personal information is collected and process by this hosting.

∙ A2 Hosting – More information about their privacy policy can be found here  A2 Hosting Website Privacy Policy. For more information about their database, please click on https://www.a2hosting.com/about/data-center/ 

BR3ATHE will comply with applicable data protection laws in the event that BR3ATHE need to transfer your personal data outside the EEA. Below are some of the mechanisms that the company may use when transferring your personal data abroad:

∙ The data subject personal data is transferred to a country the European Commission officially recognizes as ensuring a suitable level of personal data protection.

∙ BR3ATHE reserve the right to use specific contracts approved by the European Commission which afford personal data the same protection as they have in Europe (known as EU Standard Clauses).

 7. DATA RETENTION 

The data subject personal data provided to us via REN3WAL website will only be stored until the purpose for which it was processed has been fulfilled or until the data subject withdraw the consent. Retention periods under commercial and tax law must be observed in accordance with the customs and laws of your locality.

In general, the data of the data subject will be recorded in BR3ATHE internal system for subscription and/or registration for two years, after which period BR3ATHE will send to the data subject an email requesting the renewal of this subscription and/or registration. However, storage periods may also be amended due to BR3ATHE legitimate interest (e.g., to guarantee data security, to prevent misuse or to prosecute criminal offenders) to the exercise or defense of legal claims under applicable law.

This period will in any case be limited and BR3ATHE will contact you to have your registration/subscription renewed.

 8. YOUR RIGHTS AS A DATA SUBJECT 

As a data subject, have rights that may be request and that BR3ATHE highly respects, according to the following descriptive list:

∙ Right to receive information about the data processing;

∙ Right to access information about personal data that BR3ATHE hold about yourself;

∙ Right to demand the rectification of inaccurate data or incomplete data, in addition to changes to your personal data. Nevertheless, the data subject may also update the personal data directly in your account settings whenever is possible;

∙ Right to request the erasure of your personal data (the right to be forgotten) the data subject can ask to delete your personal data, after they have been blocked;

∙ Right to demand us the restriction of the data processing under certain circumstances;

∙ Right to data portability and receive the personal data concerning the data subject in a systematic, commonplace and machine-readable format and to demand the transmittance of these data to another controller;

∙ Right to object, the data subject can withdraw the consent for data processing of his/her personal data by objecting to the further procedure;

∙ Right to withdraw a given consent at any time to stop a data processing that is based on your consent; and

∙ Right to file a complaint with the competent supervisory authority according to your location.

The data subject can exercise his/her rights by writing to BR3ATHE by emailing dpo@br3athe.es.

However, BR3ATHE recall that depending on the circumstances and the nature of the request it may not be possible for the company to do what have been asked. For example, where there is a statutory or contractual requirement for BR3ATHE to process personal data, it would interfere with the legal obligations if BR3ATHE were to stop.

For more information on your rights is available from the links below:

EUR-Lex – 32016R0679 – EN – EUR-Lex (europa.eu) 

 8.1 PROCEDURE 

Any requests to exercise the data subject’s rights should be sent to the DPO via email to dpo@br3athe.es

Prior to fulfilling the request of the individual, BR3ATHE may require them to:

∙ Specify the categories personal information to which he or she is seeking access;

∙ Indicate, to the extent reasonably possible, the system in which the individual’s data is likely to be stored;

∙ Specify the circumstances in which REN3WAL obtained their Information;

∙ Provide proof of your identity when BR3ATHE has reasonable doubts concerning it, or provide additional information enabling your identification;

∙ In case of a request for rectification, deletion, or restriction, specify the reasons why the personal data is incorrect, incomplete, or not processed in accordance with BR3ATHE policies or data privacy legislation.

 8.2 RESPONSE PERIOD 

Within one calendar month of BR3ATHE receiving the request, the Company shall inform the individual in writing or electronically either:

∙ of BR3ATHE position regarding the request and any action the BR3ATHE has taken or will be taking in response; or

∙ of the ultimate date on which the data subject will be informed of BR3ATHE position and the reasons for the delay, which shall be no later than two calendar months after the original one-month period.

 8.3 DENIAL OF REQUESTS 

BR3ATHE may deny your request if (listed but not limited):

∙ the request does not meet the requirements of the item (1) above;

∙ the request is not sufficiently specific;

∙ the identity of the relevant individual cannot be established by reasonable means, including additional information they provided; or

∙ BR3ATHE can reasonably demonstrate that the request is manifestly unfounded or excessive.

 9. PRIVACY POLICY EXTENSION 

This Privacy Policy refers only to the data collected and processed by REN3WAL website and its subdomains, and applies to the entire company, including all subsidiaries. If you are one of BR3ATHE  workers, employees, service providers, contractors, subcontractors or otherwise maintain a contractual relationship with the Company, please contact your manager or the responsible parties, as per BR3ATHE  contractual relationship and/or consult BR3ATHE  internal (and/or local) privacy policies related to your area of expertise or partnership, which can be found through the channels you have access to.

 10.DISCLOSURE OF YOUR PERSONAL DATA 

BR3ATHE may share your personal information in the following situations:

• With third-party service providers: BR3ATHE may share your personal information with Service Providers to monitor and analyze the use of REN3WAL Service. The company will seek to share the minimum amount necessary. BR3ATHE may use third-party tools to monitor and analyze the use of the company websites, and to automate certain processes related to the development and operation of REN3WAL websites.

• With affiliates: The company may share our information with BR3ATHE affiliates, in which case BR3ATHE will require those affiliates to honor this Privacy Policy. Affiliates include BR3ATHE parent company and any other subsidiaries, joint venture partners or other companies that BR3ATHE control or that are under common control with us.

• With business partners: The company may share your information with BR3ATHE business partners to offer certain products, services, or promotions.

• With your consent: BR3ATHE may disclose your personal information for any other purpose with your explicit consent.

• Law enforcement: Under certain circumstances, BR3ATHE may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

• Other legal requirements:  BR3ATHE  may disclose your personal data in the good faith belief that such action is necessary to: (i) Comply with a legal obligation; Protect and defend the rights or property of the Company; (ii) Protect vital interests of the data subject or of another natural person; (iii) Prevent or investigate possible wrongdoing in connection with the Service; (iv) Protect the personal safety of users of the service or the public; Protect the public interest or to exercise official authority; (v) Protect against legal liability.

 11. GOOGLE ANALYTICS 

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of REN3WAL service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

The data subject can opt-out of having made your activity on the service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

 12. SOCIAL MEDIA  

REN3WAL has profiles on the main social media sites (LinkedIn, Instagram, Facebook, Twitter, YouTube, and Blog) and acknowledges that it is the controller for processing the data of its users, followers and people who post comments on these sites. Equally, it disclaims any liability whatsoever for comments made by users and followers on its social media profiles.

REN3WAL may use the profiles specified above to share information with its customers and other stakeholders on topics it thinks they may be interested in.

 13. LINKS TO OTHER WEBSITES 

REN3WAL website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. BR3ATHE strongly advise you to review the Privacy Policy of every site you visit. The company have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

 14. SECURITY MEASURES IN PLACE FOR PROCESSING YOUR DATA  

BR3ATHE have put in place security measures to ensure personal data processing systems’ confidentiality, integrity, availability, and resilience. BR3ATHE also verify and assess regularly the technical and organizational measures and have implemented to safeguard the security of personal data.

Currently, BR3ATHE has an internal Global Data Privacy Program, led by the DPO. All Data Privacy related documents are collected, maintained, and retained using world-class security and technology features and software.

 15. CHANGES TO REN3WAL PRIVACY POLICY 

BR3ATHE want to be as transparent as possible about the changes we make to this Privacy Policy, so we recommend that you review it from time to time.