Version: v2.0

Date: May 2023

CyberLiver, Ltd. and its affiliates (collectively “CyberLiver”, “We”) are committed to protecting your privacy. This Privacy Policy applies to all our websites (www.cyberliver.com, www.alcochange.com, www.cirrhocare.com ) and our associated mobile applications owned and controlled by CyberLiver (collectively, “Apps”). This Privacy Policy governs our data collection, processing, and usage practices. It also describes your choices regarding use, access, and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the Mobile applications, Platforms, Websites and other online services.
We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification through our data processors, through Notifications in the app in your app web portal.
While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.
If you have any questions about this Privacy Policy or our treatment of the information you provide us, please contact us using the details provided at the end of this policy.

1. Information We Collect
2. How We Use Information We Collect
3. How We Share Information We Collect
4. International Transfer of Information
5. Cookies and Similar Technologies
6. How to Access & Control Your Personal Data

1. Information We Collect

When You use our Portal, App and Visit our Websites
You are free to explore the Websites without providing any Personal Information about yourself. When you visit the App Store, Play Store and Websites and register for using the Services, we request that you provide Personal Information about yourself, and we collect Navigational Information.

When You Use our Mobile Application
We use mobile analytics software to allow us to better understand the functionality of our Mobile Apps on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. In addition to the information we collect on our Websites, when you use our Mobile Apps we may also collect your city location, device model and version, the device identifier (or “UDID”), OS version, and your CyberLiver account credentials.
We send push notifications from time to time in the app as motivational messages, to update you on events or promotions. If you no longer wish to receive such communications, you may turn them off at the device level.
We may link information we store within the analytics software to Personal Information you submit within the Mobile App. We do this to improve services we offer you and improve our marketing, analytics and site functionality.

“Personal Information”
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, date of birth, gender, location, height, weight and other information about yourself. Personal Information can also include information about any transactions, both free and paid, that you enter into on the app, and information about you that is available on the internet, such as from Facebook, Google where you’ll use it for signing in to the app/portals.
Personal Information also includes all your health and activity information submitted to the apps or collected via sensors, . Your payment information is stored in Google Play account, PayPal and iTunes account who are data processors and is secure. We don’t store any of your payment information in our databases and all the payments are carried out through secure 3rd party payment portal and are covered under their terms and privacy policies.

Log Files
When you use our services or view content provided by us, we automatically collect information about your mobile phone, computer hardware, and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by CyberLiver for the operation of the platform Services, to maintain the quality of the Service, and to provide general statistics regarding use of the CyberLiver app and website. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address and are pseudonymised.

Information we collect from third parties
We don’t collect any Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities and publicly available sources such as social media websites.

Information About Children
The app and websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at [email protected], so that we may delete the information.

2. How We Use Information We Collect

Compliance with Our Privacy Policy
We use the information we collect only in compliance with this Privacy Policy. Users who subscribe to our app and platform services are obligated through our agreements with them to comply with this Privacy Policy.

We Never Sell Personal Information
We will never sell your Personal Information to any third party.

Use of Personal Information
In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:
• improve your browsing experience by personalizing the app and websites and to improve the Service;
• send information or CyberLiver content to you which we think may be of interest to you by push notification, email, or other means and send you marketing communications relating to our business;
• promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
• we share your personal information with our partners who have a legal contract with us to collect/use your data. Our partners will get consent from you through email.
• send information to you regarding changes to our Terms of Service, Privacy Policy (including the Cookie Policy), or other legal agreements
• meet legal requirements.
We do not transfer your Personal Information to any third party.
We use the information collected through our Apps and website Premium Subscription Service by our users for the following purposes:
• to provide the Premium Subscription Service (which may include the detection, prevention, and resolution of security and technical issues);
• to respond to user support requests; and
• otherwise to fulfill the obligations under the CyberLiver Terms of Service.
Legal basis for processing Personal Information (EEA visitors only)
If you are a visitor/user located in the European Economic Area (“EEA”), CyberLiver Limited is the data controller of your personal information. CyberLiver’s Data Protection Officer can be contacted at [email protected].
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

User Testimonials and Comments
We post user testimonials and comments on our App pages, Web sites, and portal which may contain Personal Information. We obtain each user’s consent via email prior to posting the user’s name and testimonial.

Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.

Social Media Features
Our Websites include Social Media Features, such as the Facebook/Google Login, Facebook Like button and Widgets, such as the Share This button or interactive mini-programs that run in our app and portal. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our app and websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

External Websites
Our Apps, portal and websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.
Public Forums
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in “Opting Out and Unsubscribing” below.

Retention of Personal Information
How long we keep the information we collect about you depends on the type of information. as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate product/service/portal need to do so (for example, as long as is required in order to enable you to login to the app or portal or to access our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing product/service/portal need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in “To Unsubscribe from Our Communications” below.
If you provide information to our partners as part of their use of the app or portal or services, our partners decide how long to retain the personal information they collect from you. If a user requests to terminates the use of the app or portal or services, then we will provide the user with access to all information stored in our database on request, including any Personal Information, for export according to our agreement with you. After termination, we may, unless legally prohibited, delete all user information, including your Personal Information, from our databases.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences until the end of that calendar year from the date you last expressed interest in our app, portal, content, products, or services, such as when you last opened the app, email from us or ceased using your CyberLiver account. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.

3. How we Share Information we Collect

CyberLiver Partners & Research
We may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide user support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
We partner with trusted organisations and experts within our organisation who use the data collected from you to do analysis, research and release the results in public domain and we ensure you that whenever the research results are published the user identifier is anonymised and are not shared with any third party.
We may contact you to get consent if you’re willing to be a part of future research and sign a separate privacy and research agreement at that time.

Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by CyberLiver on the app, portal, websites and other services. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.

Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

4. International Transfer of Information

International Transfers within CyberLiver’s Entities
To facilitate our global operations, we transfer information to India or United States and allow access to that information from countries in which the CyberLiver affiliated entities have operations for the purposes described in this policy.
This Privacy Policy shall apply even if we transfer Personal Information to other countries. We have taken appropriate safeguards to require that your Personal Information will remain protected. When we share information about you within and among CyberLiver’s affiliated entities, we make use of standard contractual data protection clauses, which have been approved by the European Commission.

International transfers to third parties
Some of the third parties described in this privacy policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share information of users in the European Economic Area or Switzerland, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.

5. Cookies and Similar Technologies

Cookies
CyberLiver and its partners use cookies or similar technologies (such as web beacons) to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.

Single Sign-On
You can log in to our Apps or portals using a Single Sign-on (SSO) service using your email, Facebook or Google logins. This service will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.

Advertising
We don’t partner with any third party to advertise in the app or portal or website based on your personal preferences and data. We don’t share or sell any personal information to any third party with respect to advertising or marketing.

Third Party Tracking Technologies
We use Google analytics to track the user behavior on the app, portal, and websites and tracking utilities are not covered by our Privacy Policy or Cookie Policy.

7. How to Access & Control Your Personal Data

Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
• You can request access, correction, updates or deletion of your personal information.
• You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)
To exercise any of these rights, please contact us at [email protected]. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

To Unsubscribe From Our Communications
You may unsubscribe from our communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by sending us an email at [email protected] or [email protected]. Users cannot opt out of receiving transactional emails related to their account with us or the Premium Service. To Unsubscribe from Our Partners Communications
Our partners are solely responsible for their emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our users’ marketing communications by clicking on the “unsubscribe” link located on the bottom of their emails, or by contacting them directly.

Contact
CyberLiver Limited,
First Floor, Burnells,
5 Garland Road,
Stanmore,
Middlesex,
HA71NR, UK,
[email protected], [email protected]