Privacy Policy

1. INTRODUCTION

TheOptimal.me (“the Website”) is a website operated by FireFinch Limited (“FireFinch”), offering educational information on health, fitness and nutrition.

This document sets out FireFinch’s privacy policy relating to your use of the Website.  This Privacy Policy must be read together with FireFinch’s Terms and Conditions of Use appearing on the Website.

This Privacy Policy applies to all personal information collected and/or processed by us which will be reviewed every three years.

All terms (including capitalised terms) not otherwise defined in this Privacy Policy (the “Privacy Policy”) shall have the meaning ascribed to them in the Terms and Conditions of Use.

FireFinch Ltd (“FireFinch”, “we”, “us” or “our”) knows that you care how information about you is collected, used, disclosed, transferred and shared and we appreciate your trust in us to do that carefully and sensibly. This Privacy Policy will help you understand what personal data we collect, why we collect it, how we intend to use the personal data you provide to us and whether we will share your personal data with anyone else.

By visiting the Website and/or subscribing to our services, you are accepting and consenting to the practices described in this Privacy Policy.  FireFinch may, from time to time, revisit and update the Privacy Policy.  Any updates will be posted on the Website.

2. COLLECTION OF PERSONAL INFORMATION

Any personal information collected, processed and stored on the Website is done by FireFinch pursuant to the applicable provisions of the Data Protection Act 2017 (Mauritius) as well as the General Data Protection Regulations (“GDPR”) applicable throughout the European Union, as may be amended from time to time.

3. DATA OFFICER

The Data Officer at FireFinch is David Axton whose details are as follows: 

Address: 6th Floor, Dias Pier Building, Le Caudan Waterfront, Caudan, Port Louis 11307, Mauritius
Tel : +230 405 4000
Email: Help@TheOptimal.me
The Data Officer shall take responsibility for ensuring our ongoing compliance with this Privacy Policy.

4. WHAT PERSONAL INFORMATION ABOUT CUSTOMERS DO WE COLLECT?

  • The personal information that we collect and process may include:
  • Basic information, such as your name, your title or position;
  • Contact information, such as your physical address, email address and phone number(s);
  • Financial information, such as credit card details;
  • Technical information (including your IP address), such as information from your visits to the Website or applications or in relation to materials and communications we send to you electronically;
  • Information you provide to us for the purposes of customising our services for you;
  • Identification and background information provided by you or collected by us as part of our business processes; 
  • Personal information provided to us by or on behalf of our clients, and partners or generated by us in the course or providing services;
  • Any personal information which you may be required to provide in order to subscribe to our services; and
  • Any other information relating to you which you may provide to us.

The information we collect from customers helps us personalise and continually improve your experience on the Website to make it unique and offer our services to you. We use the information to deliver the services, process payments, communicate with you about our offerings, update our records and generally maintain your accounts with us, display content such as customer reviews and recommend merchandise and services that might be of interest to you. We also use this information to improve the Website, prevent or detect fraud or abuses of and/or from the Website and enable third parties to carry out technical, logistical or other functions on our behalf.

If you have given us your express consent, we may process your personal data for additional purposes. You may withdraw your consent at any time by communicating this to the Data Officer. Additional purposes for which we may process your personal data may include:

  • Carrying out market research, statistical analysis and customer profiling in relation to the Website and the services offered by us; 
  • Sending you newsletters, mail, e-mails, features, promotional material, notices of new publications, surveys and other updates, information or offers. You may, at any time, opt out of receiving such communication by communicating this to the Data Officer.

Here are the main information we gather via the Website:

  1. Information you give us: we receive and store any information you enter on the Website or give us in any other way. You can choose not to provide certain information but then you might not be able to take full advantage of many of our features and enjoy a unique experience on the Website. We use the information that you provide for such purposes as responding to your requests, customising future visits to the Website, improving our offerings and communicating with you.
  2. Automatic information: we receive and store certain types of information whenever you interact with us. For example, like many websites, we use “cookies” and we obtain certain type of information when your web browser accesses the Website or advertisements and other content served by or on behalf of FireFinch on other websites.  By accessing the Website and using our services, you consent to the use of “cookies” as provided for in our Cookie Policy which appears on the Website. 
  3. E-mail communications: to help us make e-mails more useful and interesting, we often receive a confirmation when you open an e-mail from us if your computer supports such capabilities. We also compare our customer list to lists received from other companies in an effort to avoid sending unnecessary messages to our customers.
  4. Information from other sources: we might receive information about you from other sources and add it to our account information.

5. DOES FIREFINCH SHARE THE INFORMATION IT RECEIVES?

Information about our customers is an important part of our business.  We do not sell any of your information and only share such information on the terms as described in this Privacy Policy..  Any sharing of information will only be done in terms of any applicable legislation including the Data Protection Act 2017 and the GDPR.

There may be circumstances where your personal information needs to be disclosed by reason of our legal obligations to do so or if it is required to protect our rights and/or comply with a court order and/or legal process served on us. We may also share personal information with third parties to prevent fraud, for criminal investigations or to ensure the security of our network and services.

6. DATA PROTECTION PRINCIPLES

FireFinch undertakes to process any personal data received by it in accordance with this Privacy Policy and both the Data Protection Act 2017 and the GDPR.  Accordingly, any personal information received from you shall be:

  • Processed lawfully, fairly and in a transparent manner;
  • Collected only for the purposes set out herein;
  • Processed only in a manner that is compatible with the purpose for which it is collected; and
  • Collected only if it is adequate and relevant, which collection shall be limited to what is necessary in relation to the purposes for which the information is processed.

You undertake to ensure that any personal information provided to us is accurate and, where necessary, kept up to date.  You further undertake to ensure that personal information provided to us which changes, is inaccurate, is erased and/or rectified without delay.

The personal information provided by you to us and kept by us, will only be kept for as long as is necessary for the purposes for which the information is collected.  Such information may be stored for longer periods for purposes of archiving, public interest or for statistical purposes.

All personal information will be processed in a manner which ensures appropriate security of the information provided which will include the protection against unauthorised, unlawful processing and against accidental loss, destruction or damage.

7. TOOLS WHICH WE USE

At present, in order to provide the content and offer the services on the Website as well as to process your personal information we use the following tools:

Google Analytics - Website Analytics

Google Marketing Suite - Google Marketing Tools

Facebook Analytics - Facebook and Instagram Campaign Management and Campaign Performance 

HotJar - Website Analytics and Feedback Tools

Vimeo - Video Streaming and Hosting

New Relic - Website Uptime and Incident monitoring

Paypal - Payment Gateway

8. HOW SECURE IS PERSONAL INFORMATION?

We work to protect the security of your information on our servers and during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input on the Website.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer. 

Given the global nature of our business, we may need to transfer your information to countries outside Mauritius in order to provide our services to you. You will be informed should your personal data need to be transferred overseas and we will take appropriate safeguards in order to ensure the personal data being transferred.

9. WHAT ABOUT THIRD-PARTY ADVERTISERS AND LINKS TO OTHER WEBSITES?

The Website may include third party advertising and links to other websites. For more information about third party advertising on the Website, including personalised or interest-based ads, please read our Internet Advertising section in the Cookie Policy appearing on the Website.

10. WHAT INFORMATION CAN I ACCESS?

Without prejudice to any rights conferred to you in terms of any relevant legislation, , FireFinch gives you access to a broad range of information about your account and your interactions with the Website for the purpose of viewing and, in certain cases, updating that information.

In addition to your rights under the Act, we will provide you, upon request, with a copy of your personal data and we will correct any errors identified by you. To obtain a copy of your information, you should write to the Data Officer at the address specified above or request the information on-line by sending such request to the Data Officer’s e.mail address as set out above.

Except as set forth above, we will not use your data for any automated decision making or any profiling and you have the right to restrict our processing of your personal data as well as the right to lodge a complaint with the Data Protection Commissioner regarding the processing of your personal data. We will not send you marketing materials without your express consent and will also comply with your request to stop sending any such further communications.

11. WHAT CHOICES DO I HAVE?

As discussed above, you can always choose not to provide information, even though it might be needed to make a purchase or to take advantage of specific features on the Website.

If you don't want to receive e-mail or other mail from us, please adjust the required settings. (If you do not want to receive the Terms and Conditions of Use and other legal notices from us, such as this Privacy Policy, those notices will still govern your use of the Website and orders placed with us, and it is your responsibility to review them for changes on the Website for changes.)

The Help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the Website of its manufacturer. 

However, because cookies allow you to take advantage of some of The Website’s essential features, we recommend that you leave them turned on. 

12. REGULATORY BODIES

The Website is compliant with the Data Protection Act 2017 and the GDPR.  

13. CONDITIONS OF USE, NOTICES & REVISIONS

We will hold your personal data no longer than is necessary for the purposes for which the personal data are processed.

We will delete your personal data when it is no longer reasonably required or should you withdraw your consent (where applicable), provided that we are not legally required or otherwise permitted to continue to hold such data. We may retain your personal data for an additional period to the extent deletion would require us to overwrite our automated disaster recovery backup systems or to the extent we deem it necessary.

Our business changes constantly and this Privacy Policy together with the Terms and Conditions of Use may also change. You are advised to regularly check The Website for our updates policies. 

Unless stated otherwise, this Privacy Policy applies to all information that we have about you and your account. We stand by the promises we make and will never materially change our policies and practices to make them less protective of customer information collected in the past. 

14. SECURITY

FireFinch will ensure that personal data is stored securely using modern software that is kept up to date.  Access to personal data shall be limited to personnel who need access and we will avoid unauthorised sharing of information.  When we delete any personal information this will be done so that such information is irrecoverable.

In the event of a breach of security leading to the accidental or unlawful, destruction, loss, alteration, unauthorised disclosure of, or access to, your personal information, we shall promptly assess the risk which will be communicated with you and shall deal with any problems arising immediately.

15. COOKIES

You are also bound by our cookie and internet advertising policies which are contained in a separate document.

You may refuse to provide personal information to us or disenable cookies in your browser.  If you do, or if you request your personal information to be deleted some/all of our features and services may not be available or function properly as a result.