Last Updated: December 31, 2019
Account Information and Personal Information
Personal Information from Other Sources
When you use Habit services, notably those available on the website, Habit, who is responsible for handling data, may collect and process your smartphone data. Habit is committed to adhering to the regulations concerning the privacy and data security of prospects and users of their websites. All data collected through the Habit website is processed in accordance with all local legislation and the terms laid out in the General Data Protection Act (EU regulation 2016/679) or “GDPR”. To ensure the proper application of these regulations, Habit has put in place appropriate internal procedures to raise awareness amongst its employees and ensure the regulations are correctly implemented within the organization.
Data Protection Principles
Habit is committed to ensuring a high level of data protection for its customers, prospects, users of its website, and all other persons whose data it processes. Habit is committed to respecting the regulations that apply to all the data it processes. More specifically, Habit commits in particular to the following principles:
Your personal data is processed lawfully, fairly, and in a transparent manner (lawfulness, fairness and transparency).
Your personal data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (purpose limitation).
Your personal details kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (storage limitation).
Your personal data is accurate, kept up to date, and every reasonable step is taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (accuracy).
Habit has put in place appropriate technical and organizational measures in order to ensure a sufficiently high level of security in relation to the inherent risk involved in data processing, to meet regulatory demands and to protect the rights and the data of the people concerned from the moment the data is collected.
Moreover, Habit contractually requires that its subcontractors (service providers, suppliers, data processors, etc.) implement the same level of data protection.
Finally, Habit is committed to adhering to all other principles related to data protection, and more specifically, pertaining to users’ rights, the duration of time that data is stored, as well as obligations regarding the transfer of personal data.
When you use Habit online services, we receive your data through different channels and more specifically on our websites, whilst you are browsing, when you complete an online form, when you sign up to the newsletter, when you apply for a job position, when you post comments on our social media, when you make contact with Habit or when you send your data to us in any other way.
Data Processing and Legal Grounds
Your personal data is primarily used for market research, creating customer loyalty, activities, sales information, satisfaction surveys, finding new prospects, recruitment, customer service.
In addition to instances where we received consent from you (notably to communicate personalized offers with you), it is necessary for us to collect your data for the aforementioned purpose:
For legitimate purposes in the interest of Habit (to develop new services and products, find new prospects, improve customer services…).
More specifically, your data will be used:
To provide a seamless browsing experience on our websites,
To ensure that the information, notifications, promotions, and other services we provide are suited to your interests.
We may use the Personal Information and the Account Information to solicit your feedback and to inform you about our products and services.
In an ongoing effort to better understand our users and our products and services, we may analyze the Account Information in aggregate form in order to operate, maintain, manage, and improve the Website and/or our products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.
We may employ other companies and individuals to perform functions on our behalf. Examples may include providing marketing assistance, order fulfillment, billing, and customer service. These other companies will have access to the Personal Information, the Billing Information, and the Account Information only as necessary to perform their functions and to the extent permitted by law.
We will access and use Hosted Data as required to fulfill our contractual obligations under the Terms of Service or subsequent requests for service and/or support by our customers. In doing so, we may outsource to third parties the Services or other services, in whole or in part, from time to time.
Our technical staff may require periodic access to Hosted Data to monitor system performance, test and fix systems, and develop and implement upgrades to systems. Any temporary copies of Hosted Data created as a necessary part of this process are only maintained for periods of time relevant to those purposes.
If we or any of our affiliated companies (or all or substantially all of our assets or the assets of any of our affiliated companies) are acquired, we expect that the Personal Information, the Billing Information, the Account Information, and the Hosted Data would be transferred along with the other business assets.
To the extent permitted by law, we may also disclose the Personal Information, the Billing Information, the Account Information, and the Hosted Data when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing the Information is necessary or advisable, for example, to protect the rights, property, or safety of Habit or others.
Habit is committed to storing your personal data no longer than necessary for the purpose for which it was processed. Furthermore, Habit stores your personal data in accordance with the retention period imposed by current regulations.
This retention period depends on the purpose for which the data is being processed by Habit and takes into account regulations which impose a specific retention period for certain categories of data.
Personal data collected on the Habit website, may be communicated to authorized Habit personnel in order to carry out the services as outlined above.
You have the right to view, change, delete, or contest any data pertaining to you, as well as to limit, withdraw and refuse the transmission of your personal data.
Moreover, any person under the age of 16 at the time the personal data was collected may request that the data be deleted at the earliest opportunity.
Requests to exercise this right must be addressed to:
200 Broadway, Floor 3,
New York, NY 10038
Please provide details including your full name and e-mail address in order for us to be able to identify you, as well as any other relevant information to confirm your identity. When required by law, personal data will only be used for online marketing once your express consent has been obtained. If you no longer wish to receive the Habit newsletter by e-mail, you can use the unsubscribe link located at the bottom of each message.
In a continued effort to improve the services offered on the website and meet customer expectations, Habit may use “cookies.” These are text files used to identify customers’ devices when accessing Habit services.
The storage of cookies or tracers on your device (desktop computer, tablet, smartphone, etc.) allows Habit to gather information and personal data. Depending on the settings on your device, cookies permit the following:
Cookies enable you to use the major features on the Habit website.
They help us improve our website and detect any bugs you may encounter.
They enable us to remember your choices and preferences and personalize your user interface.
They allow us to gather statistics in order to manage traffic to the website and the use of different sections of the Habit website (visited pages, navigation habits of the user) which allow us to improve the user experience on the website and the services we offer you.
They enable us to track the effectiveness of our marketing campaigns by counting and analyzing the number of sales and clicks associated with our marketing investments.
They allow us to share information with other websites in order to display advertising content that is interesting and useful to you.
They enable us to share information on social media.
At any time, you can change your browser settings to manage these cookies.
Personal Data Concerning Minors
Habit does not gather or process personal data of minors under the age of 16 without prior consent from his or her parents or legal guardian.
If personal data concerning children are gathered via the Habit website, mobile site or mobile apps, their parents or legal guardian have the right to refuse by writing to the address stated at the bottom of this page.
Furthermore, as stated above, any child under the age of 16 at the time the data was collected, may request his or her data to be erased at the earliest opportunity.
Links to Other Websites
Several pages on the Habit website contain links to access the websites of other companies. We recommend that you read the data privacy policies of these non-Habit websites, as these terms may vary from those on the Habit website. Habit is not responsible for the use of your personal data on these external websites.
In order to use the Habit’s application programmable interface (“Habit Insurance API”), you agree to comply with all of the following guidelines (“Guidelines”).
1. The Habit Insurance API collects information from your app such as precise location using GPS, wireless networks, cell towers, and Wi-Fi access points. You must ensure that your application complies with all of Google Play’s developer requirements and Apple’s App Store requirements (collectively, the “Requirements”) including obtaining appropriate consent to the collection of location information.
2. Customers that use the Habit Insurance API must keep the following guidelines in mind:
Refresh user data frequently. Your app may cache or store data — but please refresh any data that you store at reasonable intervals.
Please don’t abuse the API. Use of our API is free. We only ask that you not abuse it by making excessive calls through your apps. It goes without saying that we also don’t permit using our APIs to enable spam, phishing, or other types of fraud or malware.
For any further questions related to this policy or the way in which Habit processes your personal data, please contact us at the following e-mail address:
You can also reach us in our addresses:
200 Broadway, Floor 3,
New York, NY 10038