Privacy Policy

Effective date: July 2, 2026

Last updated: October 21, 2026

1. Who We Are and How to Contact Us

Healthy Way ("we," "our," or "us") is an organization providing informational services. We provide clients from the United States, the European Union, and other countries with information about healthcare options abroad, including in Ukraine and Central Europe.

Data Controller Contact Information:

  • Organization: Healthy Way
  • Website: https://healthyway.us
  • Email: privacy@healthyway.us

We respond to all privacy-related inquiries within 30 calendar days.

2. Scope of This Policy

This Privacy Policy applies to:

  • all visitors to our website located at https://healthyway.us;
  • all persons who submit contact or inquiry forms on our website;
  • all persons who use our informational services.

This Policy does not apply to third-party websites, healthcare providers, or payment processors. Please review their respective privacy policies separately.

3. What Data We Collect

3.1 Data You Provide Directly

When you fill out a contact or inquiry form on our website, we collect:

  • First and last name
  • Email address
  • Phone number (including country code)
  • Time zone and preferred time for contact
  • General description of your inquiry (optional)

3.2 Data Collected Automatically

When you visit our website, we automatically collect:

  • IP address
  • Browser type and version
  • Date and time of visit
  • Pages viewed
  • Referring URL
  • Cookie and similar tracking data (see Section 7)

3.3 What We DO NOT Collect or Store

Important: Healthy Way provides informational services only. We do not facilitate, arrange, or coordinate any medical procedures or treatments. Any decisions regarding healthcare providers, treatments, or travel are made independently by you. We do not receive or store any medical or health-related documentation.

We process your personal data only for the following purposes and on the following legal bases:

PurposeLegal Basis (GDPR Art. 6)
Responding to your inquiry and providing requested informationConsent (Art. 6(1)(a))
Sending information about healthcare options upon your requestConsent (Art. 6(1)(a))
Sending informational updates upon your requestConsent (Art. 6(1)(a))
Ensuring security and preventing fraudLegitimate interest (Art. 6(1)(f))
Improving website performance and user experienceLegitimate interest (Art. 6(1)(f))
Compliance with legal obligationsLegal obligation (Art. 6(1)(c))

We do not use automated decision-making or profiling.

5. How We Share Your Data

5.1 Categories of Recipients

We may share your personal data with the following categories of third parties:

  • Healthcare Information Providers — if you request information about specific healthcare providers, we may share your name and contact details solely so they may respond to your inquiry. Any further relationship, including medical consultations, is established directly between you and the healthcare provider.
  • Technical Service Providers — email services, CRM systems, and website analytics tools, only to the extent necessary to operate our informational services.
  • Government and Regulatory Authorities — only when required by applicable law in Ukraine, the EU, or the United States.

5.2 What We Do Not Do

We do not sell, rent, exchange, or otherwise transfer your personal data to any third parties for commercial purposes without your prior written consent.

5.3 International Transfers

Our informational services involve international data transfers. When transferring personal data outside the European Economic Area (EEA), we ensure an adequate level of protection through Standard Contractual Clauses (SCCs) approved by the European Commission, or other legally recognized mechanisms.

6. Your Rights

6.1 Rights Under GDPR (EU/EEA Residents)

If you are a resident of the European Union or European Economic Area, you have the following rights under the General Data Protection Regulation (EU) 2016/679:

  • Right of Access (Art. 15) — obtain confirmation whether we process your data and receive a copy thereof;
  • Right to Rectification (Art. 16) — request correction of inaccurate data;
  • Right to Erasure / Right to be Forgotten (Art. 17) — request deletion of your data where no longer necessary;
  • Right to Restriction of Processing (Art. 18) — request suspension of processing in certain circumstances;
  • Right to Data Portability (Art. 20) — receive your data in a structured, machine-readable format;
  • Right to Object (Art. 21) — object to processing based on legitimate interest;
  • Right to Withdraw Consent (Art. 7(3)) — withdraw consent at any time without affecting the lawfulness of prior processing.

You also have the right to lodge a complaint with your national data protection supervisory authority (e.g., your country's Data Protection Authority).

6.2 Rights Under CCPA/CPRA (California Residents)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

  • Right to Know — the categories and specific pieces of personal information we collect, use, disclose, and sell;
  • Right to Delete — request deletion of your personal information, subject to certain exceptions;
  • Right to Correct — request correction of inaccurate personal information;
  • Right to Opt-Out of Sale or Sharing — we do not sell or share personal information for cross-context behavioral advertising;
  • Right to Limit Use of Sensitive Personal Information — we do not use sensitive personal information beyond what is necessary to provide our informational services;
  • Right to Non-Discrimination — we will not discriminate against you for exercising your privacy rights.

To exercise any California rights, contact us at privacy@healthyway.us or submit a verifiable consumer request. We will respond within 45 days.

6.3 How to Exercise Your Rights

Submit your request to: privacy@healthyway.us

We will respond within 30 calendar days (GDPR) or 45 calendar days (CCPA). We may request identity verification before processing your request.

7. Cookies

7.1 What Are Cookies

Cookies are small text files stored on your device when you visit our website. They help us understand how visitors use our site and improve user experience.

7.2 Types of Cookies We Use

TypePurposeConsent Required
Strictly NecessaryBasic website functionalityNo
AnalyticalUnderstanding visitor behaviour and improving contentYes (EU); Opt-out (CA)
FunctionalRemembering your preferences and settingsYes (EU)

You may disable cookies through your browser settings. Note that disabling certain cookies may limit functionality of the website. EU residents will be asked to provide cookie consent via a banner upon their first visit.

8. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Policy:

Category of DataRetention Period
Contact form inquiries12 months from last contact
Correspondence and inquiry records5 years
Technical data (IP, cookies)6 months
Financial transaction records7 years (US tax law) / 5 years (Ukraine)

Upon expiry of retention periods, data is securely deleted or anonymized.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure.

These measures include:

  • Encryption of data in transit (SSL/TLS)
  • Access controls and authentication for staff
  • Regular review of data processing activities
  • Staff confidentiality obligations

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify you and, where required, the relevant supervisory authority within the timeframes prescribed by applicable law (72 hours under GDPR).

10. Children's Privacy

Our website and services are not directed at persons under the age of 18. We do not knowingly collect personal data from minors. If you become aware that a child has provided us with personal information without parental consent, please contact us at privacy@healthyway.us and we will promptly delete such data.

11. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. In the event of material changes, we will notify you by email or by posting a prominent notice on our website no less than 30 days before the changes take effect.

The current version of this Policy is always available at: Privacy Policy

The date of the most recent revision is indicated at the top of this document.

12. Contact Information

For all privacy-related inquiries, requests to exercise your rights, or complaints:

ContactDetails
Emailprivacy@healthyway.us
Phone+1 (575) 652-6871
Response Time30 calendar days (GDPR) / 45 calendar days (CCPA)

EU residents also have the right to lodge a complaint with the competent data protection supervisory authority in their country of residence.

US (California) residents may also contact the California Privacy Protection Agency (CPPA).

Appendix: Summary Table — GDPR vs. CCPA

AspectGDPR (EU)CCPA/CPRA (California)
ScopeAny org processing EU residents' dataBusinesses serving California residents
ConsentExplicit opt-in required for most processingOpt-out model (right to opt out of sale)
Response time30 days45 days (extendable by 45 more)
Max penalty€20M or 4% of global turnover$7,500 per intentional violation

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