Privacy Policy and Cookies

Last revision: November 2, 2020

By using the Platform, Product or Service, you are deemed to agree to our Terms and this Privacy Policy for the collection and processing of your personal data and cookies.

This Privacy Policy sets out our use of all information we collect in connection with your use of the Platform. The site is operated by Juliet Rose, d.o.o. Celovška cesta 128, 1000 Ljubljana (“Juliet Rose”). To understand the terminology and other terminology, please review the General Terms of Use of the Platform and other Terms first. By using the Platform, you agree to understand and have read all the Terms, which represents all documents that in any way express the use of the Platform, Services and Products on the Platform.


Data protection is a matter of trust and your trust is important to us. We respect your private and personal sphere.

In order to make you feel safe when visiting our website, we strictly follow the legal provisions when processing your personal data and we want to inform you about our collection and use of data here.


Personal data means all information about the User to whom the personal data relate, on the basis of which the identity of the individual to whom it relates can be determined. This includes names, IP addresses, etc. This does not include statistics that we collect, for example, when you visit our website or when you use our services and cannot be linked to.


When you register on the Platform, you have a User account to use the Platform, and access is password protected. You can view and change information such as orders or Conversation and Subscription information in your account. You agree to treat personal access information confidentially and not to make it available to unauthorized third parties. We do not accept responsibility for incorrectly used passwords.


Data protection is very important to us, so we comply with data protection legislation.
We collect, store and process your data for the entire processing of all purchases, for our services, technical administration and our own marketing purposes. Your personal data will only be passed on to third parties if this is necessary for the processing of contracts or billing or if you have given your prior consent and only to the extent necessary for third parties. If there are exceptions, they will be mentioned in this text below.
This information may only be used by the Contractors in the framework of the implementation of the Platform Discussions in accordance with the Cooperation Agreement signed with Juliet Rose. Any other use or transfer of information is not permitted.
Your personal data will be deleted when you exercise your right to deletion, if the data is no longer necessary to fulfil the purpose for which it was stored, and if the deletion does not violate any applicable law or the deletion would be inadmissible.
We may collect and process the following information about you:
·       Registration: The information (such as your name, date of birth, email address, postal address, telephone number, profile picture and NHS number) that you provide by filling in the forms on the Platform, even if you register as a platform user, subscribe upload or send any material through the Platform or request information from us on any of our services or the services of a third party hosting the Platform;
·       • Account login: in connection with the account login process, your password and login details;
·       • Payments and purchases: details of all transactions made through the platform when logged into your account will be recorded;
·       • IP address and URL: your activity on our site (automatically collected) when you use any website or platform and log in to any site you leave.
·       • When you contact us: the messages you send us, for example, to report a problem or send inquiries, concerns or comments about the platform or its content;
·       • Research and research: information from research that can be conducted from time to time on the platform for research purposes, if you choose to do so;
·       • Use of the platform: details of your visits to the platform, the resources you access and any data you download;
·       • You are not required to provide such information. However, if you wish to retain the requested information, we may not be able to provide some services to you.
We will use the information you provide to:
• enable us to provide you with the services and information offered by the Platform and that you request from us, for example for the quality implementation of the Conversation. This may include sharing your information with one of our Providers, and sharing limited information with call center operators;
• provide and manage your access to the Platform and your account with us;
• we check the execution of financial transactions related to online payments;
• verify your identity and parental custody relationship with any dependent child;
• respond to your message;
• We send you emails, such as newsletters you may have subscribed to (you can unsubscribe or unsubscribe at any time by following our unsubscribe instructions).
For these purposes, we must use your personal information to provide our Services and Products on the Platform and perform activities in accordance with the Terms. In some cases, data collection may be a legal or contractual requirement, so we will be limited to services that we can provide to you without your consent to use such data.
The above personal data is collected, stored and used for:
• revise the transfer of data from the Platform to improve our service;
• learning and improving the layouts and / or content of the Platform and adapting them better to Users and Contractors;
• identification of Platform Users;
• we conduct research on the demographic data of our Users; in
• We customize the information we send you based on the information you provide through the Platform.
We have a legitimate interest in using your personal information for these purposes, in order to continually improve our Platform and our Services and Products, and to ensure that we only send you information that will be useful or relevant to you.
Finally, we use your personal information to:
• send you information that we deem useful or requested from us, including information about our Services, products and Platform, or about carefully selected third parties (for example, information about appropriate guidance, guidance and counselling; and care of third parties), provided that you have consented to call for these purposes;
• With your consent, allow carefully selected third parties to send you directly information that you may find useful about their products and services.
You may order us not to inform you about our Providers, Products, Services, Platform or to share your information with third parties so that they may send you information about their products and services. Do this in your profile on the platform or send us a message at You may also exercise this right at any time by contacting us using the contact information at the end of this Privacy Policy.


For the purpose of using the HRV product, we will send you an e-mail form about our activities and a questionnaire about our general lifestyle, which includes exercise, diet and psychological stability. If you do not wish to complete this form or questionnaire, we will ensure that you use the Services in a truncated manner. Nevertheless, you can take a measurement with the Recorder.

If you allow the collection of your data, only a specific Contractor will have access to this data. The Contractor is fully responsible for the storage and security of your data. Keep the questionnaire, as the Contractors have instructions on how to delete data from their local computers that were created during the use of the Product and the Conversation Service in order to highly protect your data. How the Contractors handle, delete and store your data Juliet Rose has no authority or agreement.

In addition, your data is stored on the Autonom Health Portal, which is Juliet Rose’s Business Partner. The data is stored in accordance with the security system of the Business Partner for 3 years after obtaining the data. The data is obtained in the form of data from the Recorder when you perform the measurement. Based on the Portal, the Contractor obtains data in the form of parameters, which are based and calculated on the basis of algorithms, which are a business secret of the Business Partner. Such data is stored solely on the local computer of the Contractor, which prepares a report and interpretation of your data. Juliet Rose has no access to this information under any circumstances.

In accordance with the use of the Portal, a separate account is created for each user, as a result of which no one other than the Contractor has access to your data. Read more about how to create an account on the Portal in the General Terms and Conditions of the Platform.

If you agree that your data will be used by a group of Contractors who are certified HRV experts who have completed the training organized by Juliet Rose together with the Business Partner, you must sign a Statement on the sharing of personal data for this purpose. If you wish, you can participate in the Interpretation performed by the Contractors once within a period of up to max. 2 hours present. The Privacy Statement states that, if you sign this, Contractors may use an anonymized ID for the purpose of the Interpretation, and is in no way composed of your personal information, but is generated in the form of a number by Juliet Rose.


Information that identifies you: We will only share personally identifiable information in certain limited circumstances, as described below.

Some basic identification information (such as name, date of birth, email, and phone details) can be shared with our out-of-hours call center [managed by an independent provider] when you contact customer service. Call center operators may be outside the European Union, but they are established in the EEA, unless we inform you otherwise.

We may disclose aggregate statistics about platform visitors, users, and sales for the purpose of describing our services to prospective partners, investors, advertisers, sponsors, and other reputable third parties, and for other legitimate purposes. These statistics do not include personal data in any way.

We will not disclose, sell or rent your personal information to a third party unless you first consent to it. If you agree and change your mind later, you can contact us and we will stop any activity of this kind. However, in the event that we are reorganized or sold to a third party, you agree that any personal information we hold about you may be transferred to that reorganized unit or third party.

We may also disclose your personal information if required by law or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the platform or rights, property or personal safety of any person.


When you visit the Platform, we may automatically collect additional information about you, such as the type of Internet browser you use, the website from which you came to the website, and your IP address (a unique address that identifies your computer on the Internet) that it is automatically recognized by our web server. You cannot identify you from this information and it is only used to help provide an effective online service and to collect broad demographic data for sharing.

We use the Hotjar software to better understand the needs of our users and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users ’experience (e.g. how much time they spend on which pages, which links they choose to click on, what users do and what they don’t like, etc.). Enabling us to build and maintain our user feedback service Hotjar uses cookies and other technologies to collect information about the behaviour of our users and their devices (especially the IP address of the device (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our site). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to link them to further information about an individual user.


In addition to processing in the purchase process at Juliet Rose, your data will also be used for advertising purposes. You can send the objection to our contact address by post or e-mail at any time.

2.7.1 News
We only send news when you sign up for it or if you accept our general terms and conditions. If you no longer wish to receive news, you can unsubscribe from the news at any time by unsubscribing from each newsletter. You can send a complaint at any time to our contact address published on the website.

2.7.2 Individual advertising
In order to continuously improve and adapt our services, we use the information you provide from the Platform, the use of our products and services. For this purpose, we use e-mail, information about computers and Internet connections, operating systems or the time of your visit to the Platform.
As far as technically possible, the data is used in pseudo-anonymised form. By analyzing this data, we can continually improve our range of services. For example, this improvement allows us to make our advertising offer more targeted and to present only information that is relevant to your interest.
By using the Platform, you agree that Juliet Rose uses your data stored about your customer account, as well as pseudo-anonymized usage data, to present you with custom advertising and / or special offers and services.
If you do not wish to receive personalized advertising, you can unsubscribe at any time. You can send the cancellation at any time to our contact form on the website, by post or by e-mail.

2.7.3 Sweepstakes, market research and opinions
In the case of competitions or registration for a competition organized by Juliet Rose, your data will be stored for the purpose of informing the winners. For details, see the conditions for participation in each competition. In the case of market research and public opinion, your data will only be stored in an anonymised form for statistical analysis. Under no circumstances will the information obtained be passed on to third parties or only with your permission.
By using the Platform, you agree that Juliet Rose processes and uses your personal information from competitions, market research and public opinion polls for its own purposes.
You can object to this at any time. You can send the cancellation at any time to our contact form on the website, by mail or e-mail.


Acceptance of cookies is not a condition for using the Platform. However, we would like to point out that if you decline cookies, some Services and Products may not work as necessary for optimal performance and user experience.

2.8.1 What are cookies?
Cookies are small text files that are stored on your device when you use our services and website. For more information, visit the external information pages or

2.8.2 Which cookies does Juliet Rose use?
Juliet Rose uses various types of cookies of all kinds within the Platform. We also use comparable technologies such as Local Shared Objects. Most of the cookies used are so-called session cookies, which are deleted after the end of the browser session.
Other cookies are used to remember you when you return to the Platform, and will last longer before they are deleted.
We use cookies to:
• remember that you have used the site before (this means that we can identify the number of unique visitors we receive and it allows us to have enough capacity for the number of users we get);
• allow you to navigate the site faster and easier;
• do not forget the registration session so that you can move from one page to another within the Platform;
• save your wishes;
• customize the layout and / or content elements of the Platform for you; in
• We collect statistics on how you use the Platform so that we can improve it.
All cookies used on our Platform are set by us.
Most computer and some mobile web browsers automatically accept cookies, but if you wish, you can change your browser to prevent this or to notify you each time you set a cookie. You can also learn more about cookies at, which includes additional useful information about cookies and how to block cookies using different types of browsers. Note, however, that by blocking or deleting cookies, you may not be able to make optimal use of the Platform.
No personal information is stored in cookies stored by Juliet Rose.
Our cookies will be used for:
• Essential session management
• creating a special login session for the Platform User so that the Platform remembers that the User is logged in and that his requests to the parties are delivered in an efficient, secure and consistent manner;
• recognizing when a Platform visitor visited before allowing us to identify the number of unique visitors we receive on the Platform and ensuring that we have enough capacity for the number of users we receive;
• recognizing when the Platform User is registered;
• We may also record information from your computer, including the existence of cookies, your IP address and information about your browser program, so that we can diagnose problems, manage and monitor your use of our Platform, Services and Products.
• Functionality to customize elements of the promotional layout and / or content of the website page, for example by storing country code and providing users with content appropriate to their country. These essential session management and functionality cookies are required so that we can provide you with our platform.
• The ability to measure and measure the collection of statistics on how our Users use the Platform so that we can improve the Platform and learn which parts are most popular with Users.
We use any personal information collected through cookies for greater performance and measurement so that we can continually improve our platform and our services.

2.8.3 Foreign cookies (third party cookies)
The Juliet Rose platform is also used by various partners for advertising and analysis. These partners store so-called third-party cookies. Although Juliet Rose attaches great importance to complying with data protection rules when choosing partners, this cannot be guaranteed, as the data it contains are not identified or processed.

2.8.4 Behavioral targeting
Behavioral targeted advertising is advertising that is tailored to the interests of a particular person. These interests arise from profiles that are created over a period of time by assessing User behavior (multiple site visits, interactions, keywords, etc.). The technology used for this, commonly referred to as “tracking,” uses data from a user’s browser or device. These are mainly so-called “tracking cookies”, but other, similar technologies can also be used. The ad network operator stores a tracking cookie on the end device of the data subject when he or she first accesses the website displaying the ad from the network. A cookie is tied to a specific domain and contains information that can be read later from that domain. Based on this information, we can identify the User when he revisits the same site or another site that also has a partnership with that ad network, and then we can create a profile. These cookies are not provided by Juliet Rose but by third parties, hence they are also called “third party cookies”. At you will find detailed explanations of the various options available to you and the options for unsubscribing from online advertising based on usage.

2.8.2 Re-targeting
We use re-targeting for our Platform. This technology allows us to re-offer our Platform and products or services on partner sites. The technology is implemented on the basis of cookie technology, whereby personal data is not stored.
By using this Platform, you agree that so-called cookies are used and that we collect, store and use information about the use of the Platform. You also agree that your data is stored in cookies after the end of the browser session and that, for example, you can access it again the next time you visit the Platform. You can revoke this consent at any time by refusing to accept cookies in your browser settings.

2.8.3 How can I prevent the storage of cookies?
You can disable the storage of cookies in the web browser you are using. Because browsers are constantly evolving, Juliet Rose finds it difficult to provide accurate instructions. Please use the help of your web browser or visit an external website

2.8.4 Log files
When you visit the Platform, the browser automatically sends usage data and saves it in so-called server log files. These log files store the date, time, access page name, IP address, reference URL, amount of data downloaded, and browser data used (product and version). Server log files are analyzed to troubleshoot and improve server performance.
targeted advertising is advertising that is tailored to the interests of a particular person. These interests arise from profiles that are created over a period of time by assessing User behavior (multiple site visits, interactions, keywords, etc.). The technology used for this, commonly referred to as “tracking,” uses data from a user’s browser or device. These are mainly so-called “tracking cookies”, but other, similar technologies can also be used. The ad network operator stores a tracking cookie on the end device of the data subject when he or she first accesses the website displaying the ad from the network. A cookie is tied to a specific domain and contains information that can be read later from that domain. Based on this information, we can identify the User when he visits the same website or another website again.


Juliet Rose attaches great importance to adhering to data protection guidelines when choosing web analytics tools and external services such as social plug-ins. Because these tools and services partially store personal information and Juliet Rose can neither view nor verify it, it refers to the so-called exclusion process. With this method, you can request the deletion of your data from the appropriate tool and service provider. A list of mainly used tools and services can be found below.

2.9.1 Google Analytics
Google Analytics is a business service:
Google Inc., 1600 Amphitheater Parkway, CA 94043, USA
By using this website, you represent that you consent to the processing of data collected about you by Google.
You can disable the storage of cookies in the web browser you are using. Use the help of your web browser or visit an external website
To disable Google Analytics, you can download and install the browser plug-in provided by Google: Learn more about Google Analytics and data protection at

2.9.2 Facebook
We use plug-ins from the social network
Data protection statement:

2.9.3 Twitter
We use plug-ins from the social network Twitter.
Privacy Policy:

2.9.4 Youtube
We use plugins from YouTube.
Privacy Policy:



The Platform may from time to time contain links to external websites that are affiliated with us or run by independent third parties. Please note that this Privacy and Cookie Policy applies only to the personal information we collect on this Platform, and we cannot be held responsible for the personal information that third parties may collect, store and use through their website, and we are not responsible for privacy policies or the content of such websites. Always read the privacy policy of every website you visit carefully.


The security of all personal data related to our Users is very important to us. We have security measures in place to protect against the loss, misuse and alteration of personal data under our control. We regularly review and improve our security and privacy policies, and only authorized personnel have access to personal information. While we cannot guarantee or guarantee that information will never be lost, misused or altered, we do our best to prevent it.
You should keep in mind that sending information over the Internet is never completely secure, and although we take appropriate technical and organizational measures to protect the personal data you provide for use, we cannot ensure the security of data sent via the platform while in transit via internet and such broadcasting at your own risk.
When you end a user session, you should always close your browser to ensure that others do not access your personal information, especially if you are using a shared computer or a computer in a public place.
To improve your security, we use SSL (Secure Socket Layer) to transfer data to our services and to the website.


For the purposes of processing your personal data, we are the data controller as set out in the EU General Data Protection Regulation 2016 (GDPR). We are committed to protecting your privacy both online and in the real world. We appreciate that you do not want the personal information you provide to us to be shared universally, and here we explain how we collect the information; what we do with them and what control you have over our processing of your data. We may change or update this Privacy Policy from time to time as set forth in the Terms and Conditions.
In accordance with the GDPR, we will ensure that your personal data is processed legally, fairly and transparently without adversely affecting your rights. We will only process your personal data if at least one of the following grounds applies:
• you have consented to the processing of your personal data for one or more specific purposes;
• processing is necessary to perform the contract to which you are a party or to take action at your request prior to the conclusion of the contract;
• processing is required to fulfill a legal obligation;
• processing is necessary to protect the vital interests of you or another individual;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority conferred on the controller; and / or
• processing is necessary for the purposes of legitimate interests pursued by us or a third party, except where such interests prevail over the fundamental rights and freedoms of the data subject requiring the protection of personal data, in particular where the data subject relating to personal data, children.
Unless otherwise specified, any processing of personal data by us or one of our authorized subcontractors, including specialists or experts or operators of our call center, in connection with the provision of our services to a customer, authorized user of our platform (or their maintained) persons), processes on the basis of our contractual relationship (or in anticipation of the contractual relationship). When we do not have or do not have a contractual relationship with the data subject (for example, when processing personal data relating to a child or other dependent member), we will generally process them on the basis of legitimate interests.
In addition, where the personal data to be processed are ‘specific data’ that should receive additional safeguards, such as health information, we will only process them if there is a valid specific condition for processing (as set out in Article 9 GDPR).
If we process personal data for marketing purposes, we will only do so if we have the explicit consent of the data subject.


You have the legal right to access the personal information we hold about you. You also have the right to require us to: update and correct any outdated information or errors in this information free of charge; you object to our use of your personal information for certain purposes; delete your personal data and transfer to you or (if technically feasible) a copy of the personal data about you that they have provided to us.
When we process your personal information with your consent, you may revoke your consent to the use of your personal information as set forth above at any time by contacting Juliet Rose using the details below and subject to the legal and legal requirements for Juliet Rose. If you do not wish to retain certain information about your history and consultation notes, you may revoke your consent to the use of any of your personal information, including data sharing, at any time, using the settings in Juliet Rose’s profile or by email info @ juliet-rose .com.
You have the right to lodge a complaint with our relevant supervisory authority at any time regarding our handling of your personal data.
In the event that Juliet Rose uses personal data for automated decision-making purposes and these decisions have legal or similarly significant effect, you have the right to challenge this in accordance with the GDPR and request human intervention and express your own views and obtain reasons for Juliet Rose’s decision.
The right described above does not apply in the following circumstances:
• A decision is required to enter into or perform a contract between Juliet Rose and you;
• The decision is allowed by law; but
• You have given your explicit consent.
When Juliet Rose uses your personal information for profiling purposes, the following applies:
• Clear information explaining profiling, including its meaning and likely consequences, will be provided;
• Appropriate mathematical or statistical procedures will be used;
• The technical and organizational measures necessary to reduce the risk of errors and to facilitate the elimination of errors are implemented; in
• All personal data processed for profiling purposes are protected to prevent discriminatory effects of profiling.


Any questions, concerns or comments regarding this Privacy Policy or any requests regarding your personal information should be emailed to: or mail us at: Juliet Rose, d.o.o., Celovška cesta 128. 1000 Slovenia.