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Last updated on October 18, 2017

Actywell Digital Limited (“Hera Leto”, “we”, “us” or “our”) understands that privacy is important to you. This Privacy Policy sets out how we will collect and use the personal information that you provide to us through our website located at (the “Website”), our mobile application (the “Hera Leto App”), and our connected device (the “Hera Leto Device”). This Privacy Policy applies solely to the Website, the Hera Leto App, and the Hera Leto Device (collectively, the “Hera Leto Service”), and does not apply to any other site, product or service of Hera Leto, its affiliates or customers.


As discussed further below, the Hera Leto App is designed to work with the Apple HealthKit.  Therefore, your fitness information may be synched with the Apple HealthKit if you select that option.


By accessing or using the Hera Leto Service, you are deemed to accept the terms of this Privacy Policy. If you do not agree to this Privacy Policy, you may not access or otherwise use the Hera Leto Service. We reserve the right, at our discretion, to change, modify, add or remove portions of this Privacy Policy from time to time. Such changes shall be posted on the Website and may be made known to you via email or through the Hera Leto App. We encourage you to periodically review the Website for the latest information on our privacy practices.


The Hera Leto Service, together with all its content, is owned or controlled by Actywell Digital Limited, a company registered in Hong Kong with its registered office at Flat F, 14/F, World Tech Centre, 95 How Ming Street, Kwun Tong, Kowloon, Hong Kong. 

Personally Identifiable Information That We Collect

To provide the Hera Leto Service, we may hold and process certain personal information that you voluntarily submit to us, such as through our contact pages, by e-mail, through social media, by seeking employment with us, by making purchases on the Website, or by some other means. The personally identifiable information that you may provide to us could include your name, address, date of birth, email addresses and/or mobile phone numbers, and financial information such as credit/debit card numbers. 

Non-Personally Identifying or Aggregate Information That We Collect

When you use the Hera Leto Service, we may automatically collect certain non-identifying information about you, such as the type of browser or device operating system you use, the domain name of the website from which you linked to us, the amount of time you spend on the Hera Leto Service, the pages on the Hera Leto Service that you view, and the local time on your mobile device. We may also aggregate information collected from our users (such as the number of users in a particular region or having particular characteristics).

Non-Personally Identifying Fitness Information That We Collect

When you use the Hera Leto Device in conjunction with the Hera Leto App, we may collect certain non-identifying fitness information about you, such as your age, weight, gender, height, motion, calories burned, steps taken, distance traveled, heart rate, and heart rate variability. 

Information Usage

This information will be stored with any additional information you may provide to us, and will be used to provide you with the Hera Leto Service and any other associated services. We may contact you with offers that may interest you and/or to inform you of other products and services.

We will only use your personally identifiable information as described below, unless you specifically consent to another type of use, either at the time such personally identifiable information is collected from you, or through some other form of consent from you or notification to you:


  • We will use personally identifiable information to operate the Hera Leto Service, including providing you with any specific services that you have requested, and offering you the chance to participate in contests, sweepstakes, and promotions.

  • We may use your personally identifiable information to respond to your direct inquires.

  • We will use your personally identifiable information to add you to our mailing lists and to send you emails and newsletters from time to time.  

  • We may permit our vendors and subcontractors to access your personally identifiable information solely in connection with performing services for us. These vendors and subcontractors are not authorized by us to use your personally identifiable information for their own benefit. Authorized uses include processing your credit card information in connection with a purchase you make on the Website, or performing analytics to help us understand our user base and target similar audiences. 

  • We may use your personally identifiable information to match it with other data sources in order to enhance our records, such as appending additional information to your profile.  We also may work with other providers, such as social media platforms, who also possess your personally identifiable information in order to separately or jointly target messaging to you on and off of the Hera Leto Service.

  • We may disclose personally identifiable information as required by law or legal process.

  • We may disclose personally identifiable information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the Hera Leto Service.  

  • We may transfer your personally identifiable information in connection with an expansion, or a reduction of our business, including the sale, merger, or transfer of control of Hera Leto or certain divisions to other parties or in connection with a bankruptcy proceeding.

Non-personally identifying or aggregate information may be shared with any number of parties, provided that such information shall not specifically identify you. 


Non-personally identifying fitness information is gathered from you, and/or made available to you, through the Hera Leto Device and Hera Leto App in order to help you optimize your mind and body performance. As described below, the Hera Leto Device connects to the Hera Leto App over Bluetooth® to track your relaxation, active time and heart fitness.

  • Relaxation: The Hera Leto Service provides options for 10-minute relaxation, while tracking your daily goals and progress. This AI-assisted relaxation program was designed to work with your natural heart rate patterns and train your resilience to mental and physical stress.

  • Active Time: The Hera Leto Service tracks your daily physical activity, such as your calories burned, steps taken, and distance traveled, in order to determine how you personally respond to a range of physical activities.

  • Heart Fitness: The Hera Leto Service tracks your resting heart rate, heart rate variability, and real-time heart rate to provide a well-rounded view of overall fitness and stress across your cardiovascular and nervous systems.

The Hera Leto App is compatible with the Apple HealthKit, so you can transfer your fitness information to a location designed to be centralized and secure that enables you to control the sharing and use of your fitness information. The Hera Leto App will provide you with the option to authorize data porting to the Apple HealthKit. Once your fitness information is synched with the Apple HealthKit, Hera Leto does not control any uses Apple may make of your fitness information. For more information on the Apple HealthKit, please see

Interest Based Advertising

Please note that we may ourselves or through a third-party vendor use non-personally identifiable information in connection with our own or vendor information to display or deliver targeted advertising to you on our Website and to manage our advertising on other websites. Cookies, clickstream data, web beacons, retargeting pixels and other similar technologies may be used to collect information in order to provide personalized advertising. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising, sometimes called “interest based advertising,” utilizes anonymous information and not personally identifiable information. As a result, we and our vendor know your interests, but do not personally identify you in connection with the delivery of that specific ad. We believe that such advertising is helpful because you will see advertisements that are relevant to your interests. However, if you would like to opt-out of these interest-based advertisements, please see the below section entitled “Opt-Out Process.” 


We may store information on your device as a “cookie” or similar type of file (such as clear gifs, web beacons, tags, pixels, etc.) for the purpose of facilitating and enhancing your communication and interaction with the Website. Many websites use cookies for these purposes and to collect general usage and volume statistical information. We use this information internally to help us maintain and enhance the efficiency and usefulness of the Website. We may also use and place cookies on your device from our third-party service providers, such as from an analytics provider to help us manage and analyze usage of the Website.  We also use persistent cookies, which will remain active on your device unless you clear your cache. We set persistent cookies to enable us to track and target the interests of our users in order to enhance the services we provide. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge. If you do not wish to receive cookies or want to restrict them or flush them from your device, you may do so by changing the settings on your device or browser accordingly, in which case you may still use our Website, although some functionality may be impaired. 

Clickstream Data

As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of device and browsing software you use and the address of the website from which you linked to the Website. We may collect and use clickstream data to anonymously determine how much time visitors spend on websites, how visitors navigate through websites, and how we may tailor our Website to better meet consumer needs. This information will be used to improve our Website and the Hera Leto Service. Any collection or use of clickstream data will be anonymous and will not intentionally contain any personally identifiable data.

Security and Data Retention

We have undertaken and will continue to undertake commercially reasonable efforts designed to prevent unauthorized access to user information retained in our servers, however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. Fitness information collected by the Hera Leto Device is encrypted during transmission to the Hera Leto App and then stored locally on your mobile device to minimize the risk of interception by third parties. We retain information collected through the Hera Leto Service for our records and as needed to provide you with services, comply with our legal obligations, resolve disputes, and enforce our agreements. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

Other Sites

As a convenience to you, we may provide links to third-party websites from within the Website. We are not responsible for the privacy practices or content of these third-party websites, and we are not endorsing or promoting such third-party websites by providing a link. When you link away from the Website, you do so at your own risk. We encourage you to read the policies and terms of every website you visit.

Social Networking Services

The Hera Leto Service may integrate with social networking services.  This may include the presence of tags from social media providers on our Website that collect information from you and send it directly to such providers, such as if their registered users are also using the Hera Leto Service.  You understand that we do not control such social networking services and are not liable for the manner in which they operate. While we may provide you with the opportunity to use such social networking services in connection with the Hera Leto Service, we are doing so merely as an accommodation and, like you, are relying upon those third-party social networking services to operate properly and fairly.


You should be aware that any personally identifiable information that you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise may be viewed and used by others. We are unable to control such uses of your personally identifiable information, and by using such services, you assume the risk that any personally identifiable information you provide may be viewed and used by third parties.


Information Relating to Children

The Hera Leto Service is designed for those 13 years of age and older. We do not knowingly collect information from anyone under the age of 13. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

Communications with Hera Leto

By providing your email address to us, you expressly consent to receive emails from us. We may use email to communicate with you, to send information that you have requested, or to send you information about other services that we provide. We will not provide your email address to another party to promote their products or services directly to you without your consent or as otherwise set forth in this Privacy Policy. 


Opt-Out Process

If you receive promotional emails from us, you may unsubscribe through the link typically provided at the bottom of the promotional e-mail.

You may opt-out of or restrict the placement of cookies on your device or remove them from your browser by adjusting your preferences. Please note that cookie-based opt-outs are not effective on many mobile devices, although users of mobile applications can often opt-out of certain mobile ads via their device settings.

In order to use the Hera Leto App, you must opt-in to the collection of your fitness information and its transmission from the Hera Leto Device to the Hera Leto App.

Interest Based Advertising Opt-Out

We may, and may work with third parties to, use non-personally identifiable information to deliver targeted advertisements to you based on your online activities and other information. The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. You can opt-out of targeted advertising from certain providers at


Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. In addition, all cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your computer browser, that opt-out will not be effective for your mobile device. You must separately opt-out on each device.

Do Not Track Signals

Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.

Hong Kong Special Administrative Region

The Hera Leto Service is maintained in the Hong Kong Special Administrative Region.  By using the Hera Leto Service, you freely and specifically grant us your consent to export your personally identifiable information to the HKSAR and to store and use it in the HKSAR as specified in this Privacy Policy. You understand that data stored in the HKSAR may be subject to lawful requests by the courts or law enforcement authorities in the HKSAR.

Questions: If you have any queries about this Privacy Policy, please contact us at

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