Privacy Policy

I. Commitment to Privacy:

Portal2222 Ltd., managing and marketing services under the brand name David Michael, is fully committed to safeguarding the confidentiality, integrity, and security of all personal information collected from clients and users. This Privacy Policy is designed to provide transparency regarding how we collect, use, store, and protect your data in strict compliance with international data protection regulations, including the General Data Protection Regulation (GDPR). To ensure full compliance with GDPR, we conduct regular audits and implement state-of-the-art security protocols, including multi-layered encryption systems.

We employ industry-leading measures, such as encryption, access controls, and regular system audits, to ensure the security of your data. Additionally, we adhere to the principle of data minimization, collecting only the information necessary to provide and enhance our services. This means that we avoid unnecessary data collection and only retain personal information for as long as it is needed to fulfill our service obligations or as required by law.

Our priority is to ensure that your personal information is handled with the utmost care and responsibility, fostering trust and confidence in every interaction you have with our services. Whether you engage with us online, provide data for payments, or request services, you can rely on our unwavering commitment to uphold privacy standards and employ industry best practices to protect your information. We will notify users of significant updates to our security measures.

II. Collection and Use of Information

1. Personal Data:

We collect only the information necessary to provide and enhance our services, adhering to the principle of data minimization.

This data may include:

• Your name, contact details (email address, phone number), and relevant service-related information (e.g., details about your cat, service preferences, or health history).

2. How We Use This Data:

• To deliver requested services: This includes providing energy healing, consultations, and educational resources, tailored to your needs.
• To personalize your experience: We use the data to customize services and make recommendations based on your preferences or the specific needs of your cat, enhancing your experience with us. We retain the data only as long as necessary to provide our services or as required by applicable laws.
• To ensure seamless communication: This includes updates, follow-up support, and communication regarding services you’ve requested. We use this data to respond to queries, address concerns, and facilitate service delivery.

We will not use your data for any purposes beyond the scope of services provided without your explicit consent.

III. Service Notifications:

This data may include:

• Notify you of new services, updates, or alternative health options, including meditations, energy healing sessions, or special offers that may be of interest to you.
• Send reminders or follow-ups related to scheduled sessions or subscriptions to ensure seamless service delivery and customer satisfaction.

You can easily manage your notification preferences through your account settings.

Your Rights:

• You have the right to opt-out of receiving marketing or promotional emails at any time. You can do this by clicking the "unsubscribe" link included in our communications, or by contacting us directly at support@davidmichaelfelineharmony.com.
  You can always contact us to adjust your notification preferences.

IV. Statistical Analysis:

To enhance our website functionality and improve the user experience, we may collect non-personal and anonymized data, such as:

• Website traffic patterns
• User engagement metrics, including time spent on specific pages and click rates

Why We Collect This Data:

• To analyze and optimize website performance, ensuring a smoother and more efficient user experience. Statistical analysis is conducted on a regular basis to continuously improve website performance.
• To better understand user behavior and preferences, allowing us to create more tailored services and relevant content for our users.The data is used solely for the improvement of our services and user experience.

V. Protection of Information:

All collected data is securely stored and protected using industry-standard encryption and access controls to prevent unauthorized access. Any data used for statistical analysis is anonymized to ensure that individual users cannot be identified, safeguarding your privacy at all times. We continuously update our encryption methods to stay ahead of emerging threats and ensure data protection.

We continually update our protection protocols in line with the latest data protection standards.

VI. Data Sharing:

1. No Sale or Leasing of Information:

Portal2222 Ltd. does not sell, lease, or rent your personal information to any third party under any circumstances.

2: Limited Disclosure of Personal Information:

We share data only when necessary to fulfil our contractual obligations or in response to legal requirements. Your personal information will only be disclosed in the following specific and limited circumstances:

a. Legal Compliance:

• To comply with applicable laws, regulations, or legal processes served on Portal2222 Ltd., including requests from regulatory authorities or payment processors.

b. Protection of Rights and Safety:

• To protect and defend the rights, property, or safety of David Michael, Portal2222 Ltd., its employees, clients, or users.

c. Public Safety Emergencies:

• To address urgent circumstances involving threats to public health or safety, as determined in good faith by Portal2222 Ltd.

3. Third-Party Service Providers:

In some cases, we may share limited personal information with trusted third-party service providers to facilitate our operations, such as:

• Payment processing (e.g., PayPal, Stripe)
• Email communication services
• Data storage and management systems

4. Our Commitments to You:

• These third parties are contractually obligated to protect your information and use it solely for the purpose of providing agreed-upon services.
• We ensure all service providers comply with applicable data protection laws, including GDPR.

We only share data with trusted partners and service providers who are obligated to protect your information.

VII. Anonymized Data Sharing:

We may share aggregate and anonymized data with third parties for purposes such as statistical analysis or service improvement. This data is processed in such a way that individual users cannot be identified and is strictly used to enhance our offerings and better understand user needs. The anonymized data is solely used for research and service enhancement.

VIII. User Consent:

If any additional data sharing is required beyond the circumstances outlined above, we will seek your explicit consent before proceeding. This ensures that you are fully informed and in control of how your personal data is shared. Any additional use of your personal data will require your explicit consent.

IX. Data Protection for Minors:

Portal2222 Ltd., operating under the brand name David Michael, strictly adheres to international laws and regulations governing the collection and use of data from minors.

1. Collection and Deletion of Data:

• We do not knowingly collect personal information from individuals under the age of 18.
• If we become aware that data has been submitted by someone believed to be under the age of 18, we will take the following actions:
  a. Immediately delete the information from our databases.
  b. Where required, report the incident to the relevant authorities in accordance with applicable laws.

2. Safeguarding Measures:

• Our websites and services are designed and marketed to adults. Specific measures are in place to prevent the unintentional collection of data from minors, including: a.Age verification prompts where applicable.
  b. Clear disclaimers stating that our services are not intended for use by individuals under 18 years old.

We implement age verification procedures and ensure compliance with international regulations regarding minors' data.

3. Parental Consent:

• In jurisdictions where services may be accessed by minors with parental consent, we require verifiable parental authorization before collecting or processing any personal information related to a minor.

4. Compliance with Laws:

• We comply with the provisions of international laws, including GDPR (Article 8), COPPA (Children’s Online Privacy Protection Act), and other relevant regulations, to ensure the protection of minors' data.

5. Commitment to Transparency:

Age verification measures are implemented to prevent unintentional data collection from minors.

If you suspect that data from a minor has been inadvertently collected, please contact us at support@davidmichaelfelineharmony.com to address the issue promptly.

X. Use of Cookies:

Portal2222 Ltd., which manages and markets services under the David Michael brand, uses cookies with your consent to enhance your online experience. Cookies allow us to personalize content, improve website navigation, and provide a seamless interaction with our services.

1. What Cookies Do:

• Cookies are small text files stored on your device when you visit our website.
• They help us understand user preferences and improve website functionality.
• Cookies cannot run programs or deliver viruses to your device. They are uniquely assigned to you and can only be read by our web server.

2. Types of Cookies Used:

a. Essential Cookies: Required for the website to function properly (e.g., session management, security).

b. Performance Cookies: Collect anonymized data to improve site performance and user experience.

c. Functionality Cookies: Remember your preferences, such as language settings or login details, to enhance usability.

d. Marketing Cookies:Track browsing behavior to deliver tailored advertising or promotional offers.

We use cookies to analyse web traffic and improve the functionality of our services.

3. Your Choice:

• You can choose to accept or decline cookies through your browser settings or cookie consent banners displayed on our website.
• Declining cookies may limit certain features of the website, such as personalized content or seamless navigation.

4. Cookie Management:

• You can review, delete, or block cookies at any time using your browser’s privacy settings.
• For detailed instructions on managing cookies, refer to the help section of your web browser or visit [Your Cookie Management Policy Page, if applicable].

5. Legal Compliance:

• Our use of cookies complies with GDPR, the ePrivacy Directive, and other relevant international data protection laws.
• Cookies are only deployed with your explicit consent, except for essential cookies necessary for the website’s basic functionality.

6. Contact for Concerns:

If you have questions about our use of cookies, please contact us at

support@davidmichaelfelineharmony.com

XI. International Data Transfers:

Portal2222 Ltd. is committed to ensuring that your data is handled securely, regardless of where it is processed or stored. If you provide personally identifiable information, it may be transferred across borders to servers in jurisdictions that may not offer the same level of data protection as your home country.

1. Consent for Data Transfers:

• By using our services and providing your personal information, you explicitly: a. Consent to the collection, transfer, storage, and processing of your data as described in this Privacy Policy. b. Acknowledge that your data may be stored and processed in Estonia, where Portal2222 Ltd. is based, in compliance with Estonian laws and applicable international regulations.

2. Safeguards for Data Protection:

• We ensure that appropriate security measures, such as encryption and restricted access protocols, are in place to protect your data during international transfers.
• Data transfers are conducted in accordance with applicable data protection laws, including GDPR, where relevant.

3. Third-Party Service Providers:

• In cases where data is processed or stored by trusted third-party service providers (e.g., cloud storage or email services), we ensure that these providers comply with rigorous data protection standards and contractual obligations.

4. User Rights and Transparency:

• You have the right to request detailed information about where and how your data is processed or stored.
• If you do not consent to international data transfers, you may choose not to provide your personal information; however, this may limit your ability to access certain services.

5. Commitment to Compliance:

• All data transfers comply with applicable legal frameworks, including GDPR (Chapter V), to ensure the safe and lawful handling of personal information.
• Portal2222 Ltd. regularly reviews its data transfer practices to align with evolving international regulations and best practices.

All international data transfers are handled in accordance with applicable international data protection laws.

XII. Data Security Measures:

Portal2222 Ltd. prioritizes the protection of your personal and financial information through robust security protocols and best practices. We are committed to ensuring that your data is handled securely at all stages.

1. Encryption:

• All personal data transmitted through our website is protected using Secure Sockets Layer (SSL) encryption to prevent interception by unauthorized parties.
• Sensitive data, including login credentials and payment information, is encrypted both in transit and at rest, ensuring confidentiality and integrity.

2. Firewalls:

• Advanced, multi-layered firewall systems are implemented to safeguard against unauthorized access, data breaches, and malicious activities.
• Regular monitoring and updates ensure these firewalls remain effective against emerging threats, maintaining robust protection over time.

3. Secure Financial Transactions:

• All financial transactions are securely processed through trusted and PCI DSS-compliant providers, such as:
  • PayPal – A widely recognized and secure payment platform.
  • PayPal – A widely recognized and secure payment platform.
  • Authorized Bank Wire Transfers – Handled with strict authentication protocols.
• No financial information (e.g., credit card details) is stored directly on our servers, ensuring an added layer of security.

4. Regular Security Audits:

• Portal2222 Ltd. conducts routine security audits and vulnerability assessments to ensure compliance with international data protection standards and best practices.
• Audits help identify potential weaknesses and ensure we continuously enhance our security framework.

5. Access Control:

• Personal data is accessible only to authorized personnel who require access to perform their roles, ensuring strict confidentiality.
• Strict authentication procedures are enforced to prevent unauthorized access to sensitive information, minimizing internal risks.

6. Incident Response:

• A robust incident response plan is in place to address potential security breaches promptly, ensuring minimal impact.
• In the unlikely event of a data breach, affected users will be notified in accordance with applicable laws and regulatory requirements, ensuring full transparency.

7. Commitment to Continuous Improvement:

• Security technologies and policies are reviewed and updated regularly to align with evolving threats and regulatory requirements.
• We remain dedicated to staying ahead of new threats and enhancing our security measures to provide you with the highest level of protection.

We conduct regular security audits to ensure our systems are up-to-date and compliant with current standards.

XIII. Acknowledgment of Risk:

Portal2222 Ltd. is committed to providing the highest level of data security to protect your personal and financial information. However, it is important to acknowledge the following:

1. No System is Completely Immune:

• While we have implemented robust security measures, including encryption, firewalls, and secure transaction protocols, no system can guarantee 100% security against all potential threats or breaches.
• As with any digital service, there are inherent risks associated with data transmission over the internet.

2. Continuous Monitoring and Upgrades:

• Our security systems are monitored 24/7 and are regularly updated to address emerging threats, vulnerabilities, and to align with industry best practices.
• This ongoing vigilance helps us stay ahead of evolving threats and maintain a high standard of protection.

3. User Responsibility:

• Users are responsible for safeguarding their login credentials, ensuring secure access to their devices, and avoiding sharing sensitive information with unauthorized parties.
• We recommend that users implement strong passwords and regularly update them to further enhance security.

Incident Transparency:

• In the unlikely event of a security incident, Portal2222 Ltd. commits to notifying affected users promptly and providing guidance to mitigate any potential risks, in accordance with applicable laws.
• We will provide clear steps to protect your data and minimize any impact on your account or personal information.

By using our services, you acknowledge the inherent risks associated with data transmission over the internet and agree to cooperate with any recommended measures to enhance security on your end. By using our services, you acknowledge and accept the risks inherent to data transmission over the internet.

XIV. Transaction Data:

At Portal2222 Ltd., we prioritize the security and privacy of your financial information. All payment transactions are securely processed through trusted and PCI DSS-compliant third-party providers, including:

• PayPal
• Stripe
• Authorized Bank Wire Transfers

Key Points of Financial Data Handling:

1. Direct Transmission to Processors:

• Your financial information, including credit or debit card details, is encrypted using industry-standard SSL protocols and transmitted directly to our payment processors.
• Portal2222 Ltd. does not collect, store, or access sensitive financial data, ensuring your payment details remain confidential and secure at all times.

2. Trusted Providers:

• Payment processors used by Portal2222 Ltd. comply with international payment security standards, providing an additional layer of protection for your transactions. These trusted providers are fully committed to maintaining the highest standards of payment security.

3. Fraud Prevention:

• All transactions are actively monitored for fraudulent activity. Any suspicious activity will be flagged for further review to prevent unauthorized transactions and ensure the security of your financial information.

4. Commitment to Transparency:

• Should you have questions about how your financial data is handled, we encourage you to review the privacy policies of our payment providers (PayPal and Stripe), which provide additional details about their security practices.

By making a payment through our website, you agree to the secure handling of your transaction as described in this section. We ensure that all financial transactions are processed securely using the latest encryption technologies.

XV. Fraud Prevention and Monitoring:

Portal2222 Ltd. is committed to safeguarding your transactions through robust fraud prevention measures and continuous monitoring.

Key Measures for Fraud Prevention:

1. Real-Time Monitoring:

• All payment activities are continuously monitored using advanced fraud detection systems to identify suspicious patterns or unauthorized attempts. This helps us protect both users and our systems from potential fraud.

2. Transaction Suspensions:

• In the event of suspected fraudulent activity, transactions may be temporarily suspended or flagged for further investigation. This precaution is taken to protect both the user and Portal2222 Ltd. from potential harm.

3. Collaboration with Payment Processors:

• Collaboration with Payment Processors:

4. Notification and Resolution:

• Users will be notified immediately if their transaction is flagged for review. Any necessary steps to verify the legitimacy of the payment will be clearly communicated to ensure a smooth resolution.

5. Commitment to Security:

• These measures are designed to ensure the safety of all financial transactions while maintaining a seamless user experience. Our goal is to balance security with convenience, offering peace of mind to all users.

By using our services, you agree to cooperate with any verification processes required to resolve flagged transactions and uphold the integrity of our payment systems. We proactively monitor transactions to detect and prevent fraudulent activities, ensuring the protection of your financial information.

XVI. User Rights:

Portal2222 Ltd. is dedicated to upholding your data protection rights under GDPR and other international laws. As a user, you are entitled to the following rights:

1. Access Your Information:

• You have the right to request access to the personal information we hold about you. Upon request, we will provide details on how your data is being used and processed, ensuring full transparency.

2. Correction of Data:

• If any personal information we hold is inaccurate or incomplete, you can request corrections or updates at any time. We strive to keep your information accurate and up-to-date.

3. Deletion of Personal Data:

• You may request the permanent deletion of your personal data from our systems, subject to any legal or contractual obligations that require its retention. We will honor your request to delete your data unless we are legally bound to retain it.

4. Withdraw Consent:

• You have the right to withdraw your consent for data processing at any time. This includes opting out of marketing communications or any other non-essential data usage.

5. Data Portability:

• If applicable, you may request a copy of your personal information in a structured, commonly used, and machine-readable format for transfer to another service provider. This allows you to retain control over your data.

6. Right to Object:

• You may object to the processing of your personal data for specific purposes, such as direct marketing or profiling, where applicable.

7. Lodging Complaints:

• If you believe your data rights have been violated, you have the right to lodge a complaint with a relevant data protection authority. We encourage you to contact us first so we can address your concerns promptly.

How to Exercise Your Rights:

To exercise any of these rights, please contact us at:

Email: support@davidmichaelfelineharmony.com

We aim to address all inquiries and requests promptly, in accordance with applicable data protection laws. You can contact us at any time to exercise your rights regarding your personal data.

XVII. Policy Updates:

Portal2222 Ltd. reserves the right to update this Privacy Policy at any time to reflect:

• Changes in applicable laws or regulations.
• Updates to our services or business practices.
• Modifications required by payment processors or other third-party partners.

Notification of Changes:

Significant updates to this Privacy Policy will be communicated to clients via:

1. Email notifications sent to the address on file.
2. Prominent announcements or updates on our website.

We encourage clients to review this Privacy Policy periodically to stay informed about how their information is handled. Any updates to this Privacy Policy will be published on our website, and we encourage you to review them periodically.

XVIII. Compliance and Contact Information:

This Privacy Policy has been carefully designed to comply with the General Data Protection Regulation (GDPR) and other relevant international data protection laws, ensuring the secure, lawful, and transparent handling of your personal information.

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact us at:

Email: support@davidmichaelfelineharmony.com

We are committed to addressing your inquiries promptly and ensuring your privacy and data protection rights are respected. For any complaints regarding your data rights, please contact us, and we will promptly address your concerns.

XIX. Sharing of Data with Third Parties:

We may share your data with trusted third parties, including payment processors and service providers. These third parties are obligated to maintain the confidentiality of your data and use it only for the specific purposes for which it was shared, such as processing payments or providing additional services. We ensure that these third parties comply with data protection regulations, including GDPR, to safeguard your privacy. We only share your personal data with third parties who comply with GDPR and other relevant data protection regulations.

XX. International Data Transfers:

Your personal data may be transferred to and processed in countries outside of your country of residence. We ensure that these transfers are in compliance with applicable data protection regulations. The laws of the jurisdiction in which Portal2222 Ltd. is based will govern any disputes regarding the processing of personal data. All international data transfers are carried out securely and in full compliance with GDPR.

Effective Date: January 10, 2025

Last Updated: January 10, 2025