You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Our data protection officer can be reached on [dedicated contact email.]
1 The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with personalised services via our app, as further set out in the app terms and conditions). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. Inputting inaccurate or incomplete data may also render our services less effective for you.
2 How we use your personal data
We will only use your personal data when the law allows us to for the purposes of delivering the services you have signed up for. We do reserve the right to anonymise and aggregate your data with data from other sources and use that aggregated data (which has ceased to be personally identifiable) to determine trends and to combine with other aggregated data for a range of applications and in order to improve the App and the services which we can offer to our users, analyse health and wellness trends and for other relevant uses for our business.
2.B Legitimate interest statement
We process personal information for certain legitimate business purpose under the GDPR Article 6 (1) (F) which include some or all of the following;
• Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers.
• To identify and prevent fraud.
• To enhance the security of our network and information systems.
• To better understand how people interact with our websites.
• To provide communications which we think will be of interest to you.
To determine the effectiveness of promotional campaigns and advertising.
We will not use personally identifiable information for any marketing purposes
4 Disclosures of your personal data
We may share your personal data with internal or external third parties, such as our hosting services provider. only for the purposes of carrying out the services we have contracted to deliver, in accordance with the app terms and conditions and subject to strict terms as to data privacy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5 International transfers
We do not transfer your data outside the European Economic Area, but should we be required to do so, we would do so on the terms of Articles 44-50 General Data Protection Regulation, and in accordance
6 Data security
We take data security very seriously. As a data controller, we have implemented appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with GDPR guidelines. Further, as a data processor, we only process personal data which is necessary for each specific purpose of the processing.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7 Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Unless any such specific circumstances apply, we will wipe your personal data collected via the app on your terminating your use of the app.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8 Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may:
Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us. You will generally not have to pay a fee to access your personal data (or to exercise any of the other rights).
9 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10 Contact details
Full name of legal entity: Jonple Limited
Email address: firstname.lastname@example.org
Telephone number: +44 161 723 3216