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.] Please note that our data protection officer has special responsibilities under GDPR for compliance with the data protection legislation and, accordingly, is the appropriate first point of contact for your questions or concerns with respect to our processing of your data.
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). Furthermore, based on the data which you supply to us, we may form the opinion that it is not possible for us to provide services to you based on the app, as is set out in more detail in our 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 and may even lead to our making recommendations or providing programs which are inappropriate 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.
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 with them to deliver to us, 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 our data protection officer. 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: email@example.com
Telephone number: +44 161 723 3216