Please read this privacy policy carefully before using the App.
These terms and conditions were last updated on 5th Feb 2024.
Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in [LINK TO POLICY] and it is important that you read that information.
Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy].
YES I consent to the installation of the App for the purposes of health tracking
NO I do not consent to the installation of the App.
How you can withdraw consent
Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us by email at admin@ChangeXtra.co.uk, or by post at ChangeXtra Limited, The Ingenuity Lab, Triumph Road, Nottingham NG7 2TU, but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
Consent to processing Location Data
YES I consent to processing of my Location Data (including details of my current location disclosed by GPS technology so that location-enabled Services are activated to [PURPOSE OF LOCATION-ENABLED SERVICES]).
NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.
For the purposes of this document, the Data Protection Legislation shall mean any data protection or privacy legislation from time to time in force in the UK including the Data Protection Act 2018 and the UK General Data Protection Regulation and any successor legislation.
This policy (together with our end-user licence agreement (EULA)
and our Website terms and conditions and any additional terms of use incorporated by reference into the EULA, (together our Terms of Use) applies to your use of:
This policy sets out the basis on which any personal data We collect from you, or that you provide to Us, will be processed by Us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand Our views and practices regarding your personal data and how We will treat it.
IMPORTANT INFORMATION AND WHO WE ARE
For the purposes of Data Protection Legislation, ChangeXtra Limited is the controller and is responsible for your personal data. We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.
· Full name of legal entity: ChangeXtra Limited
· Name of DPO: Dr. Claire Mann
· Email Address: admin@ChangeXtra.co.uk
· Postal Address:The Ingenuity Lab, Ingenuity Centre, Triumph Road, Nottingham NG7 2TU.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.
We may collect, use, store, transfer and process the following kinds of personal data about you:
You may give Us information about you by filling in forms on the App, or by corresponding with Us by phone, e-mail or otherwise. This includes information you provide when you register to use the App, Our Site(s), subscribe to any of Our Services, participate in discussion boards (or other social media functions on or linked to the App or Our Site(s)), enter a competition, promotion or survey or carry out any other activity and when you report a problem with the App, or Our Site(s). If you contact us, we will keep a record of that correspondence. The information you give Us may include your name, address, e-mail address and phone number, age, username, password, demographic information, personal description, and any other information you provide.
When you sign up to use the Services, you may also choose at entirely your discretion to provide personal data about your health and well-being such as:
By providing this information to us you explicitly consent to us processing it in accordance with the provisions of this policy. Your consent can be withdrawn at any time. You acknowledge and agree that the extent of such data you provide will alter the level of use and access you’ll get from app and/or services.
With regard to each time you visit Our Site(s) or use the App or Services, We may automatically collect the following information about you:
We may receive information about you if you use any of the Services Sites We operate or the other Services We provide. In this case We will have informed you when We collected that data that it may be shared internally and combined with data collected on Our Site(s). We are also working closely with third parties (including, for example, business partners, sub-contractors, delivery services, analytics providers, search information providers) and may receive information about you from them.
We use cookies to distinguish you from other users of the App, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps Us to provide you with a good experience when you use the App or browse Our Sites(s) and also allows Us to improve the App and Our Sites(s). For detailed information on the cookies We use and the purposes for which We use them please refer to our cookies policy.
Uses made of the information
We will only use your personal data when the law allows us to do so. Most commonly we will use information held about you in the following circumstances:
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data
We may use this information for the following purposes:
Where we process such Special Category Data, we will ensure we are permitted to do so under data protection laws. We collect and use Health Data for the purposes listed above, in the section titled “Purposes for which we will use your personal data”, and we will only process your Health Data as is necessary to perform our contract with you under the terms of the EULA. We will rely on explicit consent as a legal basis or processing Special Category Data and you can withdraw this consent at any time.
Disclosure of your information
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the selected third parties set out below:
We may disclose your personal information to third parties:
All information you provide to Us is stored on secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology.
Where We have given you (or where you have chosen) a password which enables you to access certain parts of Our Site(s), you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data:
· 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 or your personal data.
· Right to withdraw consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at admin@ChangeXtra.co.uk.
Changes to Our privacy policy
We keep our privacy policy under regular review. Any changes We may make to Our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to Our privacy policy.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:
or
Data Protection Officer
ChangeXtra, The Ingenuity Lab, Triumph Road, Nottingham, NG7 2TU
Glossary
Lawful basis
Consentmeans processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third parties
Service providers [acting as processors] based in [UK] who provide IT and system administration services.
Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in [UK] who provide [consultancy, banking, legal, insurance and accounting services].
HM Revenue and Customs, regulators and other authorities [acting as processors or joint controllers] based in the UK who require reporting of processing activities in certain circumstances.
Your legal rights
You have the right to:
· Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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