These terms and conditions were last updated on 5th Feb 2024.

Please read this privacy policy carefully before using the App.

ChangeXtra Limited doing business as ChangeXtra (“we, “us”, “our”) is committed to protecting and respecting your privacy. Pausetrack is the name of the App and is our registered trademark under trademark number UK00003803151.

Consent to installation of the app

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.

Agreement to our legal terms

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:

• The Pausetrack app, once you have downloaded or streamed a copy of the Pausetrack app (“App”) onto your mobile telephone, tablet or handheld device (“Device”)
• Any of the services accessible through the App (Services) or other websites of ours (Services Sites) unless the EULA or website terms and conditions states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.
• Any chatbot, voice skill, or action, made available through third party platforms tha t are also subject to the Privacy Policy of that provider which you will have been asked to agree to as part of your use of that platform.

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.

Third party links

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

Information we may collect about you

We may collect, use, store, transfer and process the following kinds of personal data about you:

Information you give Us (Submitted information)

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:

• Weight
• Body temperature
• Menstrual cycle dates
• Details of medication you are taking
• Various symptoms related to your menstrual cycle and health
• Other information about your health (including sexual activities), physical and mental well-being, and related activities, including personal life

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.

Information We collect about you

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:

• Technical information, including the type of mobile device you use, mobile network information, your mobile operating system, the type of mobile browser you use (Device Data)
• Details of your use of any of Our App(s) or your visits to any of Our Site(s) and the resources that you access
• Internet Protocol address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about your visit, including the full Uniform Resource Locators clickstream to, through and from Our Site(s), (including date and time)
• Product you viewed or search for
• Page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from the page and any phone number used to call Our customer service number
• Location Information. We may also use GPS technology to determine your current location. Some of Our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You withdraw your consent at any time by disabling location services when you use our Service at any time through your mobile device settings .
• Our App(s) and Our Site(s) may collect information about user demographics through Google Analytics Demographics and Interest Reporting. This information will only be used for internal reporting and not shared with third parties.
• Symptoms and Behaviour data. Part of our App is designed to track your activity. We may collect your symptoms and behaviours data either when you manually input your activity data into the App or when you employ features in the App or the Services that are designed to capture your activity data.

Information we receive from other sources

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.

Cookies

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:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

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:

• to install the App and register you as a new App user
• to process in-App purchases and deliver Services including [e.g. managing payments and collecting money owed to us]
• to enable you to participate in a prize draw, competition or complete a survey
• to administer and protect our business and this App including troubleshooting, data analysis and system testing
• to carry out Our obligations arising from any contracts entered into between you and Us and to provide you with the information, products and services that you request from Us
• to deliver content and advertisements to you and to provide you with information and recommendations about other ChangeXtra services We offer that we feel may be of interest to you. You can opt out of receiving any communication We send you relating to this at any time
• We will only contact you by electronic means (e-mail or SMS) with information about services We feel may be of benefit to you and only if you have consented to this. If you change your mind and no longer  want Us to use your data in this way, please tick the relevant box situated on the form on which We collect your data (the registration form)
• to manage our relationship with you including to notify you about changes to the App, or any of Our Services
• to measure and analyse the effectiveness of the advertising we serve you
• to monitor trends so we can improve the App and to ensure that content from the App and Our Sites(s) is presented in the most effective manner for you and for your computer or device
• to administer the App or Our Site(s) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
• to improve the App or Our Site(s) to ensure that content is presented in the most effective manner for you and for your Device/computer
• to allow you to participate in interactive features of Our service, when you choose to do so
• as part of Our efforts to keep the App and Our Site(s) safe and secure
• to make suggestions and recommendations to you and other users of the App and Our Site(s) about services that may interest you or them
• to provide you with targeted advertising that We feel may be of interest to you
• in an aggregated and anonymised form for research purposes carried out internally or by trusted third parties
• in an aggregated and anonymised form as part of one or more scientific publications to inform research and public policies related to health and wellbeing, mobility, computer science and related fields

We may combine information that we receive from other sources with information you give to Us and information We collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information We receive).

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Special Category Data

Data relating to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, and information about your health (Special Category Data) is subject to stricter controls. We will only collect Special Category Data relating to your basic demographics (gender, ethnicity) and health (Health Data).

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:

• Business partners, suppliers and sub-contractors for the performance of any contract We enter into with you.
  Local councils with which We collaborate to advise and support them in the delivery of their public health function, but only in an anonymised manner.
• Universities and other research approved institutions with which We collaborate to advise and support them in the undertaking of research, but only in an anonymised manner.
• Business partners, suppliers and sub-contractors with which We collaborate, but only in an anonymised manner.
• Analytics and search engine providers that assist Us in the improvement and optimisation of the App and Our Site(s).

We may disclose your personal information to third parties:

• If ChangeXtra Limited or substantially all of its assets are transferred to a third party organisation, in which case personal data held by it about its customers will be one of the transferred assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy
• If We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply Our terms of use. Please see Our  Terms and Conditions page and other agreements; or to protect the rights, property, or safety of ChangeXtra. Our customers, or others

International transfers

We will only transfer your personal data within the UK, European Union (EU) and within the European Economic Area (EEA). Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Personal data in the EU, EEA and UK is protected by the General Data Protection Regulation and Data Protection Act 2018.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Where We store your personal data

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.

Data retention

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

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In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
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.
In the event that you do not use the App for a period of [3 years] then we will treat the account as expired and your personal data may be deleted.

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Should you require further details of our retention periods for different aspects of your personal data please contact us.

Your legal rights

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:

admin@ChangeXtra.co.uk

or

Data Protection Officer

ChangeXtra, The Ingenuity Lab, Triumph Road, Nottingham, NG7 2TU

Glossary

Lawful basis

Consent means 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.