PRIVACY POLICY
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.
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 well-being improvement.
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 support@innovatehealthlab.co.uk but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
Introduction

This privacy notice applies to your use of:

- HealthLab mobile application software (App) available on our WEB Site OR hosted on App
Site, once you have downloaded or streamed a copy of the App onto your mobile telephone or
handheld device (Device).

- Any of the Services accessible through the App (Services) that are available on the App Site or
other sites of ours (Services Sites) 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.
Who we are

INNOVATE HEALTH LAB LTD (company number 12735404), is a company registered in England and our registered office is at 21 Shepherds Court, Gilesgate, Durham, England, DH1 1JQ (collectively referred to as "Innovate Health Lab", "we", "us" or "our" in this policy).

We are committed to protecting and respecting your privacy. This privacy notice will inform you as to how we look after your personal data when you use our App, process your personal data as a customer of our Services, and tell you about your privacy rights and how the law protects you. Please read the following carefully to ensure that you fully understand how and why we are using your personal data.
Purpose of this privacy notice

This privacy notice aims to give you information on how we collect and process your personal data through your use of our App, including any data you may provide through our App when you purchase a Service or contact us.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Contact details

Innovate Health Lab is the controller responsible for your personal data. If you have any questions, comments or requests regarding this privacy notice or our data protection practices, please contact us by email support@innovatehealthlab.co.uk.

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.
Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 11/12/2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

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.
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.
Personal 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).

We may collect, use, store and transfer different kinds of personal data about you as follows:
- Contact Data.
- Financial Data.
- Transaction Data.
- App Data.
- Content Data.
- Profile Data.
- Usage Data.
- Marketing and Communications Data.
Description of categories of personal data

- Identity Data: username or similar identifier, date of birth, gender.

- Contact Data: billing address, email.

- Financial Data: bank account and payment card details.

- Transaction Data: includes details about payments to and from you and details of in-App
purchases.

- App Data: includes the type of mobile device you use, a unique device identifier (for example,
your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, body weight.

- Profile Data: includes your username and password, in-App purchase history, your interests,
preferences, feedback and survey responses.

- Usage Data: includes details of your use of our App including, but not limited to, traffic data
and other communication data, whether this is required for our own billing purposes or
otherwise and the resources that you access.

- Marketing and Communications Data: includes your preferences in receiving marketing
from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How is your personal data collected?

We will collect and process the following data about you:

- Information you give us. This is information (including Identity, Contact, Financial, and
Marketing and Communications Data) you consent to giving us information about you by filling
in forms on our App, or by corresponding with us (for example, by email). It includes
information you provide when you register to use our App, download our App, subscribe to any
of our Services, make an in-App purchase, and when you report a problem with an App or our
Services. If you contact us, we will keep a record of that correspondence.

-Information we collect about you and your device. Each time you use our Apps we will
automatically collect personal data including Device, Content and Usage Data.
How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data 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

- To install the App and register you as a new App user

Type of data:
• Identity
• Contact
• Financial
• Device

Lawful basis for processing:
• Your consent

- To process in-App purchases including managing payments and collecting money owed to us

Type of data:
• Identity
• Contact
• Financial
• Transaction
• Device
• Marketing and Communications
• Location

Lawful basis for processing:
• Your consent
• Performance of a contract with you
• Necessary for our legitimate interests (to recover debts due to us)

-To manage our relationship with you including notifying you of changes to the App or any Services

Type of data:
• Identity
• Contact
• Financial
• Profile
• Marketing and Communications

Lawful basis for processing:
• Your consent
• Performance of a contract with you
• Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
• Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

- To enable you to participate in a prize draw, competition or complete a survey

Type of data:
• Identity
• Contact
• Device
• Profile
• Marketing and Communications

Lawful basis for processing:
• Your consent
• Performance of a contract with you
• Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)


- To administer and protect our business and this App including troubleshooting, data analysis
and system testing

Type of data:
• Identity
• Contact
• Device

Lawful basis for processing:
• Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

-To deliver content and advertisements to you
-To make recommendations to you about goods or services which may interest you
-To measure and analyse the effectiveness of the advertising we serve you
-To monitor trends so we can improve the App

Type of data:
• Identity
• Contact
• Device
• Content
• Profile
• Usage
• Marketing and Communications

Lawful basis for processing:
• Your consent
• Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)


Disclosures of your personal data

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 third parties set out below for the purposes set out in the table [Purposes for which we will use your personal data]:

- Internal Third Parties as set out in the [Glossary].

- External Third Parties as set out in the [Glossary].

- [Specific third parties [listed in the table [Purposes for which we will use your personal data]
above OR such as [SPECIFIC THIRD PARTIES]].]

- Third parties to whom we may choose to sell, transfer or merge parts of our business or our
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.

- [DETAILS OF ANY OTHER THIRD PARTY DISCLOSURES.]
Data security

All information you provide to us is stored on our 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 OR [ALTERNATIVE ENCRYPTION TECHNOLOGY]]. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, 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.
[DETAILS OF PROCEDURES AND FEATURES.]

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

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. Generally, we will keep personal data which we collect for up to 6 years after you cease using our services, for any of the purposes mentioned above. 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.

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.

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 2 years then we will treat the account as expired and your personal data may be deleted.
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

Internal third parties
Other companies in the INNOVATE HEALTH LAB LTD [acting as joint controllers or processors] and who are based in [SPECIFIC COUNTRIES] and provide [IT and system administration services and undertake leadership reporting].

External third parties
Service providers [acting as processors] who provide [IT and system administration services].
Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers 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.


No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Alternatively, we could refuse to comply with your request in these circumstances.


What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.


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.


If you wish to exercise any of the rights set out above, please contact us at
support@innovatehealthlab.co.uk.