We are committed to protecting your privacy and complying with our obligations under the General Data Protection Regulation, the Data Protection Act 2018 and all other laws relevant to the handling of your personal data in respect of the Service (the “Privacy Laws”). We are the data controller for the purposes of the Privacy Laws (meaning that we are responsible for deciding how your personal data is used) and for ensuring it is handled in accordance with Privacy Laws.
When we refer to “personal data”, we are referring to any information which can directly or indirectly identify you, as explained more fully below.
WHAT PERSONAL DATA WE COLLECT ABOUT YOU (OR RECEIVE FROM THIRD PARTIES)
Information that you provide to us– this may include any of the following types of personal data which you provide to us when you register with the Service, use the Service or otherwise when you communicate or interact directly with us:
Identity Data – first name, last name, date of birth, gender, username or other user identifier;
Contact Data – your phone number(s), home and work addresses, and email address;
Profile Data –you may provide feedback to us through surveys or feedback forms and indicate your preferences to receiving marketing (from us or third parties);
Financial Data – bank or payment card details and details of any purchases you make in respect of the Service;
Body Metric Data – you may input various body metrics and measurements onto your Service account (e.g. height, shoulder width, arm length, spine length, hand length, pelvis width, thigh length, waist size, inside leg measurement, chest size etc.). Certain of this data may constitute special category data – see below; and
Special Category Data –you may upload through the Service certain special category data (such as the Body Metric Data listed above and details of your ethnicity) which will be used only to provide you with more accurate and detailed performance feedback and information through the Service (unless we specify and explain to you other purposes at the time of collection). These data are seen as more sensitive and are therefore afforded greater protection under the Privacy Laws. Prior to collecting and using any such special category data, we will obtain explicit consent from you (unless we have another legal basis for collecting and using this information).
Information that we collect about you– when you visit or use the Service we may collect the following types of personal data, using our software, hardware and other technologies:
Technical Data– this might include your IP address, account log-in information, browser information, location information (which shows where you are using the Service, such as our wearable compression suit for example), operating system and system configuration, network and software identification and device information;
Usage Data – this includes information about how you use the Service, such as click throughs, time spent on page, download errors; and
Special Category Data – see above. In some cases, we may collect this special category data from you when using our products and services, such as our wearable compression suit (including without limitation, biometric data e.g. heart rate and certain body measurements and metrics). Prior to collecting and using any such special category data, we will obtain explicit consent from you (unless we have another legal basis for collecting and using this information).
Information that we receive about you from others– we may receive certain of the information about you, as referred to above, from the school, university, academy, club, or other organisations of which you are a member or representative and with whom we have a contractual relationship (a “Customer”). We may also collect certain information from the main user of the Service (where for example, the main user adds you as an authorised user, and is required to provide your name and contact details). If we receive information from third parties we may combine this with information that we currently hold about you and process such combined information for the purposes set out below. Certain of this information may be Special Category Data, which we will process as described in the sub-sections above.
It is important that the information we hold about you is accurate. Please keep us informed of any changes to your personal information.
WHY WE USE YOUR DATA
We have set out in the table below, the purposes for using your personal data and the legal basis for doing so:
|Types of Data
|To register you as a Service user
|Identity, Contact, FinancialCertain Body Metric DataSpecial Category
|Performance of a contract with you and/or your authorised users and/or a Customer Consent
|To provide our core service to you and/or your authorised users and/or a Customer, namely, to provide a training and performance tool, which generates real-time feedback and analysis
|Performance of a contract with you and/or your authorised users and/or a CustomerConsent
|For internal administration and record keeping purposes
|Performance of a contract with you and/or your authorised users and/or a CustomerNecessary to comply with a legal obligationNecessary for our legitimate interests (for effective business administration and service provision)
|To provide, maintain, improve and develop the Service
|Performance of a contract with you and/or your authorised users and/or a CustomerNecessary for our legitimate interests (for effective business administration and service provision)Consent
|Performance of a contract with you and/or your authorised users and/or a CustomerNecessary to comply with a legal obligation
|To answer your enquiries which may involve contacting you by e-mail or phone
|Performance of a contract with you and/or your authorised usersNecessary for our legitimate interests (to ensure our users are informed and satisfied with our Service)
|To enable us to process payments which you and/or a Customer and/or your authorised users make
|Identity, Contact, Financial
|Performance of a contract with you and/or your authorised users and/or a Customer
|To contact you about our promotions
|Identity, Contact, Profile
|Necessary for our legitimate interests (to improve our products and services and develop our business generally)Consent
|To contact you about third-party products and services which we believe may be relevant to you (where you have indicated you would like to hear about these)
|Identity, Contact, Profile
|To improve and personalise your experience of the Service by delivering more relevant content and advertising and to ensure that the Service is delivered to you in the most effective way possible
|Identity, Contact, Profile, Technical, Usage
|Necessary for our legitimate interests (to develop our business, improve our service and overall user experience and inform our marketing strategy)
|To administer the Service, including trouble shooting, testing and analysis and to enable you to participate in interactive features of the Service
|All (excluding Special Category Data)
|Performance of a contract with you and/or your authorised users and/or a CustomerNecessary for our legitimate interests (to ensure that the Service is fully functional and operating in the most effective way for you)
|To verify your identity and detect fraud and security issues
|All (excluding Special Category Data)
|Necessary for our legitimate interests (to prevent and detect fraudulent activity, security incidents and criminal activity)
|To enable you to participate in prize competitions, prize draws or complete a survey
|Identity, Contact, Profile, Technical, Usage
|Necessary for our legitimate interests (to develop our business, promote new products and services, obtain feedback from users to improve our services)
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
HOW LONG DO WE KEEP YOUR DATA FOR?
We will keep your personal data for as long as you are a registered user of the Service or for as long as the term of our contract with the relevant Customer (as applicable). After this point we may still need to keep hold of your personal data if there is a legal reason for doing so (such as for tax purposes or where we need to resolve any disputes with you and/or your authorised users and/or a Customer). In such circumstances, we will only retain the minimum amount of data necessary for such reason. We may retain aggregated data for any purposes.
THIRD PARTY WEBSITE LINKS
INTERNATIONAL TRANSFERS OF YOUR DATA
Currently, we do not transfer any of your personal data outside of the European Economic Area (“EEA“); however, in the future, we may need to transfer your personal data to other countries outside of the EEA. This may happen if any of our servers are from time to time located in a country outside of the EEA or if any of our service providers are located in a country outside of the EEA. Before we proceed with any such transfer, we will ensure that we have a legal ground for doing so and have made sure that all adequate protections are in place. These countries may not have similar data protection laws to the EEA. If we transfer your personal data outside of the EEA in this way, we will take the appropriate steps to ensure that your privacy rights continue to be protected and that we continue to process your data in a fair and lawful manner. Where relevant, you will have the right to see a copy of any safeguards we put in place for international transfers of your data.
DISCLOSURE OF YOUR PERSONAL DATA
We may disclose your personal data for the following purposes:
- To any Customer of which you are a member or representative, for the purposes of fulfilling our contractual obligations to that Customer.
- To our third-party service providers who assist us with delivering the Service.
- Where you have explicitly consented to us doing so, we may disclose your personal data to third parties for marketing purposes. You can opt-out of any marketing preferences at any time by following the process referred to below.
- We may also be required to share your personal data with third parties if required by law or regulation. In such circumstances, we will make sure that the disclosure is only to the extent required by law or regulation.
If we share personal data with third parties, we will ensure that access is limited on a strictly need to know basis and is subject to suitable obligations relating to confidentiality and security.
WHERE WE STORE YOUR PERSONAL DATA
We will store your personal data on servers in the European Economic Area (unless we relocate such servers, see “International Transfers of Your Data”) and will ensure that such personal data is held securely in accordance with good industry standards. Where we have given you a password to access a part of the Service you are responsible for keeping this password secure and confidential. Please do not share this with anyone else.
Please be aware that the transmission of data via the internet is not completely secure and we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.
In certain situations, you are entitled to:
- access a copy of your personal data;
- correct your personal data;
- erase your personal data;
- object to the processing of your personal data where we are relying on a legitimate interest (as set out in the above table);
- restrict the processing of your personal data;
- request the transfer of your personal data to a third party; or
- where you have provided your consent to certain of our processing activities, in certain circumstances, you may withdraw your consent at any time (but please note that we may continue to process such personal data if we have legitimate legal grounds for doing so).
If you wish to exercise any of these rights, please contact us using the details set out in the “Contact Us” section below. You will not have to pay a fee to exercise any of these rights, unless your request is clearly unfounded, repetitive or excessive (in which case we can charge a reasonable fee). Alternatively, we may refuse to comply with your request in these circumstances.
In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office or your relevant regulator if you are concerned about the way in which we are handling your personal data.
HOW TO OPT-OUT
You can opt-out of any third-party marketing that you have previously opted into (or any of our marketing) either by contacting us using the details set out below in the “Contact Us” section or by using the opt-out function detailed in the relevant marketing email.
If at any time you wish to get in touch with us, whether that is to exercise your rights or otherwise, please contact:
Please write to us at: Fareham Innovation Centre, 4 Meteor Way, Lee-On-The-Solent, United Kingdom, PO13 9FU.
Telephone: +44 748 053 5617(UK)