Mobile application privacy policy

Please ensure you have read and understood this privacy policy before you download and/or use 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 our Website Privacy Policy and it is important that you read that information.

Fuseaware Limited (we) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy together with our Terms of Use applies to your use of:

This policy is provided in a layered format so you can click through to the specific areas set out below.

Important information and who we are

Fuseaware Limited is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).

You are an employee, agent or independent contractor of a person, company or business ("Authorising Entity") who has purchased the service provided via the App (“Service”), or of a subcontractor to the Authorising Entity. Pursuant to our agreement with the Authorising Entity, you are permitted to use the App and the Documents as an “Authorised User”, subject to your ongoing adherence to:

For the purposes of this statement the terms “personal data”, “process”, “controller” and “processor” shall have the meanings given to them in the EU General Data Protection Regulation (2016/679).

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

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.

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 2 May 2019. 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 Sites 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 Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

We explain these categories of data at the end of this policy.

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.

For the purposes of our App, we collect Special Categories of Personal Data about you (this includes health and wellbeing data). We do not collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

Cookies

We use cookies [and/or other tracking technologies] to distinguish you from other users of the App, App Site, 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 any of Our Sites and also allows us to improve the App and Our Sites. For information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Website Privacy Policy.

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:

See the Glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

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.

Purposes for which we will use your personal data

Purpose/activity Type of data Lawful basis for processing
To install the App and register you as a new App user Identity
Contact
Device
Your consent
To process in-App purchases and deliver Services including health advice Identity
Contact
Financial
Transaction
Device
Marketing and Communications
Health
Your consent
Performance of a contract with you
To manage our relationship with you including notifying you of changes to the App or any Services Identity
Contact
Financial
Transaction
Device
Marketing and Communications
Health
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 Identity
Contact
Device
Marketing and Communications
Health
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing Identity
Contact
Device
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content, advice 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 advice we provide you
To monitor trends so we can improve the App
Identity
Contact
Device
Content
Profile
Usage
Marketing and Communications
Health
Consent
Necessary for our legitimate interests (to develop 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 above:

Data security

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. 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.

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

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 12 months then we will treat the account as expired and your personal data may be anonymised or deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Please see the section below on ‘Your legal rights’ to find out more about these rights.

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 legal@fuseaware.com.

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 Fuseaware Limited Group and provide IT and system administration services and undertake leadership reporting.

External Third Parties: Service providers who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities based in the UK.

Your legal rights

You have the right to:

Description of categories of personal data