Privacy Policy for Sentimoto Ltd

Sentimoto Ltd recognises that its customers, visitors and users, want to know what’s up with privacy. We aim to be open about collecting information from you and clear about what we will use it for. This Privacy Policy is incorporated into and is subject to the Sentimoto Service Terms of Use. Your use of the Sentimoto Service (including the App and Website) and any personal information you provide on the Sentimoto Service remains subject to the terms of this Privacy Policy and our Terms of Use.The processing of personal data by Sentimoto is regulated by the laws and regulations of the UK and the EU (“Data Privacy Laws”). This policy explains how Sentimoto complies with Data Privacy Laws, the steps Sentimoto must take in processing personal data and some of the rights that data subjects have under Data Privacy Laws.

What is “personal data”?
Personal data is any information concerned with living individuals who can be identified either from that information alone or in combination with other information that is, or is reasonably likely to become, held by Sentimoto including but not limited to name and address, email address, age, gender, personal interests, date of birth and occupation.

What information do we collect from you?
We collect the following data:

  • Personal data provided or uploaded by you, including email addresses, mobile phone numbers, age, gender, personal interests, date of birth and occupation.
  • Sensor data collected by your mobile phone and any other third-party service that is used by Sentimoto including movement data from GoogleFit; movement data from accelerators, gyroscopes, barometer; light intensity data from light sensors; sound and voice activity data from microphones; location data from global positioning units, radio units, cell tower triangulation, wireless units, and BlueTooth; messaging and calling metadata; listed application metadata.
  • Push notification names (if applicable).
  • Billing information (if applicable) and mobile device information provided to Sentimoto in connection with your use of the Sentimoto Service.
  • Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model; operating system and version; unique device identifiers; sensors available on the device; browser type and version; time zone setting; and mobile network information.
  • Log File Information: When you use the Service, our servers automatically record certain information that your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol (” IP “) address, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages or the amount of time spent on particular pages.
  • Information provided to us from other sources: We may receive information about you from third parties in the course of making available the Sentimoto Service to you, including organisers of events that are listed on the Sentimoto Service; business partners; sub-contractors; and payment providers.

Use of the information we collect from you
We may use the personal data that we collect from you for the following purposes:

  • To operate, maintain, and provide to you the features and functionality of the Sentimoto Service, including the tracking of time spent outside of the house, social activity, physical activity, and sleep; triggering alerts based on changes of activity patterns; optimising the suggestion of wellbeing tips and suggestions of activities.
  • For non-marketing or administrative purposes, such as notifying you of major Sentimoto Service changes or for customer service purposes.
  • To provide you with information about activities that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
  • To notify you about changes to the Sentimoto Service.
  • To ensure that the Sentimoto Service is presented in the most effective manner for you.
  • To measure and understand the effectiveness of certain features of the Sentimoto Service.
  • To provide location based services to you if (i) you have installed the Sentimoto App on a mobile device and permitted your mobile device to transmit location data in respect of this App, or (ii) you access the Sentimoto Website via a mobile browser and you allow the transmission of your location data when prompted by your browser.
  • To make disclosures to lawful authorities when required to do so by law.
  • In particular:
    • We use your name, email, and phone number to identify you as a user of the Sentimoto Service;
    • We use sensor data to deliver the wellbeing tracking, provide you with information about location-based services to you;
    • We use Device Information to optimise the wellbeing tracking and user interface to your device;
    • We use Log File Information to measure and understand the effectiveness of the information made available to you

Processing of Information
We will process your personal data on the basis of your consent and/or our legitimate interests (which will include the administration and improvement of the Sentimoto Services, the provision of information about the Sentimoto Services and compliance with applicable laws, rules and regulations).

Sentimoto processes all personal data in accordance with the following data protection principles:

  • Processing must be fair, lawful and transparent. The data subject must be told who the data controller is, who the data controller’s representative is, the purpose for which the personal data is to be processed, and the identities of anyone to whom the personal data may be disclosed or transferred. Where Sentimoto is collecting personal data directly, we will do this on or before collection. We will also provide this information to data subjects where we receive personal data from an intermediary. Where sensitive personal data is being processed, more stringent conditions must be met. In most cases, the data subjects’ explicit consent to the processing of such data will be required.
  • Processing must be for limited purposes and must be done in an appropriate way. Personal data must generally only be processed for the purposes notified to the data subject when the data was first collected or for any other purposes permitted by data protection laws. This means that personal data will not be collected for one purpose and then used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject must generally be informed of the new purpose before any processing occurs, and their consent may be required.
  • Processing must be adequate, relevant and limited to what is necessary for the purposes. Personal data must only be collected to the extent that it is required for the specific purpose notified to the data subject. Any data that is not necessary for that purpose should not be collected in the first place.
  • Personal data must be accurate and kept up to date. Information that is incorrect or misleading is not accurate and steps should be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data must be corrected, destroyed or erased from our systems, as appropriate.
  • Personal data must not be kept longer than necessary for the purpose. This means that personal data must be destroyed or erased from our systems when it is no longer required for the specified purpose that it was collected for, provided that Sentimoto may retain personal data in order to comply with applicable laws, regulations and rules.
  • Personal data must be processed in line with the rights of data subjects. Data subjects have a number of rights under data privacy laws (see below).
  • Personal data must be kept secure. Appropriate security measures must be taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. Sentimoto is required to put in place procedures, technologies and other measures to maintain the security of all personal data from the point of collection to the point of destruction.
  • Personal data must not be transferred to people or organisations situated outside the EEA unless it will be adequately protected. Data privacy laws impose restrictions on when personal data can be transferred outside the EEA to a country that does not (according to EU data privacy laws) provide adequate protection for personal data.

Sharing of Information
We may share information about you as follows or as otherwise described in this Privacy Policy:

  • To those connected users, carers or clinicians to whom you give permission to receive information collected through the App.
  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf.
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process.
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company. If Sentimoto or a substantial part of our assets are acquired by a third party, your personal data may be one of the transferred assets.
  • Between and among Sentimoto and its current and future parents, affiliates, subsidiaries and other companies under common control and ownership.
  • In order to enforce or apply the terms and conditions of the Sentimoto Services, to protect the rights, property, or safety of Sentimoto, organisers of activities listed on the Sentimoto Services, or other users of the Sentimoto Services.
  • With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

We do not sell or share your personal data with other third party companies for their commercial or marketing use.

We may share information submitted as part of third party promotional activities only when you agree to the specific terms and conditions of the promotion by opting in to the promotion.

Cookies
When you visit the Website, we may send one or more cookies – a small text file containing a string of alphanumeric characters – to your computer that uniquely identifies your browser. The information we obtain consists of your IP address, your browser, when you visited and which pages you visited or downloaded during your visit.

We may use cookies and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you use the Sentimoto Service and (b) monitor individual and aggregate metrics such as total number of visitors, pages viewed, etc. in order to understand how users use our site and to make improvements.

We cannot use this information to find out any further personal information about you, and we will not share any individual’s information unless required to do so by law.

Security
We endeavour to ensure that all personal data is kept confidential and take reasonable steps to protect such information.

We constantly work to make sure that your personal data is properly protected through encryption, monitoring and other security measures.

We make sure that your data is only seen by people who need to view it for their work and that our staff are trained in protecting your information.

We cannot, however, guarantee the security of the User Provided Information as it may be compromised by unauthorised access, hardware or software failure or other relevant factors.
We cannot guarantee the confidentiality of any User Content or User Provided Information transmitted between you, us and other Sentimoto Service users or members of the general public, as the case may be. We will not be liable to you or anyone else for any loss in connection with any User Content or User Provided Information transmitted made through use of or in connection with the Sentimoto Service.

Email communications and alerts
If you register with the Sentimoto Service or sign up for any of Our newsletters or alerts, We will send you information about activities We feel may interest you. Your email address may also be used to send you information about Our other websites and businesses that We feel are relevant to your registration to the Sentimoto Service.

Additionally We may allow any third party which acquires Us or a substantial part of our assets, to contact you directly with information which you may find useful regarding their products and services.

You can unsubscribe from receiving our newsletter and other correspondence and / or by clicking the “Unsubscribe” link featured within Our correspondence . Alternatively, you can edit their personal information or manage notification subscriptions by updating your account settings within your user profile.

Where We Store Your Personal Data
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). We will take reasonable steps to ensure that any transfers of your data are compliant with applicable data protection and privacy laws (including the Act and any replacement legislation thereof). We will also implement reasonable technological and measures to ensure that once transferred outside of the EEA, your data is treated securely and in accordance with this privacy policy.

All information you provide to Us is stored on Our (or Our third party service providers’) secure servers located in the United Kingdom and other European Economic Area countries. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Sentimoto Service, you are responsible for keeping this password confidential.

The transmission of information via the internet is not completely secure. We will do Our best to protect your personal data, however, We cannot guarantee the security of your data transmitted to the Sentimoto Service; any transmission is at your own risk.

Once We have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Disclosure of Your Information
We may disclose your personal information to other third parties in the circumstances set out below.

  • In the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets
  • If We or a substantial part of Our assets are acquired by a third party, your personal data may be one of the transferred assets.
  • 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 the terms and conditions of the Sentimoto Service, to protect the rights, property, or safety of Sentimoto, organisers of activities listed on the Sentimoto Service, or other users of the Sentimoto Service.
  • We may share aggregated user information with third parties, such as advertisers and content distributors. For example, We may disclose the number of a particular category of users (e.g. women aged under 35) that have been exposed to, or clicked on, advertisements in a particular period.
  • We may share information submitted as part of third party promotional activities only when you agree the specific terms and conditions of the promotion by opting in to the promotion.

External Links
The Sentimoto Service may, from time to time, contain links to and from the websites of third parties which are not provided by Us and are not under Our control. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies and make your own independent judgement before you decide to buy any products or services, or submit any personal data to these websites.

Access to your information
You have the right to access the information we hold about you under Data Privacy Laws. You have a right to request the rectification, erasure, restriction or portability of your personal data, and to object to or withdraw consent for the processing of your personal data. We may charge £10 to administer this process. If you want to see your information or exercise any of these rights, send a description of the information you want to see, your request (including the information you want to access, if applicable) and proof of your identity by email to info@sentimoto.com.

Changes to our Privacy Policy
This Privacy Policy may be revised periodically and this will be reflected by the effective date stated at the top of these Terms of Use. Please revisit this page to stay aware of any changes. Your continued use of the Sentimoto Site and Sentimoto Service constitutes your agreement to this Privacy Policy and any amendments.

Right to complain
If you are not happy about the manner in which we are processing your personal data, please contact us at info@sentimoto.com. You also have the right to make a complaint to the UK Information Commissioner’s Office.

Contact
Sentimoto Ltd (registered company number 08804271) of 30 Upper High Street, Thame, Oxfordshire OX9 3EZ is the data controller of personal data collected through the Sentimoto Services.

Updated: 9th October 2017