Last updated 25th October 2022
This privacy notice for iPrescribe Exercise Digital Ltd (doing business as EXI) (‘EXI‘, ‘we‘, ‘us‘, or ‘our‘), describes how and why we might collect, store, use, and/or share (‘process’) your information when you use our services (‘Platform‘), such as when you:
- Visit our website at http://www.exi.life
- Download and use our mobile application (EXi – Exercise Prescription)
- Visit and use the EXI Data Portal – clinician facing Content Management System
- Engage with us in other related ways, including any sales, marketing, or events
When you use our Platform, you trust us with your personal information. We take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it.
Questions or concerns? Reading this privacy notice, as well as our terms and conditions of use (referred to throughout as our “Terms and Conditions”), will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Platform. If you still have any questions or concerns, please contact us using the contact information provided at the bottom of this page.
TABLE OF CONTENTS
1. WHY DO WE PROCESS YOUR INFORMATION?
We process your personal information for a variety of reasons, depending on how you interact with our Platform, including:
We collect personal information that you voluntarily provide to us when registering with the Mobile App, registering with the Data Portal, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Mobile App or otherwise contacting us.
- To provide you with a personalised physical activity program.
- To allow you to track your health metrics as you progress through your physical activity program.
- To demonstrate the effectiveness of physical activity program on population health.
- To improve our program.
- To facilitate account creation and authentication and otherwise manage user accounts.
- To respond to user inquiries/offer support to users.
- To send administrative information to you.
- To fulfil and manage your orders.
- To request feedback.
- To send you marketing and promotional communications.
- To protect our Platform.
- To evaluate and improve our Platform, products, marketing, and your experience.
- To comply with our legal obligations.
2. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Platform or at your request prior to entering into a contract with you.
Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Send users information our products and services
- Analyse how our Platform is used so we can improve them to engage and retain users
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, physical activity or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
3. WHAT INFORMATION DO WE COLLECT?
The personal information that we collect depends on the context of your interactions with us and the Platform, the choices you make, and the products and features you use.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Personal Information Provided by You
- Name and Contact data. Your first and last name, email address.
- Credentials. Your username, passwords and similar security information.
- Other Personal data. Your date of birth, gender.
- Contact Preferences. Your contact preferences such as marketing consent.
- Health data. For example, health conditions, resting heart rate, weight, blood pressure, which is used by the algorithm to develop a personalised physical activity program.
- Physical activity data. Physical activity intensity minutes, daily step count, the type of physical activity (for example walking), heart rate during physical activity and effort rating.
Mobile Application Data
- Geolocation Information. We may request access or permission to track location-based information from your mobile device, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Access. Your mobile device’s sensors, camera, HealthKit (iOS), Google Fit (Android), and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
- Mobile Device Data. Your mobile device ID, model, and manufacturer, operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
- Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.
Information automatically collected
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Platform and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity on the Platform (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
Information collected from other sources
We do not obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties‘) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
- Healthcare Organisations. If you have been referred to the mobile application by your organisation (and have signed up using an invite code), we will shareidentifiable personalisedas explicitly stated in your invitation and included in your onboarding consent experience.
- Employee offered programs: If you have been referred to the mobile application by your organisation (and have signed up using an invite code), we will provide higher level aggregated and anonymised data to that organisation so that they can analyse general trends.
- Research program: If you have been referred to the mobile application by your organisation (and have signed up using an invite code), we will provide higher level aggregated and anonymised data to that organisation so that they can analyse data for the specific research you’ve consented to participate in.
- Data Analytics Service: We may use third-party Service providers to monitor and analyse the use of our Service. Including but not limited to:
- Google Analytics – For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
- Firebase – For more information on what type of information Firebase collects, please visit the How Google uses data when you use our partners’ sites or apps webpage: https://policies.google.com/technologies/partner-sites
- Communication & Collaboration Tools
- Performance Monitoring Tools
- Website Hosting Service Providers
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
Specific information about how we use such technologies and how you can refuse certain cookies can be obtained by contacting us at firstname.lastname@example.org
6. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process.
All information we collect is stored on secure servers held in both the European Economic Area (EEA) and GDPR compliant international data processors only. Where international data processors are used, all appropriate technical and legal safeguards will be put in place to ensure that you are afforded the same level of protection as within the EEA.
Where We have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Platform is at your own risk. You should only access the Platform within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Platform, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Platform. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us using the contact information provided at the bottom of this document.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact information provided in this policy.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/about-edpb/members_en
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be expressed and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact information provided in this policy.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time:
- From within the mobile application, goto your Profile and then Settings
- Contact us using the contact information provided
You will then be removed from the marketing lists. However, we may still communicate with you for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
If you would at any time like to review or change the information in your account or terminate your account, you can:
- From within the mobile application, goto your Profile and then Account
- Contact us using the contact information provided
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may contact us using the contact information provided at the bottom of this document.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. DO WE MAKE UPDATES TO THIS POLICY?
We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Michael Kaye, by email at email@example.com