Dated: 28 April 2019
PLEASE READ THIS POLICY CAREFULLY BEFORE USING POLYFINS TECHNOLOGY IN SERVICES
You must be 16 years or older to use our Services.
When visiting Polyfins website at https://eczemaless.com/ (our “Website”), using our application: “EczemaLess – An AI Eczema App” (our “App”) or using any of the services offered via the Website or the App (the “Services”), you will be asked to indicate your acknowledgment of, and where applicable your consent to, the practices described in this policy.
Our Website contains links to third party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.
Information we may collect
We may collect and process the following data about you:
· Information that you provide to us. You will be asked to provide us with your information when you:
o fill in forms on our Website or App, or correspond with us by phone, email or otherwise;
o register to use our Services subscribe to our newsletter, promotional emails or other marketing materials;
o use the Services;
o report a problem with our Services; or
o complete any surveys we ask you to fill in that we use for research purposes (although you do not have to respond to these if you do not want to).
The information you will be asked to provide to us for these purposes will include your name, gender, date of birth, email address, phone number, symptoms of your illness, potential causes of your illness symptoms, your medical history, any allergies you have, or further information required to verify your identity.
· Information we collect about you. With regard to each of your visits to our Website or our App, we may automatically collect the following information; however, this information cannot be used to identify you:
o device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
o technical information about your computer, including where available, your IP address, operating system, and browser type, for system administration and analytical purposes;
o details of your visits to our Website and App, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website and App (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs);
o information showing us from which app store you downloaded our App; and
How we use your information and justification of use.
Use of personal information under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds that justify our use of your information:
· Consent: where you have consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us);
· Contract performance: where your information is necessary to enter into or perform our contract with you;
· Legal obligation: where we need to use your information to comply with our legal obligations;
· Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and
· Legal claims: where your information if necessary for us to defend, prosecute, or make a claim against you or a third party.
We use information held about you (and information about others that you have provided us with) in the following ways:
Types of Information we collect
· Email address, name, date of birth, gender
o Uses of that Information: To provide you with access to our Website, App, and any other information which you request from us, and to use our Services.
o Use Justification: contract performance
· illness symptoms, potential causes of illness symptoms, allergies, pregnancy status, history of hypertension or diabetes
o Uses of that Information: To provide you with the Services.
o Use Justification: Consent (we require your consent to process your sensitive personal data, which is required in order to provide the Services.)
· Email address, name
o Uses of that Information: For marketing products and services that we believe will be of interest to you.
o Use Justification: Legitimate interest (for marketing our own similar products and services and any re-engagement campaigns) Consent (for marketing unrelated products or services or products or services of third parties).
· Date of birth, illness symptoms, potential causes of illness symptoms, medical history, allergies, location
o Uses of that Information: To identify more appropriate products and services to market to you.
o Use Justification: Legitimate interest (to tailor our services appropriately). No marketing of third party products or services will be conducted without your consent.
· Email address, name, date of birth, illness symptoms, potential causes of illness symptoms, medical history, allergies
o Uses of that Information: To assess your suitability for clinical research and invite you to partake.
o Use Justification: Legitimate interest – no personal data will be used as part of a clinical trial without your consent. Consent (for contacting you about clinical research that may be of interest to you).
· Email address, name, date of birth, illness symptoms, potential causes of illness symptoms, medical history, allergies
o Uses of that Information: To administer our Services and for internal operations, including research, data analysis and data statistics, and to create derived, anonymised and aggregated data to improve our Services.
o Use Justification: Legitimate interest (to administer and improve our Services).
· Email address
o Uses of that Information: To notify you about changes to our Services.
o Use Justification: Contract performance, legitimate interests (to update our Services from time to time).
We will not sell your personal data (or any other data you provide us with) to third parties, however, we reserve the right to share any data, which has been anonymized and/or aggregated. You acknowledge and accept that we own all right, title and interest in and to any derived data or aggregated and/or anonymized data collected or created by us.
We may use the information for marketing products and services to you in the following ways:
Types of marketing activity
· Newsletters and marketing emails relating to our own similar services and products. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.
o Use justification: Legitimate interest (to market our products and services – you have the right to unsubscribe at any time)
· To send you details about unrelated services or products or special offers and discounts which are being provided by our selected business partners. Where required by law, we will ask your consent at the time we collect your data to conduct any of these types of marketing.
o Use justification: Consent (which can be withdrawn at any time)
We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us.
Your passwords are stored on Polyfins’s servers in encrypted form. We do not disclose your account details. It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the internet is not completely secure. Although Polyfins will do its best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website, 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 any unauthorised access.
Sensitive information between your browser and our Website is transferred in encrypted form using Secure Socket Layer (“SSL”). When transmitting sensitive information, you should always make sure that your browser can validate the Polyfins certificate.
Please contact us if you would like further details on the specific safeguards applied to the export of your personal information outside EEA.
Disclosure of your information
We may also disclose your personal information to third parties in the following circumstances:
Purpose of disclosure and third party(s) to which disclosure might be made
· We track your interaction with Polyfins services anonymously. This tracking is limited to your interaction with Polyfins services and in no way do we track anything else other than the Polyfins services. We use this information to further improve Polyfins services and the information
we gather is used exclusively for internal purposes; it is never sold, shared or communicated to third parties.
· If Polyfins or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets.
o Use Justification: Legitimate interest (to sell our Company or assets); and where required by applicable law, consent (for sensitive personal data).
· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Polyfins, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
o Use Justification: Legal obligation, vital interest.
· We may disclose certain data to organizations involved in clinical trials and other types of research where you have been authorized to do so.
o Use Justification: Consent.
· Fraud Prevention and other checks. We and other organizations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or accurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies.
o Use Justification: Legitimate interest (to assist with the prevention of fraud and to assess your risk profile).
· We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere
in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
o Use Justification: Legal obligation (to cooperate with law enforcement and regulatory authorities).
How long we retain your personal data
We will hold the above information for as long as is necessary in order to provide you with the Services, deal with any specific issues that may raise, or otherwise as is required by law or any relevant regulatory body.
We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.
Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at firstname.lastname@example.org.
You have the following rights in relation to your personal data:
· Right to Rectification
o We will use reasonable endeavors to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.
· Right to erasure / ‘Right to be forgotten’
o By deleting your account, Polyfins will delete all of your personal data without undue delay (unless there is a legitimate and legal reason why Polyfins is unable to delete certain of your personal data, in which case we will inform you of this in writing).
· Right to restriction of processing
o You have the right to ask us to stop processing your personal data at any time.
· Right to data portability
o You have the right to request that Polyfins provide you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.
· Right to complain
o You have the right to lodge a complaint to a supervisory authority such as the Bundesdatenschutzbehörde in Germany or the Information Commissioner’s Office in the UK. Although we encourage our customers to engage with us in the event they have any concerns or complaints.
Polyfins will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive, or manifestly unfounded requests, we may charge you requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.
Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use Polyfins’s Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use the Services.
Changes to this policy
For the purpose of the relevant data protection legislation, the data controller is Polyfins Technology Inc.