Privacy
Policy
1. Introduction
MSN Lifepal
Limited, owner of this mobile application ‘Lifepal’, (hereinafter MSN Lifepal
or we), respects your privacy and is committed to protecting your personal
data.
This
privacy policy (together with our Terms of Use as set out in www.lifepal.app
and any additional terms of use incorporated by reference into the Terms of
Use) applies to your use of:
Please read
the following carefully to understand our practices regarding your personal
data and how we will treat it.
This
privacy policy:
For the
purposes of this privacy policy:
2. Who we are
MSN
Lifepal, who owns, operates and manages the App, is the controller and is
therefore responsible for your personal data.
If you have
any questions or concerns regarding the collection and processing of your
personal data by us or if you wish to exercise any of your rights (as set out
in section 9 of this privacy policy), please do not hesitate to contact us
using the details set out below and we will be happy to provide you with a
response as soon as possible.
MSN Lifepal
takes the protection of your personal data very seriously. However, if you are
of the opinion that we have not dealt with your concerns adequately, you have
the right to submit a complaint to the Office of the Commissioner for Data
Protection in Cyprus or to the data protection supervisory authority of the
country in which you reside.
3. How we collect your personal data
We obtain
your personal data mainly through any information you provide directly to us or
through information we collect from your Device. Below is a list of ways in
which we collect your personal data:
4. The data we collect about you
We may
process the following personal data about you:
We also
collect, use and share Aggregated Data such as statistical
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 Profile
Data for scientific research purposes such as for example to identify whether
there are patterns in one’s health signalling the development of cancer.
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.
5. 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:
We provide
further details in connection to each legal basis on which we rely below, as
follows:
Performance
of a contract
When you
register as a new App user and agree to the Terms of Use, we will process your
personal data in order to:
Where we
need to collect personal data in accordance with our Terms of Use, and you fail
to provide that data when requested, we may not be able to provide the App
Services to you.
Legitimate
interests
We may
process your personal data on this basis in order to:
Legal
obligation
In certain
cases, we may need to retain your personal data in order to comply with our
legal obligations, such as our tax obligations.
Consent
We will
only request your consent in the following circumstances:
When you
provide us with medical information on the App, we will be processing special
categories of personal data. When we process such special categories of
personal data, we will need your prior explicit consent. If you do not give us
such consent, you will not be able to input the medical information that we
need in order to provide you with recommendations on whether to visit a doctor
or undertake a medical examination.
THIRD PARTY
MARKETING
We will get
your express opt-in consent before we share your personal data with any third
party for marketing purposes and/or before we provide you with any information
in connection to offers or promotions of third parties.
OPTING OUT
You can ask
us or third parties to stop sending you marketing messages at any time by
logging into the App and adjusting the marketing preferences on your profile or
by following the opt-out links on any marketing message sent to you or by
contacting us by using the contact details in section 2 above.
6. With whom we may share your personal
data
We may
share your personal data with third parties as listed below for the purposes
set out in section 5 above. When we do so, we request from such third parties
to have appropriate technical and organisational measures in place to protect
your personal data. We will not share any of your personal data for any purpose
other than the purposes described in this privacy policy.
INTERNATIONAL
TRANSFERS
Some of the
third parties we work with are based outside the European Economic Area (EEA)
so their processing of your personal data will involve a transfer of data
outside the EEA.
Whenever we
transfer your personal data out of the EEA, we ensure a similar degree of
protection is afforded to it by ensuring at least one of the following
safeguards is implemented:
7. Safeguarding your data
All
information you provide to us is stored on our secure servers.
Where we
have given you (or where you have chosen) a password for the App, you are
responsible for keeping this password confidential. Please do not share it with
anyone.
Unfortunately,
we cannot guarantee 100% protection against unauthorized access in the case of
data transfers across the internet, but we and our business partners do our
utmost to protect your personal data in line with the prevailing data
protection regulations by means of physical, electronic, and process-oriented
security precautions.
8. How long we keep your personal data
We will
only retain your medical information for as long as we have your consent. All
other personal data we have collected from you during your use of the App will
be retained for as long as you continue being a user of the App and, once your
account is terminated for any reason, for as long as we are required to do so
by law or for one or more of our business purposes, in accordance with the
retention criteria set out below.
To
determine the appropriate retention period for personal data, we consider the
amount, nature and sensitivity of the personal data, the potential risk of harm
from unauthorised use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes
through other means, and the applicable legal, regulatory, tax, accounting or
other requirements.
In some
circumstances, we will anonymise your personal data (so that it can no longer
be associated with you) for research purposes as described in section 4 above,
in which case we may use this information indefinitely without further notice
to you.
If you have
tried to register as a user on the App but have been unsuccessful (due to the
fact that you have not provided us with all the information we have requested
or you have not verified your email or you are not eligible to become a user or
for any other reason), we will delete any personal data you have provided to us
prior to registration (i.e. your email address) within ten (10) calendar days
from your unsuccessful attempt to register.
9. Your legal rights
You have
the following rights in terms of the personal data and information we hold
about you:
Receive
access to your personal data
This
enables you to receive a copy of the personal data we hold about you and to be
informed on how we are lawfully processing it.
Request
correction of the personal data we hold about you
This
enables you to have any incomplete, inaccurate or out of date information we
hold about you corrected. You can do this yourself by updating your personal
data on your account profile in the App.
Request
erasure of your personal data
This
enables you to ask us to delete or remove personal data where there is no good
reason for us continuing to process it. You also have the right to ask us to
delete or remove your personal data where you have successfully exercised your
right to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your personal data to
comply with local law. Note, however, that we may not always be able to comply
with your request of erasure for specific legal or contractual reasons which
will be notified to you, if applicable, at the time of your request. You may
request your data to be deleted by contacting us at info@lifepal.app.
Object to
processing of your personal data
You can
object to the processing of your personal data where we are relying on a
legitimate interest (or those of a third party) and there is something about
your particular situation which makes you want to object to processing on this
ground as you feel it impacts on your fundamental rights and freedoms. You also
have the right to object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and
freedoms.
Request the
restriction of processing of your personal data
This
enables you to ask us to suspend the processing of your personal data in the
following scenarios:
The right
to ‘data portability’
Where you
request a transfer of your personal data, we will provide to you, or a third
party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated
information which you initially provided consent for us to use or where we used
the information to perform a contract with you.
Withdraw
your consent
In cases
where you have given your consent to us, you will be able to withdraw that
consent at any time. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide the App Services as described in this
privacy policy and in the Terms of Use. We will advise you if this is the case
at the time you withdraw your consent.
10. How to exercise your rights
To exercise
any of your rights as set out in section 9, you can use the contact details set
out in section 2 above.
For
security reasons, we may need to request specific information from you to help
us confirm your identity and ensure your right to access to your personal data
(or to exercise any of your other rights). We may also contact you to ask you
for further information in relation to your request to speed up our response.
11. Third Party links
Our App
may, from time to time, contain links to and from the websites of our partner
networks and/or advertisers. Please note that these websites and any services
that may be accessible through them have their own privacy policies. We do not
accept any responsibility or liability for these third-party privacy policies
or for any personal data that may be collected through these websites or
services. Please check these policies before you submit any personal data to
these websites or use these services.
12. Children
We do not
intend to solicit or collect personal data from anyone under the age of
eighteen (18). If you are under eighteen (18), do not enter information on the
App or engage the App Services. If you believe a child of yours under the age
of eighteen (18) has entered personal data, please contact us using the contact
details in section 2 above to have the data removed and terminate the child’s
account.
13. Changes to our privacy policy
and your duty to inform us of changes
We keep our
privacy policy under regular review. This version of the privacy policy was
last updated on the 8th of April 2021.
If we
update our privacy policy in the future, the changes will be posted on the App
and, where appropriate, notified to you either by email or when you next start
the App. 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 App
Services.
We do
however encourage you to review this policy periodically so as to be always
informed about how we are processing and protecting your personal
information.
It is
important that the personal data we hold about you is accurate and current.
Please keep us informed of your personal data changes during our relationship
with you.