PRIVACY POLICY

Welcome to Appy, a service provided by Appy Limited (us and we). We are committed to protecting and respecting your privacy. 

We offer online services through our site located at www.weareappy.com (the “Site”) and our mobile application Appy (the “App”) (collectively, the “Services”). This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and stored by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our Services and otherwise providing data to us you are accepting and consenting to the practices and our use of your personal data as described in this Policy. 

For the purpose of the Data Protection Act 2018 (the “Act”), the data controller is Appy Limited, 61 International House, Mosley Street, Manchester M2 3HZ.  


INFORMATION WE MAY COLLECT FROM YOU 

By personal data we mean identifiable information about you. Generally, this is likely to include information such as your name, email address, geographical postcode, mobile and home telephone number and your IP address.

We may collect and process the following data about you: 

Information you give us 

• You may give us information about you by filling in forms, either via registering to become a member of Appy or otherwise, via the interactive functions offered by our Services, or by corresponding with us by phone, email, social media or otherwise. This includes information which you provide when you register to use our Services, participate in discussion boards, use other social media functions on our Services, enter a competition, promotion or survey, download content from our Services and when you report a problem with our Services. 

• The information you give us may include your name, postcode, email address and phone number, personal description and photograph, username, password, your device’s phone number and your date of birth. Certain personal data is mandatory to be provided to us in order that we can fulfil your request, for example to register with us, and we shall make this clear to you at the point of collection of the personal data. We will have to use some of this information in order to provide our Services to you when you subscribe to Appy. This includes your name, age, email address and other information. 

• You may also give us information regarding your general health and fitness status, details of any medical conditions or injuries, food likes and dislikes, your nutritional requirements, details of your health and wellbeing goals, details of your alcohol consumption and smoking habits, details of your level of self-esteem and body image and general health, fitness and wellbeing areas of interest. We will use and process such ‘special personal data’ only when you have given your explicit consent to our doing so. 

• You may choose to create a more detailed profile of yourself when submitting basic registration information to use our Services. Your profile is available to all other users of the Services. So, even if you do not choose to include personal information in your profile, if your username includes or reveals your name or any other personal information, then this will be available to other users of our Services. 

Other Information we collect about you 

With regard to each of your visits to and/or use of our Services we may automatically collect the following information: 

• technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your device’s IMEI number, the MAC address of your device’s wireless network interface or its mobile number, mobile network information, operating system, browser type and version, browser plug-in types and versions, operating system and platform; 

• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Services (including date and time), content you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), methods used to browse away from the page and any phone number used to call our customer service number (if applicable).  We only use this information on an anonymous basis for research and analysis.  

Location information 

• We may also use GPS technology or Foursquare to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by contacting us at info@weareappy.com or within your settings on your mobile device. 

Information shared with advertisers 

• We will not sell your personal data to advertisers nor will we share any personal data that directly identifies you (such as your name, email address or other contact information) with advertisers without your prior permission. We may, however, share personal data that does not directly identify you (such as your age and bodyweight goals) with advertisers, so that they can show you advertisements that may be of interest to you, and will provide advertisers with reports about advertisement performance and interaction.     

Information we receive from other sources 

• We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers) and may receive information about you from them. 

• We may, at our sole discretion, allow you to create, authorise and sign into an account on our Services using a third-party platform such as Facebook, Twitter, LinkedIn, Stackoverflow, Github and any other platform or social media service from time to time. By using those third-party services to do so, you understand that we will have access to certain personal data within your accounts on those platforms.

A full data deletion request can be sent to info@weareappy.com


COOKIES 

Our Services use cookies to distinguish you from other users. This helps us to provide you with a good experience when you use our Services and also allows us to improve them. For more detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy


USES MADE OF THE INFORMATION 

We will only use your personal data where we have a lawful basis to do so. The lawful purposes that we rely on under this Privacy Policy are:  

• consent (where you choose to provide it);

• performance of our contract with you; 

• compliance with legal requirements; and 

• legitimate interests. When we refer to legitimate interests, we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.

We therefore use information held about you in the following ways: 

Information you give to us 

We will use this information: 

• to manage your account; 

• to provide you with information about other services we offer that are similar to those that you have already subscribed to or enquired about; 

• to notify you about changes or improvements to our Services; 

• to ensure that content from our Services is presented in the most effective manner for you and for your device; 

• on an anonymous basis, for research purposes and for our general business purposes. 

Information we collect about you 

We will use this information: 

• to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; 

• to improve our Services to ensure that content is presented in the most effective manner for you and for your device; 

• to allow you to participate in interactive features of our Services, when you choose to do so; 

• as part of our efforts to keep our Services safe and secure; 

• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; 

• to make suggestions and recommendations to you about goods or services that may interest you in accordance with the Marketing section below. 

Information we receive from other sources 

We may combine information we receive from other sources with information you give to us and information we collect about you. We may use information we receive from other sources and the combined information for the purposes set out above (depending on the types of information we receive). 


MARKETING 

When you register to use our Services, you will be given the opportunity to consent to receive marketing communications from us. You can choose to no longer receive marketing communication from us by updating your account settings or contacting us at info@weareappy.com. We shall therefore retain your personal data in our records for marketing purposes until you notify us that you no longer wish to receive marketing communications from us. If you still have an account with us, we shall continue to contact you in relation to your account only.


DISCLOSURE OF YOUR INFORMATION 

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. 

We may share your information with selected third parties including: 

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you and we shall use our efforts to procure that such third parties only use your personal data in accordance with our instructions and applicable laws; 

• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others unless you adjust your settings on your mobile device; and 

• Analytics and search engine providers that assist us in the improvement and optimisation of our Services. 

We may disclose your personal information to third parties: 

• 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 Appy Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will 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 our Terms of Use and other agreements, or to protect the rights, property, or safety of Appy Limited, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection. 


WHERE WE STORE YOUR PERSONAL DATA 

The data that we collect from you may be transferred to, and stored at, a destination outside Kingdom and/or the European Economic Area (“EEA”). It may also be processed by staff operating outside the United Kingdom and/or EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. 


SECURITY 

We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal data from unauthorized access and disclosure. In particular, all information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; 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. 


YOUR RIGHTS 

You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here

• Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.

• Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date. 

• Right to portability: You can request that we transfer your personal data to another service provider if you initially provided consent for us to use the personal data or where we used the personal data to perform a contract with you.

• Right to restrict or object to processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information, if you believe our processing impacts on your fundamental rights and freedoms. However, we may demonstrate that we have legitimate grounds to process your personal data not withstanding your rights and freedoms.

• Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it.  However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws and when we respond to your request we shall notify you of any specific legal reasons that we have to retain your personal data.

• Right to stop receiving marketing information: You can ask us to stop sending you information about our services, but please note we shall continue to contact you in relation to any matters relating to your account, if you have one.

We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.

If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time. You do also have the right to contact the Information Commissioner, see www.ico.org.uk or, if you are based outside of the United Kingdom, please contact your local regulatory authority

RETENTION OF PERSONAL DATA

Subject to the provisions of this Privacy Policy, we will retain personal data in accordance with applicable laws. 

In particular, we shall retain your personal data for as long as you access or use our Services. However, we may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents.

Where we have no legal basis for continuing to process your personal data, we shall either delete or anonymise it 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.


THIRD PARTY LINKS 

Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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 before you submit any personal data to these websites.  


CHANGES TO OUR PRIVACY POLICY 

Any changes we may make to our Privacy Policy in the future will be posted on this page. You are responsible for regularly reviewing this Policy so that you are aware of any changes to it. 


CONTACT 

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to info@weareappy.com


Last modified 14/09/20