Privacy Policy

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique Account created for You to access our Service or parts of our Service.

Application means the software program provided by us downloaded by You on any electronic Device, named Nudg.

Controller refers to the company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any Device that can access the Service such as (but not limited to) a computer, a mobile/cell phone or a digital tablet. Personal Data, means any information relating to You such as a name, an identification number, location data, online identifier.

Service refers to the Application.

Service Provider means any natural or legal person who processes the data on our behalf. It refers to third-party companies or individuals employed by us to facilitate the Service, to provide the Service on our behalf, to perform Services related to the Service or to assist us in analysing how the Service is used.

Health Data or Fitness Data refers to data such as Blood Glucose, Heart Rate, Active/Basal Energy, Blood Pressure, Weight, Height, Respiratory Rate, Sleep, which are collected via native phone services such as Apple Health and/or third party cloud services such as Dexcom API, and GoogleFit, after explicit consent from You.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of Application usage).

You the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. You can be referred to as the Data Subject or as the User as You are the individual using the Service.

We take Your information seriously. This policy:

• sets out the types of information that we collect;
• explains how and why we collect and use Your information;
• explains for how long we keep Your information;
• explains when, why and with whom we will share Your information;
• sets out the lawful basis we have for using Your information;
• explains the effect of refusing to provide the information requested;
• explains whether we make automated decisions concerning You;
• sets out the cookies we use to collect personal data about You;
• explains whether we transfer Your information outside of the United Kingdom or the European Economic Area;
• explains the different rights You have when it comes to Your information; and
• explains how You can contact us.

The information we will receive about You includes:

• Your contact details, specifically, Your name, mobile / home phone number, email address, telephone number, home address and postcode;
• Your age and date of birth;
• Your gender;
• Health data such as Blood Glucose, Heart Rate, Active/Basal Energy, Blood Pressure, Weight, Height, Respiratory Rate, Sleep. which are collected via native phone services such as Apple Health and/or third party cloud services such as Dexcom API, and GoogleFit, after explicit consent from You.
• Your location and Your usage of the Application.

We Pseudonymise all information about You that we collect. This means that we process your information in such a way that it is no longer possible to identify You from the information we collect. We keep all information about you separate and protected.

All data collected by the application is done so only with the user's explicit permission which is needed upon installation on their mobile device. All data that is transferred from the user's device to our servers is encrypted in transit. Loved By Ltd's servers are from an approved list of services found on the UK governments digital marketplace ensuring security compliance (using AWS). All personally identifiable (names, addresses, contact info, social media details) data are stored and encrypted in another location which operates with more secure and stricter access. The personally identifiable data is connected to a unique primary key which is used to ensure individual data does not get cross contaminated. The use of these primary keys ensures Loved By Ltd can purge any data linked to a single user upon their request.

Information You give us

• You give us information about You when You contact us or otherwise interact with us, including via our website, Application, e-mail, letter, phone call or social media.
• You give us information about You when You register via our website or the Application to create an Account and/or to receive any kind of communication or updates from us.

Information we collect automatically

We collect certain information by automated means, such as cookies and web beacons, whenever you visit our website or the Application. This could include IP address, browser type, operating system, referring URLs, information on actions taken on our website, and dates and times of website visits. You can find more information about our use of cookies in our Cookie Policy Cookie Policy.

We may use Personal Data for the following purposes:

To provide a requested service or carry out a contract with you

• To perform any contract entered into between You and us, including to register and manage Your Account and to manage Your registration as a user of the Service. The personal data You provide can give You access to different functionalities of the Service that are available to You as a registered user, such as personalised content.

Where we have your consent

• To contact You, including by email, SMS and telephone or other equivalent forms of electronic communication, such as the Application's push notifications, to send You marketing communication or updates from us, including our newsletters. This is where You have given us Your consent to receiving our updates. We will contact You according to your preferences and You can opt-out of receiving these communications at any time. You can opt out at any time by contacting us, using the details set out at the end of this Privacy Policy in the "How can You contact us" section.
• Should the purpose of data collection change, You will be informed and Your consent will be re-obtained to cover the new data processing activity.

Where we have a legitimate interest

• To investigate and address enquiries, questions and complaints and respond to any feedback.
• To compile statistics about the behaviour of our website visitors and other users of our services.
• To contact You, including bt email, SMS and telephone or other equivalent forms of electronic communication, such as the Application's push notifications, regarding updates or informative communications related to the functionalities, products or services, including the security update, when necessary or reasonable for their implementation.
• To maintain and enhance the safety, security, and stability of our Services by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity). You can report such
• To assist in the effective resolution of disputes.
• To develop and improve our engagement with you.
• To ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.
• To contact you, including by post, telephone and/or in person, to provide you with marketing communications or updates from us, including our newsletters. We will contact you according to your preferences (including the mail preference services and telephone preference services) and you can opt-out of receiving these communications at any time.
• To enforce any agreement, we have in place with you, or to protect the rights, property, safety, or security of the Application, third parties, users of our Services or the public.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our Service users is among the assets transferred.

We use your information where this is necessary to achieve legitimate interests - whether belonging to us, you, or a third party - provided these interests are not outweighed by your interests or fundamental rights and freedoms.

Where we have a legal obligation

• Where we are under a duty to process your information, in order to comply with (and/or where we reasonably believe we are under a duty to comply with) any legal obligation.

While using our Application, in order to provide features of our Application, we may collect, with Your prior permission:

• Information regarding Your location

  We use this information to provide features of our Service, to improve and customise our Service. The information may be uploaded to our servers and/or a Service Provider's servers or it may be simply stored on Your Device. You can enable or disable access to this information at any time, through Your Device settings.

• Apple Health / Google Fit

  We use this information to provide features of our Service, to improve and customise our Service. The information may be uploaded to the our servers and/or a Service Provider's servers or it may be simply stored on Your Device. You can enable or disable access to this information at any time, through Your Device settings.

• Age

  You must be at least 13 years old to use the Application and Services. If you believe that we have information about someone younger than this, please contact us via the details set out in the "How to contact us" section below.

  We will not use Your information for any other purposes unless we are required to do so by law.

Your information will only be retained for as long as is necessary.

We will retain Your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

When determining the relevant retention periods, we will take into account factors including:

1. our contractual obligations and rights in relation to the information involved;
2. legal obligations under applicable law to retain data for a certain period of time;
3. our legitimate interests where we have carried out a balancing test;
4. statute of limitations under applicable laws;
5. (potential) disputes;
6. if you have made a request to have your information deleted; and
7. guidelines issued by relevant data protection authorities.

Otherwise, we securely erase or anonymise your information where we no longer have a legitimate reason for keeping it.

We will also retain Usage Data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

• With Service providers: we may share Your personal information with Service providers, for example to monitor and analyse the use of our Service.
• For business transfers: We may share or transfer Your personal 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.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Occasionally we embed links, video, audio and pictures from other websites such as YouTube, Instagram. When this embedded content is accessed via the Application, the owner of that website may use their own Privacy Policy, Terms and Conditions, Cookies to record that you watched or viewed the content. We have no control over and are not responsible for these cookies so you should check the relevant website for their Privacy Policy, Terms and Conditions and Cookie Policy for more information. Once you access any embedded links outside of our application/service our Privacy Policy, Terms and Conditions and Cookie Policy no longer applies.

To provide better service to You on our website, we use cookies to collect Your personal data when You browse our website. See our Cookie Policy for more details.

We carry out automated decision-making, including profiling (i.e. analysing or predicting your behaviour based on your information). We do not make decisions about you based solely on automated processing. You agree when you give your consent to us carrying out automated decision-making and profiling. You have the right to withdraw Your consent at any time, to withdraw your consent please Contact Us (See the "How can You contact us" set out at the end of this Privacy Policy), and/or by deleting your account, you can do this by going to settings, click delete account and follow the online screen instructions.

Where possible, we try to only store and process Your information within the UK and European Economic Area (EEA). Data collected by the Application is encrypted both while in storage and when transmitted from Your device. If we or any third party transfers Your information outside of the UK or EEA, we always require that appropriate safeguards are in place to protect the information when it is processed. If we intend to transfer your information to any third countries, we will update this privacy policy to reflect such overseas transfers.

By law, You have a number of rights when it comes to Your information.

The right to object to processing

You have the right to object to certain types of processing, including processing for direct marketing (if applicable).

The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your information and Your rights. This is why we're providing you with the information in this privacy policy.

The right of access

You have the right to obtain access to Your information (if we're processing it), and certain other information (similar to that provided in this privacy policy). This is so you're aware and can check that we're using Your information in accordance with data protection law.

The right to rectification

You are entitled to have Your information corrected if it's inaccurate or incomplete.

The right to erasure

This is also known as "the right to be forgotten" and, in simple terms, enables You to request the deletion or removal of Your information where there's no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

The right to restrict processing

You have rights to "block" or suppress further use of your information. When processing is restricted, we can still store Your information, but may not use it further. We keep lists of people who have asked for further use of their information to be "blocked" to make sure the restriction is respected in future.

The right to lodge a compliant

You have the right to lodge a complaint about the way we handle or process Your personal information with Your national data protection regulator. See details of the UK data protection regulator set out at the end of this Privacy Policy in the "How can You contact us?" section below.

The right to withdraw consent

If You have given Your consent to anything we do with Your personal information, You have the right to withdraw Your consent at any time (although if You do so, it does not mean that anything we have done with Your personal information with Your consent up to that point is lawful). This includes Your right to withdraw consent to us using Your personal information for marketing purposes.

To exercise any of Your rights in relation to Your information, or to ask a question, contact us using the details set out at the end of this Privacy Policy in the "How can You contact us" section. We'll respond as soon as we can. Generally, this will be within one month from when we receive Your request but, if the request is going to take longer to deal with, we will let You know. We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

• excessive or repeated requests, or
• further copies of the same information.

If you have any questions on the processing of Your information, would like to exercise any of Your rights, or are unhappy with how we've handled Your information, please contact us via email at support@nudg.com.

Alternatively, You may also write to us at:
71-75 Shelton Street, London, Greater London, United Kingdom, WC2H 9JQ

If You're not satisfied with our response to any complaint or believe our processing of Your information does not comply with data protection law, You can make a complaint to the relevant data protection regulator. In the UK, this is via the Information Commissioner's Office (ico.org.uk).