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Longevity App Privacy Policy

Last Updated: March 3rd 2023

INTRODUCTION

This privacy policy applies between you, the user of Rejuve Application and Rejuve Network (or Rejuve.AI), the owner and provider of Longevity Application. Rejuve Network takes the privacy of your information very seriously. The privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the application.

WHAT IS AN APP PRIVACY POLICY?

A mobile app privacy policy is a legal statement that discloses how a party gathers, stores, and uses the personal or Sensitive Personal information it collects from app users. Personal information refers to anything that can be used to identify an individual, including names, phone numbers, email addresses, device IDs, and locations. Sensitive Personal information refers to information pertaining to one’s racial or ethnic makeup, political stances, religious beliefs, trade union membership, health conditions, sexual orientation, criminal files and court proceedings, biometric data, and genetic data.
 

These policies are used by companies and mobile app developers to stay compliant with federal laws. They fulfil the legal requirement to safeguard user privacy while also protecting the company itself from legal challenges.

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We, Rejuve.AI, reserve the right to make changes to this Privacy Policy at any time and for any reason.  We will alert you about any changes by updating the “Last updated” date of this Privacy Policy.  You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Rejuve App after the date such revised Privacy Policy is posted. 

COLLECTION OF YOUR INFORMATION

We may collect information about you in a variety of ways. The information we may collect via the Longevity App depends on the content and materials you use, and includes: 

PERSONAL DATA

Demographic and other personally identifiable information (such as your name and email address) that you voluntarily give to us when choosing to participate in various activities related to Longevity, such as creating an account, completing health inventories and questionnaires, sending feedback, or participating in our research program.

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The following personal / sensitive data may be collected by Longevity:

1. USER DATA:

Data Type
Details
Email
User’s email address
Origin
From which app users creates account from
Username
Name of user
Phone number
Users phone number

2. HEALTH PROFILE::

Data Type
Details
Username
Gender
Birthday
Height
Device Connections
Health tracker/wearable devices the user has connected to the app

3. PRE-EXISTING HEALTH CONDITIONS:

Data Type
Details
Username
Type
Health condition type
Condition
Condition

4. USER ACTIVITY:

Data Type
Details
Username
Activity Title
Such as account created if survey taken
Activity Type
Such as survey name if survey taken
Description
Description of activity

5. EXTERNAL LONGEVITY APP DATA:

Data Type
Details
Username
Rejuve App
Type of device [FITBIT, APPLE WATCH, HEALTHKIT]
Data Type
Data type such as Heart rate, Steps, Calories etc.
Data
Data values processed/formatted
Raw Data
Data values before processed/formatted

6. DEVICE PUSH NOTIFICATION:

Data Type
Details
Username
Device Id
ID of user’s mobile device to send notifications
Platform
User’s device platform

7. SURVEY ANSWERS:

Data Type
Details
Username
Survey ID
ID of survey taken
Submission ID
Submission ID of taken survey
Question ID
Question ID
Answer
Respective answer to the Question ID

8. BAYES NET RESULTS:

Data Type
Details
Submission ID
Submission ID of taken survey
Request ID
Result ID of survey taken
Username
External Service ID
From which service the result comes from
Distribution States
Bayes net states based on user’s answers
Out Variable ID’s
Bayes net output variable ID’s
Explain variable ID’s
Bayes net explain variable ID’s
Reverse explain variable ID’s
Bayes net reverse explain variable ID’s
Reverse evidence variable ID’s
Bayes net reverse evidence variable ID’s
Anomalies
Bayes net anomalies input
Variable Answers
Output from Bayes net
Explanations
Output from Bayes net
Risk Level
Calculated risk level from Bayes net output
User Insights
Calculated user insights from Bayes net output
Goals
Calculated goals from Bayes net output

9. DEVICE CONNECTIONS (WEARABLES) DATA:

Data Type
Details
Daily activity summary
Daily activity summary
Get frequent activity
User frequent activities
Body Fat
Body fat logs, body goals, time series data
BMI
BMI time series
Body Weight
Body weight logs, time series data
Food
Food goals, recent foods, frequent foods, favorite food, time series
Water
Water goal, time series
Heart Rate
Time series – period/intra-day
Sleep
Sleep logs, sleep goals
Activity – Calories
Time series – period/intra-day
Activity – Calories BMR
Time series – period/intra-day
Activity – Distance
Time series – period/intra-day
Activity – Floors
Time series – period/intra-day
Activity – Elevation
Time series – period/intra-day
Activity – Minutes Sedentary
Time series – period/intra-day
Activity – Minutes lightly active
Time series – period/intra-day
Activity – Minutes fairly active
Time series – period/intra-day
Activity – Minutes sedentary
Time series – period/intra-day
Activity – Minutes sedentary
Time series – period/intra-day

DERIVATIVE DATA  

Information our servers may automatically collect when you access the Longevity App, such as your native actions that are integral to the App.  

FINANCIAL DATA 

Financial information, such as data related to your payment method (e.g., valid credit card number, card brand, expiration date) may be collected by our partners when you purchase, order, return, exchange, or request information about our services from the Longevity App. You are encouraged to review their privacy policy and contact them directly for responses to your questions.

DATA FROM SOCIAL NETWORKS 

User information from social networking sites, such as [Apple’s Game Centre, Facebook, Google+ Instagram, Twitter], including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. This information may also include the contact information of anyone you invite to use and/or join Longevity.

GEO-LOCATION INFORMATION 

We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Longevity App, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

MOBILE DEVICE ACCESS 

We may request access or permission to certain features from your mobile device, including your mobile device’s e.g: Bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

MOBILE DEVICE DATA

We may collect device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.

PUSH NOTIFICATIONS

We may request to send you push notifications regarding your account or the Longevity app. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings or within the App settings.

DATA FROM CONTESTS, GIVEAWAYS, AND SURVEYS 

Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

USE OF YOUR INFORMATION

Having accurate information about you permits us to provide you with a smooth, efficient, and customised experience. Specifically, we may use information collected about you via the Longevity app to:

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  1. Administer health surveys

  2. Compile anonymous statistical data and analysis for use internally (or with third parties with your consent). 

  3. Create and manage your account.

  4. Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Longevity app to you. 

  5. Email you regarding your account or order.

  6. Enable user-to-user communications.

  7. Fulfil and manage purchases, orders, payments, and other transactions related to the Longevity App.

  8. Generate a personal profile about you to make future visits to the Longevity App more personalised.

  9. Increase the efficiency and operation of the Longevity App.

  10. Monitor and analyse usage and trends to improve your experience with the App.

  11. Notify you of updates to the App.

  12. Offer new products, services, mobile Rejuve.AI apps, and/or recommendations to you.

  13. Perform other business activities as needed.

  14. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.

  15. Process payments and refunds.

  16. Assist law enforcement and respond to subpoena.

  17. Request feedback and contact you about your use of the App. 

  18. Resolve disputes and troubleshoot problems.

  19. Respond to product and customer service requests.

  20. Send you a newsletter.

  21. Solicit support for the Longevity App.

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows: 

BY LAW OR TO PROTECT RIGHTS 

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

THIRD-PARTY SERVICE PROVIDERS 

With your consent, we may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance. 

MARKETING COMMUNICATIONS

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

INTERACTIONS WITH OTHER USERS 

If you interact with other users of the Longevity App, those users may see your name, profile photo, and descriptions of your activity, including sending invitations to other users, chatting with other users, liking posts, following blogs.

THIRD-PARTY ADVERTISERS

We may use third-party advertising companies to serve ads when you visit the Longevity App. These companies may use information about your visits to the App and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you. 

AFFILIATES

We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us. We will not share any personal information, including medical information, without your consent.

BUSINESS PARTNERS 

We may share your information with our business partners to offer you certain products, services or promotions. We will not share any personal information, including medical information without your consent

OFFER WALL

The Longevity App may display a third party-hosted “offer wall.”  Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for acceptance and completion of an advertisement offer.  Such an offer wall may appear in the App and be displayed to you based on certain data, such as your geographic area or demographic information.  When you click on an offer wall, you will leave the Rejuve App.  A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account.    

SOCIAL MEDIA CONTACTS  

If you connect to the Longevity App through a social network, your contacts on the social network may see your name, profile photo, and descriptions of your activity.

SALE OR BANKRUPTCY 

If we reorganise or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity.  If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honour commitments we made in this Privacy Policy.

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We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

RACKING TECHNOLOGIES

COOKIES AND WEB BEACONS

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Longevity App to help customise the App and improve your experience. When you access the Longevity App, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the App. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

INTERNET-BASED ADVERTISING

Additionally, we may use third-party software to serve ads on the Longevity App, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimise your online experience with us. For more information about opting-out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

WEBSITE ANALYTICS 

We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Longevity App through the use of cookies, to analyze and track users’ use of the App, determine the popularity of certain content, and better understand online activity. By accessing the Longevity App, you consent to the collection and use of your information by these third-party vendors. We do not transfer personal information to these third-party vendors. 

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You should be aware that getting a new phone, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

THIRD PARTIES

The Longevity App may contain links to third-party websites and Apps of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the App, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or Apps that may be linked to or from the Longevity App.

SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information.  While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorised parties. Therefore, we cannot guarantee complete security if you provide personal information.

POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 17. If you become aware of any data we have collected from children under age 17, please contact us using the contact information provided below.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems [including our mobile Apps] 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. 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 Policy.

OPTIONS REGARDING YOUR INFORMATION

ACCOUNT INFORMATION

You may at any time review or change the information in your account or terminate your account by:

  • Logging into your account settings and updating your account

  • Contacting us using the contact information provided below

  • [Other]

Upon your request to terminate your account, we will deactivate and/or delete your account and information from our active databases in a secure manner. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.]

EMAILS AND COMMUNICATIONS

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:

  • Noting your preferences at the time you register your account with the Longevity App

  • Logging into your account settings and updating your preferences

  • Contacting us using the contact information provided below

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

HEALTH & HEALTH RESEARCH POLICY FOR APPLE USERS

Health, fitness, and medical data are especially sensitive and apps in this space have some additional rules to ensure privacy for you as a customer, is protected:

  •  The Longevity App does not use or disclose to third parties’ data gathered in the health, fitness, and medical research context, including from the Clinical Health Records API, HealthKit API, Motion and Fitness, Movement Disorder APIs, or health-related human subject research. For advertising, marketing, or other use-based data mining purposes other than improving health management, or for the purpose of health research, with user consent. We may, however, use your health or fitness data to provide a benefit directly to you, provided that the app is submitted by the entity providing the benefit, and the data will not be shared with a third party. We shall disclose the specific health data that you are collecting from the device.

  •  The Longevity App will not write false or inaccurate data into HealthKit or any other medical research or health management apps and will not store personal health information in iCloud.

  •  Rejuve.AI will conduct health-related human subject research only if your consent is obtained, or, in the case of minors, their parent or guardian. Such consent will include the (a) nature, purpose, and duration of the research; (b) procedures, risks, and benefits to the participant; (c) information about confidentiality and handling of data (including any sharing with third parties); (d) a point of contact for participant questions; and (e) the withdrawal process.

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The App will ensure that health-related human subject research secures approval from an independent ethics review board (IRB). Proof of such approval will be provided upon request.

HEALTH & HEALTH RESEARCH POLICY FOR ANDROID USERS

All apps that are listed on the Play Store are required to follow Google’s Developer Program Policies, as well as the Developer Distribution Policies.

Google does not currently place specific restrictions on health apps. However, the Privacy and Security section of their developer program policies requires specific steps for handling sensitive information which Rejuve.AI adheres to.

Google includes the following types of data as personal and sensitive info:

  • Personally identifiable information

  • Financial and payment information

  • Authentication information (signup/login data)

  • Phonebook or contact data

  • Microphone and camera sensor data

  • Sensitive device data

With this information in mind, we ensure the below requirements are met:

A PRIVACY POLICY IS PROVIDED

As we handle personal and sensitive user data, we post a privacy notice in the Play Developer Console, as well as in the app that is submitted to the Play Store.

The privacy, together with any in-app disclosures, comprehensively discloses how your app collects, uses and shares user data, including the types of parties with whom it’s shared.

HTTPS IS APPLIED

As we handle personal and sensitive user data, we securely manage it and transmit it securely using SSL/TLS.

WE EXPLAIN USE OF UNRELATED DATA

We prominently display how user data is used and get user consent for any data that is used that is unrelated to the listing on the Play Store. 

Google Play Store policies do not account for regulatory requirements dictated under HIPAA or FDA medical device classifications. We therefore ensure that any regulations that apply to the App are adhered to. See below sections for our Policy in regard to GDPR.
https://developers.google.com/terms/api-services-user-data-policy

GOOGLE API SERVICES

The Longevity App may utilize Google API Services, with Users’ permission (for example to sync Wearables data from Google Fit with the App). The App’s use and transfer of information received from Google APIs to Rejuve.AI’s database or any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

OUR GDPR POLICY

​The policy sets out how Rejuve Network seeks to protect personal data and ensure that staff understand the rules governing their use of personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.

​GDPR PROCEDURES

Fair and lawful processing – We process personal and sensitive data fairly and lawfully in accordance with individuals’ rights. Our processes are designed to maintain company compliance with current personal data protection law and regulation. The Data Protection principles we follow are that Personal data shall be:

  • Processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)

  • Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’)

  • Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)

  • Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased, or rectified without delay (‘accuracy’)

  • Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’)

  • Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

RESPONSIBILITIES OF THE DATA PROTECTION OFFICER

The data protection officer shall have at least the following tasks:

  • Inform and advise employees who carry out processing of their obligations pursuant to Data Protection Regulation and other relevant data protection provisions.

  • Monitor compliance with Data Protection Regulation and the policies of the company in relation to the protection of personal data, including the assignment of responsibilities, awareness-raising and training of staff involved in processing operations, and the related audits.

  • Provide advice where requested as regards the data protection impact assessment and monitor its performance.

  • Provide the point of contact for the GDPR regulator and data subjects.

RESPONSIBILITIES OF THE IT MANAGER

  • To ensure appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

  • To ensure appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

RESPONSIBILITIES OF THE MARKETING MANAGER

  • Approving data protection statements attached to emails and other marketing copy

  • Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy

SENSITIVE PERSONAL DATA

  • In most cases where we process sensitive personal data, we will require the data subject’s explicit consent to do this unless exceptional circumstances apply, for example, where we are required to do this by law. Any such request for consent will need to clearly identify what the data is, why it is being processed and to whom it will be disclosed.

ACCURACY AND RELEVANCE

​We will ensure that any personal data we process is accurate, adequate, relevant, and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

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Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO.

YOUR PERSONAL DATA

You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform the Data Protection Officer so that they can update your records.

DATA SECURITY

You must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third-party organisations.

STORING DATA SECURELY

  • In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it

  • Printed Personal data must not be left unattended or in view and data should be shredded when it is no longer needed. When not in use, printed or hard copies of Personal data must be stored in a secure environment.

  • Data stored on a computer should be protected by strong passwords (please refer to the information security policy).

  • Data stored on CDs or memory sticks must be locked away securely when they are not being used

  • The DPO must approve any cloud used to store data

  • Servers containing personal data must be kept in a secure location, away from general office space

  • Data should be regularly backed up in line with the company’s backup procedures

  • Data should never be saved directly to mobile devices such as laptops, tablets, or smartphones

  • All servers containing sensitive data must be approved and protected by security software and a strong firewall.

DATA RETENTION

Personal data may only be retained based on a ‘current’ lawful basis and legitimate purpose. We must retain personal data for no longer than is necessary.

TRANSFERRING DATA INTERNATIONALLY

There are restrictions on international transfers of personal data. We must not transfer personal data of UK citizens anywhere outside the UK without first consulting the Data Protection Officer.

SUBJECT ACCESS REQUESTS

Please note that under the General Data Protection Regulation, individuals are entitled, subject to certain exceptions, to request access to information held about them.

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If you receive a subject access request, you should refer that request immediately to the DPO. We may ask you to help us comply with those requests.

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Please contact the Data Protection Officer if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law.

PROCESSING DATA IN ACCORDANCE WITH THE INDIVIDUAL’S RIGHTS

  • We will abide by any request from an individual not to use their personal data for direct marketing purposes and notify the DPO about any such request.

  • We will not send direct marketing material to someone electronically (e.g., via email) unless there is an existing business relationship with them in relation to the services being marketed.

  • Please contact the DPO for advice on direct marketing before starting any new direct marketing activity.

  • All staff will receive training on this policy. Further training will be provided at least every six months or whenever there is a substantial change in the law or our policy and procedure.

PRIVACY NOTICE – TRANSPARENCY OF DATA PROTECTION

Being transparent and providing accessible information to individuals about how we will use their personal data is important for our organisation. The following is the information that every privacy notice needs to include:

  • Identity and contact details of the controller, their representative or the Data Protection Officer

  • Purpose and lawful basis for processing

  • Legitimate interests of the controller and third party, where applicable

  • The categories of data held (not required if data came from the subject)

  • Any recipient or categories of recipients of the personal data

  • Details of transfers to third countries and safeguards

  • Retention period or criteria used to determine the retention period of the data

  • The existence of each of the data subjects’ rights

  • The right to withdraw consent at any time, where relevant

  • The right to lodge a complaint with a supervisory authority

  • The source of the personal data and whether it came from publicly accessible sources (not required if data came from the subject)

  • Whether the personal data is part of a statutory or contractual requirement or obligation and possible consequences of failing to provide the personal data

  • The existence of automated decision making, including profiling, and information about how decisions are made, the significance and the consequence 

CONDITIONS FOR PROCESSING

We will ensure any use of personal data is justified using at least one of the lawful conditions for processing and this will be specifically documented. All staff who are responsible for processing personal data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice.

JUSTIFICATION FOR PERSONAL DATA

We will process personal data in compliance with all six data protection principles.

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We will document the additional justification for the processing of sensitive data.

CONSENT

The personal data that we collect is subject to a positive action by the subject, which needs to be documented, to validate that ‘Consent’ is the lawful basis for processing that personal data. Consent can be revoked by the subject at any time.

CRIMINAL RECORD CHECKS

Any criminal record checks are justified by law. Criminal record checks cannot be undertaken based solely on the consent of the subject.

DATA PORTABILITY

Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.

RIGHT TO BE FORGOTTEN

A data subject may request that any information held on them be deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.

PRIVACY BY DESIGN AND DEFAULT

Privacy by design is an approach to projects that promote privacy and data protection compliance from the start. The DPO will be responsible for conducting Privacy Impact Assessments and ensuring that all IT projects commence with a privacy plan.

INTERNATIONAL DATA TRANSFERS

No data of EU citizens  may be transferred outside of the EU without first discussing it with the data protection officer.

DATA AUDIT AND REGISTER

Regular personal data audits to manage and mitigate risks will be conducted using a Data Protection Impact Analysis (DPIA). The DPIA contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.

REPORTING BREACHES

All members of staff have an obligation to report actual or potential data protection compliance failures. This allows us to:

  • Investigate the failure and take remedial steps if necessary

  • Maintain a register of compliance failures

  • Notify the Supervisory Authority (SA) of any compliance failures that are material either in their own right or as part of a pattern of failures

MONITORING

The DPO has overall responsibility for this policy. They will monitor it regularly to ensure it is being adhered to.

CONSEQUENCES OF FAILING TO COMPLY

We take compliance with this policy very seriously. Failure to comply puts both you and the organisation at risk. If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us through:
contact@rejuve.ai 

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