Last updated: June 3, 2019
- THE LIFEQ GROUP RESPECTS YOUR PRIVACY
- LifeQ is a group of companies operating in several countries. Our main company is LifeQ Global Ltd in Ireland. Our main service is the LifeQ Service, which includes but is not limited to the LifeQ Application, LifeQ User Portal and LifeQ Consent.
- Our key activity is the collection, use and analysis of data from wearable health devices and similar technology in order to promote user health and wellness.
- We also collect and analyze data to provide some privacy-related services, such as the capture and storage of your consent and facilitation of data subject access queries, in order to promote good data practices.
- We respect your privacy and take all reasonable steps to comply with relevant data protection laws.
- We regard information about your physical and mental health as highly sensitive and private personal information.
- WHAT PERSONAL DATA WE COLLECT AND WHEN
When you create a LifeQ account
- You need to create a LifeQ account if you want to use the LifeQ Service directly.
- When you create your LifeQ account, we ask for some personal information needed to identify you and use the service. This includes your name, email address, your date of birth, and other basic information about you.
When you activate or add a device to your LifeQ account
- When activating a device to use with the LifeQ Application or Portal, you need to download or register through the LifeQ Application and enter information about yourself, such as your full name, date of birth, sex, height and weight.
- The device and the LifeQ Service collect physiological and other health-related data about you and send it to LifeQ and other organizations that you allow to receive your personal information.
- We may also collect location data from your device, which could disclose your movements.
- We also collect variables calculated by the LifeQ Service, such as activity, various heart rates, oxygen consumption, calories used, sleep patterns and averages among others to give you information about your health and physiology.
When you use the LifeQ Application and/or LifeQ User Portal and sync your device
- When you sync your device with the LifeQ Application or Portal, data recorded on your device about your activity is sent from your device to our servers. This data is associated with your account and is stored and used to provide the LifeQ Service.
- Each time a sync occurs, we log data about data transmission such as sync time and date, device battery level, and the IP address used when syncing.
When you use the LifeQ Service through our clients
- We also provide the LifeQ Service to client organizations that may use parts of our service in the products and services that they provide to you.
- Our clients may therefore obtain and process personal data through the LifeQ Service, including your name, email address, year of birth and other basic information about you.
- Our clients may also process signals directly from wearable devices, such as location and movement, and variables calculated by the LifeQ Service. These variables include heart rate, oxygen consumption, calories used, sleep patterns and others.
- When you receive access to the LifeQ Service from LifeQ or another party such as one of our clients, you agree to us and our client processing your personal data according to this Policy.
When you use LifeQ Consent
- LifeQ Consent captures information about your data and consent choices and shares this as agreed by you.
When you contact us
- When you contact LifeQ for customer service or other reasons, we collect your name and email address along with additional information you provide so that we can help you and improve the LifeQ Service.
When you visit and use our website
- LifeQ collects certain information when you use our website. This includes automatic log data about your visit, such as browser type, operating system, URL of the page that referred you, actions you performed, and the IP address you used to access pages on the website.
- We use this type of information to provide you with a better website experience, to prevent website misuse, and to ensure the website is working properly.
- PURPOSE OF PROCESSING YOUR PERSONAL DATA
To offer you the LifeQ Service
- We use your personal information to offer you our services.
- The data produced is displayed through our services.
To improve the LifeQ Service
- During processing, an anonymous copy of the data remains with us for statistical and scientific research to improve the LifeQ Service and understand how it is used and to ensure its availability.
- Anonymized data is only used in such a way that no specific person’s identity can be disclosed.
To provide you with support
- Our Support team may use the data you provided, collected data, and calculated variables to provide you with technical support.
To communicate with you
- We may use certain data to communicate with you and to offer surveys or other events that you can choose to participate in.
- If your personal data is used for additional purposes outside the context of providing the LifeQ Service, we will normally ask your consent to do so.
- There are limited situations where we do not need to ask for your consent, for example, in a public health emergency.
- HOW WE PROTECT YOUR PERSONAL INFORMATION
- LifeQ uses technical and organizational measures to safeguard personal data entrusted to us against loss, misuse and unauthorized access, disclosure or alteration.
- Only our authorized employees, you and anyone else you authorize may have access to your data.
- Although we take appropriate and reasonable security measures to help protect your personal data, use of the internet is never entirely secure and so we cannot guarantee the security or integrity of any personal data sent by or to you via the internet.
- We also cannot guarantee that personal data is protected against loss, misuse, or alteration by third parties with whom you share personal data.
- HOW WE SHARE PERSONAL DATA
With other LifeQ companies
- LifeQ is a global business so we may need to share your personal information with other LifeQ companies to provide our services.
With service providers
- We use third-party service providers to help us better understand the use of LifeQ Services and for related purposes.
- We do not disclose or share personal or other identifying data outside the LifeQ group for any purpose other than the LifeQ Service or in the following exceptional circumstances:
- where any relevant law requires disclosure, including the law of countries where you do not live;
- to respond to valid requests from local and foreign public authorities and law enforcement officials;
- to protect the rights, privacy, safety, property or operations of LifeQ, its affiliates and users;
- to help us limit any damages we may suffer and to investigate or pursue civil or criminal remedies in appropriate cases; and
- to enforce any of our terms and conditions or policies.
- We may also transfer personal information to an affiliate or a third party if we are involved in any corporate restructuring, merger, sale, joint venture, assignment, transfer or other disposal of any portion of LifeQ’s business, assets or stock, including in connection with any bankruptcy or similar proceeding.
- Data breaches include unauthorized access to information, for example where a hacker gains unlawful access to a network, or where an unencrypted laptop containing data is stolen.
- We will notify you about any confirmed and possibly serious data breaches that involve your personal information, as required by law in the relevant country.
- TRANSFER OF PERSONAL DATA ACROSS BORDERS
- Personal data is processed on LifeQ’s servers in the United States and Europe. Our authorized clients, affiliated third parties and sub-processors anywhere in the world may access this personal data in connection with the LifeQ Service.
- Although we take appropriate security measures to help protect your personal data, the internet is never entirely secure and so we cannot guarantee the security or integrity of any personal data sent by or to you via the internet.
- You may withdraw your consent to data transfers at any time by contacting Support, but it will then be technically impossible for us to continue to provide you with the LifeQ Service.
- Not all countries have the same data protection standards or laws. The law that applies to a particular set of data may be different to the law of the country in which you initially provided the data. For example, United States law generally grants law enforcement authorities greater rights of access to personal data (especially of non-US citizens) hosted on US-based equipment than European countries would allow in respect of data hosted in Europe.
- LIFEQ SUB-PROCESSORS
- A sub-processor is a third-party data processor engaged by LifeQ that has or could have access to or process service data, which may contain personal data.
- LifeQ engages different types of sub-processors to perform various functions such as cloud service provision, wearable device provision and support.
- UPDATING AND ACCESSING YOUR PERSONAL INFORMATION
- As a data subject, you generally have rights, among others, to:
- request access to any personal data we or our clients may process;
- correct or delete any inaccurate or irrelevant data free of charge;
- request the restriction of processing of personal data;
- withdraw consent or object to the processing of personal data;
- data portability allowing personal data to be transferred to another service provider;
- prohibit the processing of personal data for direct marketing; and
- complain to a government authority or regulator.
- If you wish to exercise any of these rights, you can contact Support or use the services that LifeQ has available.
- There are exceptions to some data subject rights, and some situations where we may lawfully refuse to comply with data subjects’ requests. For example, we may refuse to comply with a request that could cause other people’s privacy to be violated, or that we cannot reasonably carry out, or that is not allowed under any law that applies.
- We may also be allowed or required by law to keep certain personal information for longer periods, for recordkeeping or research purposes for example, subject to suitable safeguards where necessary.
- Please help us keep your personal data up to date and accurate by emailing us if you become aware of any errors.
- RETENTION OF PERSONAL DATA
- We retain your personal information for as long as we need it to fulfill the purpose for which we collected it.
- When the primary purpose for processing personal information has been achieved but there are legal reasons we need to keep it for longer, we will normally securely archive the information and restrict access to a minimum.
- LINKS, THIRD-PARTY APPLICATIONS AND THIRD-PARTY PRIVACY PRACTICES
- The LifeQ Service may link to sites that we do not operate, and you can download third-party applications to use in connection with the LifeQ Service.
- These linked sites and applications are not under our control, and we are not responsible for their privacy practices or content.
- NO USE BY MINORS
- The LifeQ Service is intended for use by adults only. We do not intentionally gather personal information from children.
- You may not access our website or application, or use our services if you are younger than 18 years old or do not have legal capacity in your jurisdiction to enter binding contracts.
- If we learn that we have collected or received personal information about a child without consent or verification from a parent or legal guardian, we will delete that information as soon as possible.
- Please contact us if you believe we might have any information from or about a child.
- POLICY UPDATES
- If we make material changes to how we treat personal information, we will notify you by email or through a notice on the website home page.
- OUR CONTACT DETAILS
- If you have any questions, complaints, compliments or other feedback about these Terms or the LifeQ Service please email us at firstname.lastname@example.org.
- Our address is LifeQ Global Ltd, Arthur Cox Building, Earlsfort Terrace, Dublin 2, Ireland.