Legal requirements: in addition to the uses above, please note that we may also process your information where we are required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process. 

Special categories of personal data

There are more limited bases for processing special category personal data. This is personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation. Similarly, there are fewer bases for processing criminal convictions and offences data. 

We do actively collect health and fitness data that you optional provide for the purpose of building your user profile. Whilst we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally. For example, where you volunteer special category data to use, such as if you send us an email containing special category data.

Where possible, we request that you redact or otherwise withhold such data unless it is necessary to provide such information and the information has been manifestly made public by you.

What if you do not provide the personal data requested?

You are not required to provide us with any personal data but you will be unable to sign-up for and use our App without providing the personal data requested at the sign up phase.

Change of purpose

We will only use your personal data for the purposes for which we collected it (as identified above in the What we use this data for column), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so. 

Who will we share your personal data with?

We may share your personal data where this is required by law, where it is necessary to perform our contract with you, or where we have another legitimate interest in doing so. 

We may need to share your personal data with:

• other entities within our group as part of our regular reporting activities in company performance, in the context of a business reorganisation or group restructuring exercise, for assistance in relation to marketing and business development, for system maintenance support and hosting of data
• professional advisers including lawyers, bankers, auditors and insurers to the extent such information is relevant to their performance of their services
• regulators
• providers of cloud storage, web analytics, advertising, email distribution and other services
• any of our service providers where such information is relevant to their performance of such services
• the public and other users of our App. We only do this where you have made the information public yourself, for example, when you submit a review that is then posted on our App, hashtag or otherwise tag our brand on social media

We may share your personal data with third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protection our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

As we are established in United Kingdom, any personal data we collect about you will be processed in United Kingdom.  However, we host our app with a hosting provider with servers located in Europe.

We may also further transfer the personal data we collect about you to United Kingdom and other countries where the parties listed above are based for their operations. Those countries may not have the same standard of data protection laws as the EEA or the UK. Where this is the case, we will put in place the EU standard contractual clauses for data transfers between EU and non-EU  countries and the international data transfer addendum to the European Commission’s standard contractual clauses for international data transfers to ensure that your personal data is treated in a manner that is consistent with and respects the EEA and UK laws on data protection. If you require further information about this you can request it from contacting us at mildred.aduamoah@pecepta.com.  

How long will we retain your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. In doing this we will have regard to 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 requirements. 

Generally, we will keep information relevant to our dealings with you until you close down your account on the App unless we are required to keep any of the information for regulatory reasons. An account that has not been closed down but has been inactive for 10 years will be closed down.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. 

Once we no longer require your personal data for the purposes we collected it for, we will securely destroy your personal data in accordance with applicable laws and regulations.

Accuracy of personal data

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.

For EU/UK individuals: your rights in relation to your personal data

If you are an individual in the EU or UK, you have rights which you can exercise in relation to the personal data we hold about you under certain circumstances. These rights are to:

• request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
• request rectification of your personal data; 
• request the erasure of your personal data;
• request the restriction of processing of your personal data;
• object to the processing of your personal data;
• not be subject to a decision based solely on automated processing which significantly affects you;
• request the transfer of your personal data to another party.

If you want to exercise one of these rights please contact us at mildred.aduamoah@pecepta.com. We will do our best to accommodate your request or objection but please note that not all rights are absolute. 

You also have the right to make a complaint at any time to a supervisory authority for data protection issues. 

Fees

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 

Right to withdraw consent

Where you have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact mildred.aduamoah@pecepta.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to unless we now have an alternative legal basis for doing so.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our App and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data. 

Further information

This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account