Privacy & Cookies Policy
Circadia Technologies Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who uses our services and provides personal data through either (a) our Mobile App: iOS/Android (“Mobile App”), (b) our website myinsomniatest.com (“Website”) or (c) the sleep tracker device that has to be used in conjunction with the Mobile App (“Sleep Device”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy & Cookies Policy carefully and ensure that you understand it. Your acceptance of the Cookies part of this Privacy & Cookies Policy will occur when you tick the consent box on Our Mobile App or Our Website and you acceptance of the privacy part of this Privacy & Cookies Policy is deemed to occur upon your first use of Our Mobile App, Website or Sleep Device AND/OR You will be required to provide express consent by reading and accepting this Privacy & Cookies Policy when signing up for an Account or Subscription (if we offer one). If you do not accept and agree with this Privacy & Cookies Policy, you must stop using Our Mobile App, Website and Sleep Tracker immediately.
- Accountmeans an account required to access and/or use certain areas and features of Our Mobile App or Website;Cookiemeans a small text file placed on your computer or device by Our Mobile App or Website when you visit certain parts of Our Mobile App or Website and/or when you use certain features of Our Mobile App or Website. Details of the Cookies used by Site are set out in Part 14 below;Cookie Lawmeans the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;Raw Datameans data collected that is personal data as defined under the Data Protection Legislation (as defined below) which comprises identifiers to one or more factors specific to you physical, physiological, genetic, mental, economic, cultural or social identity where such identifiers are provided by you via Our Mobile App or Website or collected by technical sensors or otherwise through Our Sleep Tracker and Mobile App, including but not limited to height, weight, respiration data, sleep data, environmental data and motion data; andThird Party Providersmeans any third party provider(s) that we may elect to work with to extend the use and benefits you derive from Our Mobile App, Sleep Tracker or Website, including but not limited to sleep coaches, wellness coaches, alternative medicine therapists, sports coaches, service companies in the sleep, health and wellness industry.
Email address: firstname.lastname@example.orgTelephone number: 02033055585 PostalAddress: 207 Lavender Hill, SW11 5SD, London, United Kingdom
- The right to be informed about our collection and use of your personal data. This Privacy & Cookies Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15. The ICO has more guidance on their website, [here]
- The right to access the personal data we hold about you. Part 13 will tell you how to do this. The ICO has more guidance on their website,[here]
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more. The ICO has more guidance on their website,[here]
- The right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more. The ICO has more guidance on their website, [here]
- The right to restrict (i.e. prevent) the processing of your personal data. Please contact us using the details in Part 15 to find out more. The ICO has more guidance on their website,[here]
- The right to object to us using your personal data for a particular purpose or purposes. Please contact us using the details in Part 15 to find out more. The ICO has more guidance on their website,[here]
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time. Please contact us using the details in Part 15 to find out more.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases. Please contact us using the details in Part 15 to find out more.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
How We Collect the Data
|Identity Information including first name, last name, title, gender, date of birth||Via Our Mobile App including via any installed plugins, Our Website platform, via online questionnaires, over the telephone or via email or social media interaction, Third Party Providers, at health and wellness and technology events, other general marketing. Sometimes data may be collected automatically through these mediums.||Consent Legal Obligation Legitimate Interest|
|Contact information including address, email address, telephone numbers||Via Our Mobile App including via any installed plugins, Our Website, via online questionnaires, over the telephone or via email or social media interaction, Third Party Providers, at health and wellness and technology events and other general marketing. Sometimes data may be collected automatically through these mediums.||Consent Contract Legal Obligation Legitimate Interest|
|Payment information including card details, bank account numbers, CVV codes||Via Our Mobile App, Our Website, over the telephone, email, payment processing partners and servers. Sometimes data may be collected automatically through these mediums.||Contract Legal Obligation Legitimate Interest|
|Profile information including login details, purchase history||Via Our Mobile App, Our Website, the Sleep Tracker, , online questionnaires. Sometimes data may be collected automatically through these mediums.||Contract Legitimate Interest|
|Technical information including IP address, browser type and version, country, operating system||Via Our Mobile App and Our Website. Sometimes data may be collected automatically through these mediums.||Legal Obligation Legal Interest|
|Data from third parties other than Third Party Providers||Social media platforms and insights tools. Sometimes data may be collected automatically through these mediums.||Contract Legitimate Interest|
|Raw Data||Via Our Sleep Tracker. Sometimes data may be collected automatically through this medium.||Consent Contract Legitimate Interest|
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality and aware of any obligations relating to the use of your personal data by them; and
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
Subject to part 9, We will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].
- We may sometimes contract with the following third parties to supply certain services and as such your personal data and/or Raw Data may be shared with them as outlined below.
Activity Carried Out
|AWS (Data Processor)||Payment processing, order processing Customer Relationship Management||digital marketing||EU Region|
|Stripe||Payment processing Gateway||e-commerce||As prescribed by Stripe’s data transfer policy|
|AWS||Storage and processing of personal data and Non Personal Data||Cloud storage||EU Region|
|Maintenance such us updates to prevent hacking and cybersecurity||App or Website administration||UK|
|Third Party Providers||Consultations, care sessions or other health and wellness support that builds on and extends the benefits of the use of Our Mobile App, Sleep Tracker or Website||health and wellness services||UK|
|Research bodies||Sharing of Raw Data on an anonymised and aggregate basis for research purposes||Research industry|
*LocationPersonal data collected by Us may be stored and processed in your region, in the United States, or in any other country where Circadia or its affiliates, subsidiaries or service providers maintain facilities. Typically, the primary storage location is in the customer’s region or in the United States, often with a backup to a data centre in another region. The storage location(s) are chosen to operate efficiently, to improve performance, and to create redundancies to protect the data in the event of an outage or other problem. All data stored outside of the United Kingdom or the EEA will be processed in accordance with Part 9 of this Privacy & Cookies Policy.ResearchWe may use your Raw Data and other personal data on an anonymised basis, aggregate it with anonymised Raw Data and other personal data from other users of Our Mobile App, Sleep Tracker or Website to formulate analysis, theories and papers for distribution internally with our own research and development department or externally with research bodies, Third Party Providers or otherwise. When you create your Account you will be given an opportunity to consent to the use of your personal and Raw data for these purposes. If you have previously consented but later would prefer us not to use your personal data in this way, please let Us know by contacting us as described in Part 15. If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
- In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Mobile App, Sleep Tracker or Website, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account and opting out of your personal data being used for research purposes).
- If you are based in the United Kingdom, you may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”).These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Email address: email@example.comTelephone number: 02033055585Postal address: 207 Lavender Hill, SW11 5SD, London, United Kingdom