LIVITAY LIMITED PRIVACY NOTICE

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Welcome to the Livitay Ltd (T/a Sanctuary Health) privacy notice. 

Sanctuary Health respects your privacy and is committed to protecting your personal data.  Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. You can view the notice on our website http://www.sanctuaryhealth.io.  Please also use the Glossary at the end to understand the meaning of some of the terms used in this notice.

Introduction

This notice (together with our end-user licence agreement (EULA) as made available by the relevant digital distribution service (DDS) and any additional terms of use incorporated by reference into the EULA, together our Terms and Conditions of Use) applies to your use of:

  • The Sanctuary Health web application software (App) hosted on app.sanctuaryhealth.io (App Site), once you have gained access to or streamed a copy of the App onto your mobile telephone, handheld device or desktop device (Device).
  • Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). 

This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  This App is not intended for children under the age of 13 and we do not knowingly collect data relating to children under the age of 13.  Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Livitay Ltd is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this notice).

If you have any questions about this privacy notice, please contact us using the details set out below.

Contact details

Our full details are:

  • Full name of legal entity: Livitay Ltd
  • Name or title of data privacy manager: Jamie Shepherd 
  • Email address: jamie@sanctuaryhealth.io
  • Postal address: 32 Portland Terrace, Newcastle, NE2 1QP, U.K

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK. We would, however, appreciate the opportunity to deal with your concerns before you approach the relevant supervisory authority, so we request that you please contact us in the first instance. 

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Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review.

This version was last updated on 20 May 2024. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App or log onto one of the Services Sites. The new notice may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

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

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data.
  • Contact Data.
  • Device and Technical Data.
  • Content Data.
  • Profile Data.
  • Usage Data.
  • Marketing and Communications Data.
  • Location Data

We explain these categories of data in the Glossary at the end of this notice.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not, in the normal course of our business activity, collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.  

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How is your personal data collected?

We will collect and process the following data about you:

  • Direct interactions.  You may give us your Identity or Contact details by filling in forms or corresponding with us by post, email, phone or otherwise.  This includes personal data you provide when you:some text
    • Request marketing to be sent to you;
    • Give us feedback; or
    • Contact us for any other purpose (including via social media). 
  • Automated technologies or interactions. As you interact with the App, we may automatically collect Technical Data about your Device, browsing actions and patterns. We collect this data using cookies and other similar technologies. Please see below for further details about cookies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:some text
    • Our Customers with whom you have an employment (or other) business relationship, in order to provide access to the services on our platform.
    • Technical Data from analytics providers such as Google (some of which may be based outside the UK);
    • Identity and Contact Data from publicly available sources such as the Electoral Register based inside the UK or social media platforms.

Cookies

We use cookies to distinguish you from other users of the App, App Site, the DDS or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. 

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where we need to perform a contract we are about to enter or have entered with you and/or your healthcare provider (our Customer).
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where you have consented before the processing.  

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity 

Type of data 

Lawful basis for processing 

To register you as a new App user 

Identity

Contact

Device

(a)  Performance of a contract with you

(b) Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

(c)  Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

(d) Consent

To manage our relationship with you and/or your provider (our Customer) with whom we may be contracted to provide our Services including notifying you of changes to the App, our privacy notice or any Services

Identity

Contact

Profile

Marketing and Communications

(a)  Performance of a contract with you or your employer (our Customer)

(b) Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

(c)  Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions.

To enable you to participate in a prize draw, competition or complete a survey

Identity

Contact

Device

Profile

Marketing and Communications

(a)  Performance of a contract with you

(b) Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity

Contact

Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Location

(a)  Performance of a contract with you

(b) Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

(c)  Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

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Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

External Third Parties:

  • The Health Plan or Employer through which you gained access to the App.
  • Service providers and agents who process data on our behalf e.g. internet service and platform providers, analytics providers, email verification providers and those organisations we engage to help us send communications to you.
  • Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Customers

We may share generic non-identifiable information to our Customers (your provider) about your engagement with our App and services provided via our platform.  Where this occurs, this information will be anonymised so that any information shared will transfer aggregated data only and does not allow individuals to be recognised.  We will ask you for permission to pass any data on to our Customers in a form which allows you to be personally identified.  This information will be used to more broadly understand and gain insight into the well-being of our Customer’s employees.

International transfers

Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider 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.

In some circumstances you can ask us to delete your data: see Request Erasure below for further information.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

We explain these rights in the Glossary at the end of this notice.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at info@sanctuaryhealth.com or jamie@sanctuaryhealth.io 

Glossary

  1. Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

  1. Your legal rights

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:some text
    • if you want us to establish the data's accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Description of categories of personal data

  • Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
  • Contact Data: billing address, delivery address, email address and telephone numbers.
  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting.
  • Content Data: includes information stored on your Device, including friends' lists, login information, photos, videos or other digital content and check-ins.
  • Profile Data: includes your username and password, your interests, preferences, feedback and survey responses.
  • Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data. 
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Location Data: includes your current location disclosed by GPS technology.

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