Introduction

This policy also applies to any services accessible through the our website of ours (Services) unless a separate policy is notified to you when accessing or using those Services.

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

1. IMPORTANT INFORMATION AND WHO WE ARE

Pausa Life is the controller and is responsible for your personal data (collectively referred to as ”Company”, ”we”, ”us” or ”our” in this policy).

We have appointed a Data Protection Manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: Pausa Life Limited
• Name or title of Data Protection Manager: Adam Bates
• Email address: privacy@pausa.life
• Postal address: The Hub on the Mound, 60 High Street, Tarvin, CH3 8JB

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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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

We keep our privacy policy under regular review.

This version was last updated on 1st February 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 use our services. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of our 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 websites 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 Service 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. Please check these policies before you submit any personal data to these websites or use these services.

2. THE DATA WE COLLECT ABOUT YOU

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

• Identity Data: name and date of birth
• Contact Data: email address, contact telephone number, GP practice and provider and if relevant school and teacher.
• Health and Lifestyle Data including information regarding your your mental wellbeing data and risk factors for specific diseases.
• Usage Data: includes details of your use of any of our website including, but not limited to, traffic data and other communication data, and the resources that you access.
• Communications Data: information on your communications preferences.

Sensitive Data

Some of the data we collect is particularly sensitive, such as data about your your health. This data is integral to the purpose of our Service, and by agreeing to use our Service and input your data into the website, you consent to us collecting this data. If you do not consent, then you must not use our services.

Aggregated Data

We may anonymise and aggregate data from all subjects. This data may 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 age or health data, but without your name, address or contact details.

We may also use collated, anonymised data to monitor website usage, for population analysis and for the identification of behaviour trends. We may publish these findings, or share them with third parties.

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Health and Lifestyle, Biological, Data about your contacts, and Communications Data) you consent to giving us about you by filling in forms on our website, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use our Service, input your details into our websites, and when you report a problem with the Services or our websites. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you use the our websites, we will automatically collect personal data including Device and Usage Data. We collect this data using cookies and other similar technologies.
• Information we receive from other sources: we will receive personal data about you from:
  • analytics providers, such as Google analytics (who may be based outside the UK).

Cookies

Our websites use cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use. You can choose to block cookies at any time. If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

3. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so.

One of the main purposes of the Service is to collect information on your health and wellbeing, in order to calculate your risk factors for specific diseases and provide advice on how to manage those risk factors.

By accessing our Service, you consent to us processing your information for those purposes. If you do not consent to us processing your information for those purposes, you must not use our Services.

Other uses of your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Marketing and Communications

We will not use your personal information for any marketing purposes.

We will send you communications relating to your use of the Services, and notifications about assessment requests.

4. DISCLOSURES OF YOUR PERSONAL DATA

We will share your personal data with the third parties set out below

• Service providers acting as processors based in the United Kingdom who provide IT and system administration services.

5. HOW TO WITHDRAW YOUR CONSENT

You may withdraw your consent at any time by contacting us at privacy@pausa.life.

Where you do this, your data will no longer be available to you. But this will not affect the lawfulness of any processing carried out before you withdraw your consent, or any processing we carry out which does not require your consent.

Also, your anonymised data (which is no longer personal information) may still be used within the aggregated data we collate.

6. INTERNATIONAL TRANSFERS

We may transfer your personal data to third parties providing services to us who are based outside of the United Kingdom. This includes parties providing IT administration services and hosting services.

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:

• Transferring data to countries that have been deemed to provide an adequate level of protection for personal data. This includes (but is not limited to) countries within the European Economic Area; or
• using specific contracts approved for use within the UK which give personal data the same or equivalent protection it has in the UK.

7. DATA SECURITY

All information you provide to us is stored on our secure servers.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and your device’s internal storage.

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

8. DATA RETENTION

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

Because of the purposes for which we are collecting your information, it is very difficult to provide a set retention period. We will keep this under regular review. When reviewing whether to retain 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 most cases, this means we will retain your data unless and until you delete your data.

For more details, please contact our Data Protection Manager.

9. YOUR LEGAL RIGHTS

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

These rights are as follows:

• 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:

  • 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 will not be able to provide information to your employer.

  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 privacy@pausa.life.