This Privacy Policy explains how Memory Tracks Ltd (“Memory Tracks”), will process the data relating to you that you provide to us (or that we may collect) when you register and use the LifeTracks mobile application (“the APP”) and online services on our Website (“the Website").
This privacy policy applies only to the actions of Memory Tracks and any third party who accesses the App or our Website and is not either (i) employed by Memory Tracks and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Memory Tracks and accessing the App or Website in connection with the provision of such services (“the Users”).
At Memory Tracks, we are committed to protecting and respecting your privacy.
INTRODUCTION AND GENERAL TERMS
The LifeTracks App and website are operated by Memory Tracks (“we”, “us”, “our” or “Memory Tracks”), a company incorporated in England & Wales with company number 10791734 whose registered office is at Flat 2, Grove House, Blackheath Grove, London, SE3 0DG.
Where we decide the purpose and means for the processing of personal data relating to you, we are the “controller”. As controller, we will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679 and Data Protection Act 2018.
If you have any questions or comments about this Privacy Policy please contact us at:
Email:Support@lifetracks.net
Please read this Privacy Policy carefully as it contains important information about the following:
What information Memory Tracks may collect about you or receive from others;
How and why Memory Tracks will use that information;
Whether Memory Tracks will disclose information about you to anyone else; and
Your choices and rights regarding the personal information we hold about you.
This Privacy Policy should be read in conjunction with our other policies and procedures, Website terms and conditions, notices or agreements with you, as may be relevant.
2. INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data:
Customer Services (including visiting our App and Website)
Type of information
We may ask you for, or you may submit, personal and non-personal information to us when contacting us through the App or our Website in relation to the products and services that we offer.
Personal data that we may obtain includes:
your first and last name
email and/or postal address
phone number(s)
your username (typically your email address) and password
any other personal information you voluntarily provide
Purpose of the processing and legal basis for the processing
We may legally process the personal information that we hold on the basis that we have a legitimate interest, under our legal obligations and/or for the performance of a contract, including processing for the following purposes:
to provide you with information about the products and services that we offer, including news about Memory Tracks that may be of interest to you
to set up and administer your user account
to enter into and perform our contract for sales of our products and services;
to respond to your enquires when you contact us through the App or our Website by telephone, post or email
to resolve issues or fix problems in relation to the App
Who is this information shared with?
We keep your information confidential. We will not sell your information. We may disclose your information to our personnel and to third party suppliers or subcontractors (including our employees, independent agents and/or professional advisors and third party payment providers who process payments made via the App or on our Website to support payment and enquiries).
If we do share your information, we will only do so insofar as it is reasonable or necessary for the operation of our business, including for the purposes set out in this Privacy Policy, and provided that the recipients do not make independent use of the information and have agreed to adhere to the rules set out in this Privacy Policy.
In some instances, this data sharing may involve the transfer of information outside the EU. Please see our section on International Data Transfers below.
Setting Up Your Account
Type of information
When you set up your user account, we will ask you to provide us with personal information, which may include the following:
full name
date of birth
postal address (including country of residence)
information about your preferences and interests
operating system you are using (which is automatically collected)
name of person in your care
their year of birth
where they spent their childhood
Purpose of the processing and legal basis for the processing
We may legally process the personal information that we collect on the basis that we have a legitimate interest, under our legal obligations and/or in the performance of a contract:
to register and administer your user account
to respond to your enquiries
to make improvements to the App content and navigation
to identify and improve our understanding of our current Users
Who is this information shared with?
We keep your information confidential. We will not sell your information. We may disclose your information to our personnel and to third party suppliers or subcontractors (including our employees, independent agents and/or professional advisors and third party payment providers who process payments made via the App or on our Website to support payment and enquiries.
If we do share your information, we will only do so insofar as it is reasonably necessary for the purposes set out in this Privacy Policy, and provided that the recipients do not make independent use of the information and have agreed to adhere to the rules set out in this Privacy Policy.
In some instances, this data sharing may involve the transfer of information outside the EU. Please see our section on International Data Transfers below.
Making any inferences that you have specific health or medical condition
Type of information
There is no special or sensitive category data processed or collected by the app or service. However, given the nature of the services, it may be inferred that a particular user has a specific medical condition, such as dementia. Accordingly, we have sought to adopt best practice and flag this up to you before you subscribe to the services.
Purpose of the processing and legal basis for the processing
The processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional
Who is this information shared with?
We do not share any information which may allow such an inference to be drawn, other than as set out above or otherwise permitted by law
Marketing and Advertising
Type of information
Our App may from time to time contain third party advertising and links to other Websites.
These third party Websites have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible.
Purpose of the processing and legal basis for the processing
If we do receive any personal information about you from these third party social media sites, we will not process your information for the purposes of direct marketing unless you have provided your consent or it is otherwise lawful for us to do so.
We may use this information to find out more about our digital community so that we can better understand and serve our customers and Website visitors (for example, to create bespoke content by analysing general interests).
Where we provide you with information about our products, services or offers (such as via our email updates), we will only use your personal information in this way in accordance with laws relating to marketing directly to individuals, and in the pursuit of our legitimate interest of marketing our business.
In some cases, we will do this on the basis that you have provided your consent (including where you submit your details.
If you change your mind, you may opt-out at any time via the unsubscribe feature that appears in our emails or by emailingSupport@lifetracks.net
We will not share with any other third party the personal information that we obtain about you for the purposes of marketing, unless you have provided your consent or it is otherwise lawful for us to do so.
If you would like us to delete the personal information that we have received about you from these sites, please email us atSupport@lifetracks.net
If you do not want us to receive further information about you from these sites, you should also contact the sites directly to turn off the ‘follow’ setting.
Data Analytics and Cookies
We may use cookies to understand how users interact with our App and Website.
As you interact with our App and website, we may automatically collect data about your browsing activities. We use cookies to collect and log analytical information such as the date, times and frequency with which you access the App.
This processing is necessary for us to pursue our legitimate interest in improving the App, and providing a more relevant service to our customers.
This information is not used to develop a personal profile of you.
3. SPECIAL CATEGORY DATA
Although we will not obtain more sensitive personal data (known under law as special categories of personal data), such as data revealing racial or ethnic origin or concerning your health (or that of others), our marketing and advertising materials on our Website will state our services are for individuals living with dementia and related illnesses.
If you volunteer such information and subscribe to our services, you will be consenting to our processing it in relation to the purpose for which you have provided it. Accordingly, although we do not keep a record of any special category or sensitive personal data relating to your health or medical condition, by using the service it may be inferred that you have experienced or are experiencing a medical condition such as dementia or similar condition. You are subscribing to the services in the knowledge that this may be inferred from your subscription that we will not disclose your personal data to any third party other than as expressly permitted by law.
4. DATA SHARING
We will share your information with third parties only in the ways that are described in this Privacy Policy. If you would like to find out more about how the third parties listed in this policy use your information, this should be set out in their respective privacy policies.
We keep your information confidential, but may disclose it to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard this information.
In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email, account message and/or a prominent notice on our Website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements between us, to investigate potential breaches, or to protect the rights, property or safety of the companies forming part of the Memory Tracks, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. CONSUMER CONTROL AND OPT-OUT OPTIONS
If you do not wish to receive promotional or other marketing material from us or third parties then you can opt-out by clicking on the unsubscribe link in those emails or contacting us atSupport@lifetracks.netat any time.
6. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU
You have a number of rights in relation to the way we process personal data about you. Where an individual makes a request in accordance with provisions of the GDPR, we aim to comply without undue delay, and within one month at the latest. Those data subject rights include the right to make the following requests:
to ask for confirmation and information about the personal data that we process about you, including a copy of data we are processing about you;
to have inaccuracies corrected or incomplete personal data made complete;
to ask us to restrict, stop processing, or to delete your personal data;
to request a machine readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
to not be subject to automated decision-making, including profiling; and
to make a complaint to the data protection supervisory authority.
To make a request, please let us know by contactingSupport@lifetracks.net
7. DATA RETENTION
In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary.
If you would like us to stop using your personal information, please email us atSupport@lifetracks.net
8. DATA RELATING TO CHILDREN
We do not knowingly use the Website to solicit data from or market or sell to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information or may be receiving communications from us or otherwise interacting with us without consent of a parent or guardian, we ask that this be brought to our immediate attention. We will make it our priority to address this situation and delete information relating to a child as soon as practicable. In such an event, please contact us atSupport@lifetracks.net
9. SECURITY OF DATA
We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our App and services, taking into account the likelihood and severity those risks might pose to the rights and freedoms of our App Users.
In particular, access to your User account is controlled by a password and a user name that is unique to you.
Please be aware that, while we make the security of our App and your personal information a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your personal information with us, you accept the aforesaid and provide your information at your own risk.
10. INTERNATIONAL DATA TRANSFERS
If we transfer your data outside of the EEA, we have agreements in place which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your Personal Data. If you would like to find out more about these safeguards, please let us know by writing toSupport@lifetracks.net
11. CHANGES TO THIS POLICY
This Privacy Policy may be updated from time to time. We will notify you of any changes to this policy by posting the new version of the Privacy Policy on our Website. You are advised to consult this Privacy Policy webpage regularly for any changes.
12. HYPERLINKS TO THIRD PARTY WEBSITES
Our Website may contain hyperlinks to third party Websites. These third party Websites operate independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources. The appearance of such links on our Website is not an endorsement. Should you use any of these Websites, such use is at your own risk and we would advise that you review their respective privacy policies.
13. CONTACT US
Questions, comments and requests in relation to this Privacy Policy are welcome and should be addressed toSupport@lifetracks.net
Last Updated: January 2022
