MOBILE APP PRIVACY POLICY!!
Ceftronics Limited is committed to protecting your personal data and respecting your privacy.
Introduction
This policy (together with our Mobile App Terms and any additional terms of use incorporated by reference into those terms, together our Terms of Use) applies to your use of:
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The CEFREF mobile application software (App) available via Apple, Inc’s ‘App Store’ for iOS devices and via Google, Inc’s ‘Play Store’ for Android devices (each an App Store and, collectively the App Stores), once you have downloaded and installed a copy of the App onto your smartphone, tablet or other compatible device (Device).
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Any of the services accessible through the App (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. This App is 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.
This policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
Important information and who we are
Important information and who we are
Ceftronics Limited is the controller and is responsible for your personal data (collectively referred to as Ceftronics, we, us or our in this policy).
Contact details
Our full details are:
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Ceftronics Limited, 85 Great Portland Street, First Floor, London, England W1W 7LT.
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Email address: info@cefref.com.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). 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 28/10/2021 . It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by SMS, by email or when you next start the App. The new policy 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 Services may, from time to time, contain links to and from third party websites. 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:
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Identity Data.
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Contact Data.
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Financial Data.
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Transaction Data.
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Device Data.
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Content Data.
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Profile Data.
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Usage Data.
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Marketing and Communications Data.
We explain these categories of data here
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 policy.
Special Category Personal Data
Except as noted below, we do not 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.
The only Special Category information that we collect is the information about headaches and pain relief medication that you choose to enter into the App and, by entering into the App you consent to us:
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storing it for you to access and view in the App and for you to use our Services;
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applying algorithms to it to calculate the number and severity of headaches recorded in a given period, and the number of days in which pain relief medication was taken; and
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providing you with options to download or share that data, if you wish to do so.
How is your personal data collected?
We will collect and process the following data about you:
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Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Store and the App when using the Services, or by corresponding with us (for example, by email). It includes information you provide when you register to use the App Store, download or register the App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data with other users via the App's functionality, post reviews via the App, or enter a competition, promotion or survey, and when you report a problem with an App or our Services. If you contact us, we will keep a record of that correspondence.
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Information we collect about you and your device. Each time you use our App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our Mobile App Cookie Policy for further details.
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Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
Cookies
We use cookies and/or other tracking technologies to distinguish you from other users of the App and the distribution platform (Appstore), and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Mobile App Cookie Policy.
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:
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Where you have consented before the processing.
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Where we need to perform a contract we are about to enter or have entered with you.
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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.
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Where we need to comply with a legal or regulatory obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We do not share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data
Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data above:
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External Third Parties as set out in the Glossary.
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Specific third parties, such as other users of the App when you choose to use the data sharing functionality of the App. When sharing your data with your doctor via the App, no personal data is included within the data (unless you have included any personal data within your free form notes and you choose to share these with your other data), but your doctor will of course be able to link the data that you share with them to you, and may add it to your medical records. If you choose to share your data with your doctor, by doing so you are giving your consent to this
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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 policy.
International transfers
We do not transfer your personal data outside the UK.
Data security
All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party provider of payment processing services. Where we have given you (or where you have chosen) a password that enables you to access our App or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 browser web storage (including HTML5) and other technology.
When sharing your data with other users of our App using the data sharing functionality of our App, please ensure that you do not submit any personal data that you do not want to be seen, collected or used by other users, such as within free form notes in the App. You can choose whether or not to include your free form notes when sharing your data.
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.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
If you do not have a paid subscription and you do not use the App for a period of one year, then we will treat the account as expired and your personal data may be deleted. If you cancel a paid subscription, then we will treat the account as expired when you cancel and your personal data may be deleted.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You have the right to:
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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.
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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.
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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.
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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.
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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:
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if you want us to establish the data's accuracy;
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where our use of the data is unlawful but you do not want us to erase it;
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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
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you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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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.
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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.
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@cefref.com.
Glossary
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.
Third parties
Service providers acting as processors based in the UK who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
Description of categories of personal data
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Identity Data: any personal identifiers included within your email address such as first name and/or last name, but not otherwise.
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Contact Data: email address (used to set-up account); address and telephone numbers (if you provide them when contacting us.
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Transaction Data: includes details of in-App purchases.
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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, time zone setting.
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Content Data: includes information stored on your Device, including the information and free form notes you enter in the App.
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Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
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Usage Data: includes details of your use of any of our Apps or your visits to our sites including, but not limited to, traffic data and other communication data, and the resources that you access.
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Marketing and Communications Data: includes your preferences in receiving marketing from us and your communication preferences.
