Bestlife App: Privacy Notice
Last updated: 10th May 2023
A quick summary:
Below is our detailed privacy notice which provides you with information on how we use your personal data when you use the Bestlife App (the "App"). We have produced this summary to give you an overview about what we do and how it involves your personal data, but please do read the full privacy notice.
Personal data is information relating to an identified or identifiable individual. It can include your name and email address, as well as information about you such as your likes and interests as well as things you have done and where you have been.
Our App aims to help young people be active through a digital game and has been developed to help children and young people be happier and healthier. The App will also help health researchers at Born in Bradford understand more about how exercise affects children's mental and physical health. We will only provide personal data to wider research organisations where you have given your consent.
This App is connected with Born In Bradford and information from the App can be used alongside other information you have provided to Born In Bradford as part of the overall program. This will only be done with your consent (or your parent/guardian's consent if you are under 16).
If you have any questions at all, please do feel free to contact us at: Admin.Jump@bthft.nhs.uk
Who we are:
The App is operated by Active Bradford Limited (together "we", "us", "our"). This privacy notice sets out how we process your personal data. Active Bradford Limited is the controller of your personal data. "Controller" is a legal term under data protection legislation and means the entity that is responsible for how your personal data is used. As controller we will determine how your personal data is used.
Whose personal data do we collect:
The App is aimed at children, but is also available to adults. This means we will collect personal data of you when you use the App. If you are under 16 we will also collect information about your parents/guardians – in order for them to decide if you can use the App.
What personal data do we collect and from where
We collect your personal data directly from you when you register to use the App. The App also collects information about you when you use the App, such as the number of steps you have taken, the types of activity you have taken part in (both indoors and outdoors), and the places you have visited.
The App will also ask you from time-to-time about your mood and your views on the App. Your mood and views will be your personal data also.
As the App aims to improve the health and wellbeing through exercise and engagement, the App will also track changes in the activity and mood of users.
Finally, the App will collect certain information about the device you are using the App on, such as the type of device and your IP address.
If you are a parent or guardian of a user under 16, we will collect your email address, name, and the age of your child in order for you to permit your child to use the App.
How do we use your personal data
In accordance with data protection laws, we will only process your personal data if we have a lawful basis for doing so. In respect of your personal data, these bases are: (i) if it is necessary to provide services to you under the performance of the contract we have with you; (ii) if we are required to do so in accordance with legal obligations; (iii) if you have given your consent; and, (iv) if it is in our legitimate interests to process your personal data, provided that none of these prejudice your own rights, freedoms and interests. The following is a list of the purposes for which we process your personal data, and the lawful basis on which we carry out such processing.
Purpose | Lawful Basis |
To permit your child onto the App | Consent (parental) |
To manage your account with us (where applicable) | Necessary for the performance of a contract |
To monitor your activity on the App, including number of steps you have taken, your activities and places you have visited | Necessary for the performance of a contract |
To track your physical activity levels as you use the App | Legitimate interests: to better understand the effectiveness of the App for you and in general |
To ask you about your mood | Legitimate interests: to be able to map your mood against your activity to better understand the effectiveness of the App for you and in general |
To track your mood and emotional wellbeing | Legitimate interests: to be able to map your mood against your activity to better understand the effectiveness of the App for you and in general |
To ask your views about the App | Legitimate interests: to better understand the services our users find most useful |
To send push notifications through the App about content and services | Consent |
To respond to communications, including customer support queries | Legitimate interests: so that we can deal with queries and complaints |
To send you updates about the App | Necessary for the performance of a contract |
To send you newsletters and marketing information that you have requested | Consent |
To prepare and analyse statistics relating to the use of the App by you and other users | Legitimate interests: to understand and improve the usability of the App |
To administer a sale or possible sale of the whole of or part of our business or the restructuring of our business | Legitimate interests: to facilitate any such possible or actual transaction or restructuring |
To assist law enforcement agencies in their investigations | Legitimate interests: the law enforcement agencies provided that this does not affect your rights |
To conduct legal proceedings, including defending ourselves legally and making claims | Necessary to comply with legal obligations |
We may also process your personal data for purposes which are compatible with those listed above and below. When we do this we will update this privacy notice.
Anonymised Data:
We will anonymise the personal data of those that use the App so that we can carry out analysis regarding the effectiveness of the App, how the App is being used, those that are most likely to use the App (i.e. age and gender). In addition, we will use anonymised information from the App to help with medical research into exercise and emotional wellbeing.
In all cases, the anonymised data will not be able to identify you.
Marketing:
Where you have consented to receive marketing from us we will contact you from time-to-time with information that may be of interest to you.
Our communications will contain an 'unsubscribe' feature. This can be used to object to receiving future communications.
When do we disclose your personal data
In the long-term, we would like to share information about those that have used the App with the health and wellbeing research community in order to carry out research and to provide health advice relating to the activity on the App (both physical activity and emotional wellbeing). We will ask you (or your parent if you are under 16) for your consent before we do this. This will be entirely optional and you will not be required to give your consent. If you do not give your consent, you will still be able to continue using the App. You can also withdraw your consent at any time – please see below.
We may, for the purposes outlined above, disclose your personal data to any of the following recipients:
- Companies within our group (including to their employees and sub-contractors) which assists us in providing our services or which otherwise have a need to know such information.
- Third parties which assists us in providing our services (known as processors), including Dubit Limited. In each case we will have contractual protections in place to ensure that such processors only process your personal data on our instructions.
- External professional advisors who need to access such information for the purpose of advising us.
- Law enforcement bodies which may have any reasonable requirement to access your personal data.
- Potential purchasers of our business or investors in it or in any company within our group (including in the event of insolvency).
We do not transfer your personal data outside of the EEA (including the UK). If we ever do, we will ensure where there are adequate safeguards in place to ensure the security of your personal data.
Cookies:
The App uses cookies and similar technologies. The use of these is limited to those that are strictly necessary to enable the App to function, such as managing authentication and your login.
Cookies are small text files that are downloaded onto your device and can help to improve the functionality of websites and apps. You can learn more about cookies and how to manage and disable them here: https://ico.org.uk/your-data-matters/online/cookies/
How long do we keep your personal data for
If you are involved in the Age of Wonder program with Born In Bradford then we will retain your personal data indefinitely in accordance with the lifetime consent that you have given.
For all other users, we will retain your personal data for so long as you use the App. If you wish to erase your information, you can do so in the App. If you select this option, we will retain your information for a further 30 days before deleting it permanently. You can change your mind at any time within these 30 days.
Your rights
You have the following rights under data protection legislation. If you have any questions about your rights, or you wish to exercise any of these rights, please contact us at: Admin.Jump@bthft.nhs.uk
We may require you to provide forms of identity should you wish to exercise one of your rights below.
- Access: You are entitled to confirmation that we process your personal data and a copy of such personal data.
- Rectification: If the personal data we hold on you is incorrect, you have the right for this to be rectified. You may also update your personal data through your account settings.
- Erasure: You can elect to erase your personal data within the App.
- Restriction: You may request a restriction on the processing we undertake on your personal data. This will only apply if we have no lawful basis to process your personal data, your personal data is inaccurate or to comply with an objection request (see below).
- Objection: You may object to our processing of your personal data if our processing is carried out on the basis of legitimate interests. Please note, however, that should we determine that our interests are so compelling as to override your objection we may continue to process your personal data.
- Objecting to direct marketing: You may object to receiving direct marketing at any time.
- Portability: You have the right to receive some of your personal data in machine readable format. This right extends to you being able to request that such data is sent to a third-party controller.
- Withdrawing consent: If the lawful basis we rely on to process your personal data is consent you have the right to withdraw this consent. Please contact us at [to withdraw consent for the processing of your personal data.
- Complaining to a supervisory authority: Further information about your rights can also be obtained from your national data protection regulator – in the UK, this is the ICO (https://ico.org.uk). If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with your national data protection supervisory authority, although we would ask that you contact us in the first instance.
- Your right to be informed: You can contact us to find out more or to ask any questions you may have about our use of your personal data.
Please note that your rights above are not absolute and we may be unable to comply with your request (in whole or in part). Please also note that if we reasonably determine that your request is manifestly unfounded we reserve the right to refuse to comply with your request.
When you make a request we may have to ask you to prove your identity.