Privacy Policy - EDO

• Any of the services accessible through the website (Services) that are available on the App Site. 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.

• IMPORTANT INFORMATION AND WHO WE ARE
• THE DATA WE COLLECT ABOUT YOU
• HOW IS YOUR PERSONAL DATA COLLECTED?
• HOW WE USE YOUR PERSONAL DATA
• DISCLOSURES OF YOUR PERSONAL DATA
• INTERNATIONAL TRANSFERS
• DATA SECURITY
• DATA RETENTION
• YOUR LEGAL RIGHTS
• GLOSSARY
• DESCRIPTION OF CATEGORIES OF PERSONAL DATA

Important information and who we are

‍

Servita Professional Services (UK) Limited is the controller and is responsible for your personal data (referred to as "we", "us" or "our" in this policy).

We have appointed a data protection officer (DPO). 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: Servita Professional Services (UK) Limited
• Email address: support@edo.health
• Postal address: The Smiths Building, 179 Great Portland Street, London, United Kingdom, W1W 5PL

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.

‍

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 in January 2024. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email. 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 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. 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.
• Financial Data.
• Transaction Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.
• Location Data.
• Health Data.

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.

We do collect via your use of the App along with any linked physical device data relating to your health, and health status, including data related to your physical condition along with details relating to your fitness and exercise information. Personal health data also includes data that can be used to make inferences about or detect the health status of an individual. This is a Special Category of Personal Data.

We do not collect any other Special Categories of Personal Data about you such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership. Nor do we collect any information about criminal convictions and offences.

‍

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, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the website and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). This may include your name, email address, password, date of birth, gender, height, weight, and in some cases your mobile telephone number.
• Information we collect about you and your device. Each time you visit one of Our Services 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 cookie policy for further details.
• Health Data. We will automatically collect personal data predominantly via your connected Fitbit wearable, including Health, Device, Content and Usage Data. The website and any linked devices collect raw data to extract and estimate certain metrics regarding your sporting activity. These metrics include: Total Distance, High Metabolic Load Distance, High Speed Running, Metres per Minute, Step Balance, Accelerations, Decelerations, Dynamic Stress Load, Current Heart Rate, Maximum Heart Rate, Average Heart rate, Time in “Red Zone”, Current Speed, Max Speed, Sprint Distance, Number of Sprints and Average Calories expended. Your linked device will transfer the raw data to via the Fitbit App via Bluetooth. When your App Account syncs with our servers over Wi Fi, the measurement metrics are backed up to our servers.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
  • Device Data from the following parties: analytics providers such as Google based outside the UK;
  • Identity and Contact Data from data brokers or aggregators;
  • Identity and Contact Data from publicly available sources.

Cookies

We use cookies to distinguish you from other users of our Services and to remember your preferences. This helps us to provide you with a good experience when you use any of Our Sites and also allows us to improve Our Sites. 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 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:

• Where you have consented before the processing. Where we need to perform a contract we are about to enter or have entered with you.
• 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.

See 'Lawful basis' 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.

‍

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:

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• 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

‍

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out 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.
• Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

‍

Data security

‍

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, 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 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

‍

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

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.

In the event that you do not use the website for a period of 3 years then we will treat the account as expired 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.

Please click on the links below to find out more about these rights:

• 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 or your personal data.
• Right to withdraw 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 support@edo.health .

‍

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

Internal third parties

Other companies in the Servita Group acting as joint controllers or processors and who are based in United Kingdom and provide IT and system administration services and undertake leadership reporting.

‍

External third parties

Service providers acting as processors based in the UK, United States and other EU countries who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in United Kingdom 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.

‍

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 your personal data. 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 transfer of your personal data. 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.
• Financial Data: bank account and payment card details.
• Health Data: data relating to your health, and health status, including data related to your physical condition along with details relating to your fitness and exercise information we collect through your use of the App and any linked tracking or similar device from time to time including Total Distance, High Metabolic Load Distance, High Speed Running, Metres per Minute, Step Balance, Accelerations, Decelerations, Dynamic Stress Load, Current Heart Rate, Maximum Heart Rate, Average Heart rate, Time in “Red Zone”, Current Speed, Max Speed, Sprint Distance, Number of Sprints and Average Calories expended
• Transaction Data: includes details about payments to and from you and details of in-App purchases.
• Device Data: includes the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
• Profile Data: includes your username and password, in-App purchase history, 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, whether this is required for our own billing purposes or otherwise.
• 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.

‍

‍