Privacy Notice
Last Revision Date: May 2020
Purpose: We take our responsibilities as custodians of your data very seriously. This privacy policy explains what personal information we collect, how we use it and your rights with regards to this data.
Contents
- Introduction
- Who are we?
- What types of information do we collect?
- Cookies
- How we use your personal data (legal basis for processing)
- Your data, your rights, your choices
- Sharing and disclosing your personal information
- Safeguarding Measures
- Transfers outside the EU
- Legitimate Interests Assessment
- How long we keep your data
- Special Categories Data
- National Data Opt-out
- Lodging a Complaint
Introduction
Lifelight® regards your privacy and the handling of your personal data with the utmost importance. This Privacy Notice details how we collect, use and securely store any personal data submitted to us through use of our website and Lifelight Application.
We are what is known as a ‘data controller’ for processing your personal data submitted to us through our website. For patient’s data submitted to us through use of our Lifelight Application xim is what is known as the ‘data processor’ and not the ‘data controller.’
There is also an explanation of the various rights you can exercise as a data subject, as well as how you can exercise those rights.
The scope of this Privacy Notice applies to https://lifelight.ai/
Introduction
Lifelight® regards your privacy and the handling of your personal data with the utmost importance. This Privacy Notice details how we collect, use and securely store any personal data submitted to us through use of our website and Lifelight Application.
We are what is known as a ‘data controller’ for processing your personal data submitted to us through our website. For patient’s data submitted to us through use of our Lifelight Application xim is what is known as the ‘data processor’ and not the ‘data controller.’
There is also an explanation of the various rights you can exercise as a data subject, as well as how you can exercise those rights.
The scope of this Privacy Notice applies to https://lifelight.ai/
Who are we?
Xim Limited, creators of Lifelight (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data. We are registered as a ‘data controller’ – you can read more about our responsibilities by visiting the Information Commissioner’s Office website here. It should be noted from above that for patient’s data that is submitted through use of our Lifelight Application xim is what is known as the ‘data processor’ and not the ‘data controller.’
Xim’s registered office is: The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP
We are a company registered in England and Wales under company number: 3699022
Our Information Commissioner’s Office (ICO) Registration number is: ZA241740
We act as the data controller when processing your data. The individual responsible for data protection is Claire Robinson who can be contacted at:
The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP
Who are we?
Xim Limited, creators of Lifelight (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data. We are registered as a ‘data controller’ – you can read more about our responsibilities by visiting the Information Commissioner’s Office website here. It should be noted from above that for patient’s data that is submitted through use of our Lifelight Application xim is what is known as the ‘data processor’ and not the ‘data controller.’
Xim’s registered office is: The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP
We are a company registered in England and Wales under company number: 3699022
Our Information Commissioner’s Office (ICO) Registration number is: ZA241740
We act as the data controller when processing your data. The individual responsible for data protection is Claire Robinson who can be contacted at:
The University of Southampton Science Park, 2 Venture Road, Chilworth, Southampton, Hampshire SO16 7NP
What types of information do we collect?
Xim Limited processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We collect information that you give us to process your enquiry and to better understand how our services are used. We’ve outlined the main types of information that we handle below. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
Examples of the types of personal data that we collect are:
- Name
- Personal Email
- Business Email
- Mobile Telephone Number
- Technical information from usage of our Apps
How do we collect your information?
We collect your information when you provide it to us through the website contact form or when you communicate with us in other ways. Whenever you subscribe to our newsletter or fill out a form, we may also collect and process data in order to carry out any services you use.
What types of information do we collect?
Xim Limited processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We collect information that you give us to process your enquiry and to better understand how our services are used. We’ve outlined the main types of information that we handle below. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
Examples of the types of personal data that we collect are:
- Name
- Personal Email
- Business Email
- Mobile Telephone Number
- Technical information from usage of our Apps
How do we collect your information?
We collect your information when you provide it to us through the website contact form or when you communicate with us in other ways. Whenever you subscribe to our newsletter or fill out a form, we may also collect and process data in order to carry out any services you use.
How we use your personal data (legal basis for processing)
Xim Limited takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.
The purposes and reasons for processing your personal data are detailed below:
- We collect your personal data in the performance of a contract or to provide a service and to ensure that we fulfil our obligations to you
- We collect and store your personal data as part of our legal obligation for business accounting and tax purposes
Legitimate interests
We have a legitimate interest in improving our service from a technical perspective. In order to do this we collect technical information so we can carry out service improvement related research.
Furthermore, this information is also used for auditing and ad hoc issue investigation.
We have a legitimate interest in improving our service for you, the user. In order to do this we collect behavioural information so we can see what actions you take within the app so we can continually improve the service for you.
You are entitled to receive more information about our legitimate interests on request. If you would like to receive more information please contact us using the details set out below.
How we use your personal data (Legal basis for processing)
Xim Limited takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.
The purposes and reasons for processing your personal data are detailed below:
- We collect your personal data in the performance of a contract or to provide a service and to ensure that we fulfil our obligations to you
- We collect and store your personal data as part of our legal obligation for business accounting and tax purposes
Legitimate interests
We have a legitimate interest in improving our service from a technical perspective. In order to do this we collect technical information so we can carry out service improvement related research.
Furthermore, this information is also used for auditing and ad hoc issue investigation.
We have a legitimate interest in improving our service for you, the user. In order to do this we collect behavioural information so we can see what actions you take within the app so we can continually improve the service for you.
You are entitled to receive more information about our legitimate interests on request. If you would like to receive more information please contact us using the details set out below.
Your data, your rights, your choices
At xim, we want to make sure you find it easy to access and amend the data we hold about you. Subject to limitations, you can also make certain requests about that data. Please contact us using the details set out below if you wish to exercise your data rights, or contact the data protection regulator to find out more about them.
The right to be informed:
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Notice.
The right of access:
You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Notice). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
The right to rectification:
You are entitled to have your information corrected if it is inaccurate or incomplete.
The right to erasure:
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information that we hold.
The right to restrict processing:
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but will not use it further.
The right to object to processing:
You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving information about xim’s products and services which may be of interest to you via email or post).
The right to data portability:
You have the right to obtain and reuse your information for your own purposes across different services. To our best ability we will provide your information in an easily accessible format.
The right to lodge a complaint:
You have the right to lodge a complaint about the way we handle or process your information with the national data protection regulator.
The right to withdraw consent:
If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw that consent at any time.
Please note that withdrawing your consent does not make unlawful what we have done with your personal data up to that point (when your consent was active).
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Your data, your rights, your choices
At xim, we want to make sure you find it easy to access and amend the data we hold about you. Subject to limitations, you can also make certain requests about that data. Please contact us using the details set out below if you wish to exercise your data rights, or contact the data protection regulator to find out more about them.
The right to be informed:
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Notice.
The right of access:
You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Notice). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
The right to rectification:
You are entitled to have your information corrected if it is inaccurate or incomplete.
The right to erasure:
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information that we hold.
The right to restrict processing:
You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but will not use it further.
The right to object to processing:
You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving information about xim’s products and services which may be of interest to you via email or post).
The right to data portability:
You have the right to obtain and reuse your information for your own purposes across different services. To our best ability we will provide your information in an easily accessible format.
The right to lodge a complaint:
You have the right to lodge a complaint about the way we handle or process your information with the national data protection regulator.
The right to withdraw consent:
If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw that consent at any time.
Please note that withdrawing your consent does not make unlawful what we have done with your personal data up to that point (when your consent was active).
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Safeguarding Measures
Xim Limited takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: SSL, TLS, encryptions, pseudonymisation, restricted access, IT authentication, firewalls and anti-virus/malware.
Safeguarding Measures
Xim Limited takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: SSL, TLS, encryptions, pseudonymisation, restricted access, IT authentication, firewalls and anti-virus/malware.
Transfers outside the EU
Given the worldwide nature of online communications and services, it is very common for users’ data on sites like ours to be transferred outside of the country in which it was collected. For example, the servers which host our sites could be located abroad. Where we transfer your data to countries outside of the European Economic Area (“EEA”), we will only do so if measures to maintain to protect your data and its privacy have been put in place.
Xim transfers your information to the United States where some of its service providers are based. However, xim ensures that the organisations to whom your information is transferred have adequate safeguards in place to protect your data, in particular, through being “Privacy Shield” certified. You can obtain more information on what this means here.
Transfers outside the EU
Given the worldwide nature of online communications and services, it is very common for users’ data on sites like ours to be transferred outside of the country in which it was collected. For example, the servers which host our sites could be located abroad. Where we transfer your data to countries outside of the European Economic Area (“EEA”), we will only do so if measures to maintain to protect your data and its privacy have been put in place.
Xim transfers your information to the United States where some of its service providers are based. However, xim ensures that the organisations to whom your information is transferred have adequate safeguards in place to protect your data, in particular, through being “Privacy Shield” certified. You can obtain more information on what this means here.
Legitimate Interests Assessment
As noted in the ‘How we use your personal data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
Legitimate Interests Assessment
As noted in the ‘How we use your personal data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
How Long We Keep Your Data
Xim Limited only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
Where you have consented to us using your detai