1.                Who are we?

1.1               We are Red Realm Limited trading as “AndBreathe”. For privacy queries, you can contact us at info@andbreathe.com. Other contact details are on our website.

2.                What’s the point of this policy?

2.1               It tells you what to expect when we collect your personal information via our app or website. Please only use our service if you are completely happy with this policy.

2.2               Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies.

3.                Might the policy change?

3.1               Yes. We will post any new version on our website (please check whenever you visit the site) and also notify you by email, SMS, in-app message or otherwise. We will assume you agree to the new version of the policy if you use our site or app after its effective date.

4.                What do we collect?

4.1               Information which you upload to our service or otherwise give us such as:

·                     your name and contact details;

·                     details about your transactions on our service;

·                     information that you include in communications with us; and

·                     contact or other information which you give or allow us to use for newsletters or other marketing. 

4.2               Your activity on the app, such as the how many minutes a day you have used it.

4.3               Other automated information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the site from which you arrived at our service, details of your activity with date / time stamps including pages you visited and your searches / transactions. 

4.4               The following information about you may be provided to us by other people:

·                     Limited billing information sent to us by our payment provider or the relevant app store for verification purposes e.g., your name, email address and billing address.

5.                What’s our reason / legal basis for collecting the information?

5.1               Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract. This applies to initial enquiries and to contact and transaction details.

5.2               [Special category:] Because it’s necessary for [the supply of social care / health services by care providers / health professionals (in the case of health information)].

5.3               Because it’s in our “legitimate interests”, e.g., to manage and improve our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to automated usage data.

5.4               Because you’ve specifically agreed on our service (e.g, by ticking a consent box). This applies to contact or other information which you give or allow us to use for newsletters or other marketing. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.

6.                How long do we keep personal information?

6.1               Until our contract with you has ended. You can end the contract by emailing us at the above email address.

6.2               We may hold on to some (or all) of your information for longer (typically up to six years) if reasonably needed for legal, regulatory or tax reasons, deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions.

6.3               We will keep your information which we use only for newsletters or other marketing until you tell us to stop sending you such messages.

6.4               We will generally keep automated browsing information for up to 26 months.     

7.                To whom do we send or make available your personal information?

7.1               To other people who supply us with a service, e.g., hosts, payment providers, and businesses which help us send communications and which provide us with e-commerce, online advertising, analytics, social media and other IT services.

7.2               To regulators, the police and other law enforcement authorities to help deal with fraud and abuse and/or comply with legal requirements.

7.3               To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.

7.4               To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.

8.                Do we send your information outside the UK ?

8.1               Your personal information which we collect is stored within the UK and is not transferred to any other countries except as follows.

8.2               We may store some of your personal information on servers located in countries within the European Economic Area (EEA).

8.3               Your personal information (e.g., name, email address, IP address, browsing information) may be transferred to the US by the following companies: Apple (app admin), Google / Facebook (analytics / advertising / app admin) and the social media companies listed in our cookies policy. Transfer is generally on the basis of contracts with special standard contractual clauses designed to provide adequate safeguards for your personal information. Some of the companies were certified under the “Privacy Shield” framework which is no longer applicable due to a court decision; we understand that the authorities are working on a replacement and we aim to update our policy to reflect this in due course.

9.                What rights do you have?

9.1               If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete it or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g. marketing).

9.2               You may also have the right to object to use of your personal information in certain circumstances.

9.3               If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO).

9.4               For more information about your rights, visit the ICO’s website: www.ico.org.uk.