Policy version: 01/05/2024

CA Health (the App) is provided by Christian Antonee Limited, 5 Puller Road, London EN5 4HG, United Kingdom, London, NW3 (‘we’, ‘our’ or ‘us’).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your information).

It also explains your rights in relation to your information and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your information is regulated by law, including under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

We are the controller of your information obtained via the App, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

If you are aged under 18 you must not use the App as it is not designed for you. We do not intend to collect the information of anyone under 18. If you are aware that any information of anyone under 13 has been shared with the App, please let us know so that we can delete that data.

If you are aged over 18 you may use the App. This version of our privacy policy is primarily written for adults, including parents and guardians of child users. If you become aware that a child has provided us with your information without parental consent, please contact us through our support team. If we become aware that an individual under 18 has provided us with your information without parental consent, we will take steps to remove the data and cancel that individual’s account.

The App is distributed only on UK App stores and is solely intended for use by people in the UK.

What this policy Applies to

This privacy policy relates to your use of the App only.

The App links to other websites or services owned and operated by certain trusted third parties to (e.g. make additional products, information and services available to you). These other websites or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other websites or services, please consult their privacy policies as appropriate.

Information we collect about you

The information we collect about you depends on the particular activities carried out through the App.  We will collect and use the following information about you:

Contact details: your name, address, email address and telephone number;

Personal details: age, sex, height;

Account information: password and User ID for your account;

Billing information, transaction and payment card information;

Health and fitness information collected via devices connected to the internet, including weight, height, estimated heart rate, exercise intensity, kcal, Body Mass Index, fat %, muscle mass and bone density; and

Online identifiers (e.g. IP addresses, Device IDs).

You must provide that information to use the App and its services unless we tell you that you have a choice.

Sometimes you can choose if you want to give us your information and let us use it. Where that is the case, we will tell you and give you the choice before you give the information to us. We will also tell you whether declining to share the information will have any effect on your use of the App or our services.

We collect and use your information for the purposes described in the section ‘How and why we use your information’ below.

How your information is collected

We collect information from you directly when you input it into the App or indirectly, such as your activity while using the App, for example:

·         Create and manage your account with us.

·         Providing services and/or the functionalities of the App to you.

·         Conducting checks to identify you and verify your identity or otherwise to help prevent and detect fraud against you or us.

·         To enforce legal rights or defend or undertake legal proceedings.

·         Protect the security of systems and data used to provide the App and its services.

·         Disclosures and other activities necessary to comply with legal and regulatory obligations, e.g. to record and demonstrate evidence of your consent to our use of your information where relevant.

·         Marketing our services to existing and former customers

In such cases, information will be anonymised where possible and only shared where necessary.

 

 

How and why we use your information

Under data protection law, we can only use your information if we have a proper reason, e.g.:

               where you have given consent;

               to comply with our legal and regulatory obligations;

               for the performance of a contract with you or to take steps at your request before entering into a contract; or

               for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your information for and why.

What we use your information for

Our reasons

Create and manage your account with us

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you

OR

To perform our contract with you or to take steps at your request before entering into a contract

Providing our services and/or the functionalities of the App to you

Depending on the circumstances:

—to perform our contract with you or to take steps at your request before entering into a contract

—for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you

Conducting checks to identify you and verify your identity or otherwise to help prevent and detect fraud against you or us

To comply with our legal and regulatory obligations

OR

For our legitimate interests, to, for example, minimise the risk of account or identity theft or fraud that could be damaging for you, a third party or us

To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, i.e. to protect our business, interests and rights

Communications with you not related to marketing, including about changes to our terms or policies or changes to the App or service or other important notices

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, i.e. to provide the best service to you

Protect the security of systems and data used to provide the App and its services

To comply with our legal and regulatory obligations

We may also use your information to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Operational reasons, such as improving efficiency, training and quality control or to provide support to you

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you

Statistical analysis to help us understand our customer base

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you

Updating and enhancing customer records

Depending on the circumstances:

—to perform our contract with you or to take steps at your request before entering into a contract

—to comply with our legal and regulatory obligations

—where neither of the above apply, for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Disclosures and other activities necessary to comply with legal and regulatory obligations, e.g. to record and demonstrate evidence of your consent to our use of your information where relevant

To comply with our legal and regulatory obligations

Marketing our services to existing and former customers

For our legitimate interests, i.e. to promote our business to existing and former customers

See ‘Marketing’ below for further information.

To share your information with third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, or in the event of our insolvency

In such cases, information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

—to comply with our legal and regulatory obligations

—in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets

 

Sensitive Personal Data

We may request your consent to process sensitive your information. Our App may require this data to provide the services, including when you use or interact with a wearable or other connected device that integrates with the services. If you choose not to provide sensitive your information, certain features or services may be unavailable or not function properly.

 

Marketing

We will use your information to send you updates (by email, text message, telephone or post) about our services including exclusive offers, promotions or new services.

We have a legitimate interest in using your information for marketing purposes (see above ‘How and why we use your information’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

               contacting us at info@christianantonee.com

               using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We will always treat your information with the utmost respect and never sell it for marketing purposes.

For more information on your right to object at any time to your information being used for marketing purposes, see ‘Your rights’ below.

Who we share your information with

We may share your information with:

               service providers we use to help us run our business or provide the services or functionalities in the App, such as website hosting, data analysis, payment processing services, information technology provision, email delivery, credit card processing, and other similar services.

               To third parties to permit them (or their own customers) to send you marketing communications, consistent with your choices.

We only allow the companies referred to above to handle your information if we are satisfied they take appropriate measures to protect your information. We also impose contractual obligations on service providers to ensure they can only use your information to provide services to us and to you.

We or the third parties mentioned above occasionally also need to share your information with:

               our or their professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations

               law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations

               other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your information will be bound by confidentiality obligations

How long your information will be kept

Different retention periods apply for different types of your information. If you would like further details about how we retain your information please contact us: info@christianantonee.com

Following the end of the of the relevant retention period, we will delete or anonymise your information.

Transferring your information out of the UK

Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your information to countries outside the UK. In those cases, we will comply with applicable UK laws designed to ensure the privacy of your information.

Under data protection laws, we can only transfer your information to a country outside the UK where:

               the UK government has decided the particular country ensures an adequate level of protection of your information (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR

               there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or

               a specific exception applies under relevant data protection law

Your rights 

 

In certain circumstances, you have the following rights which you can exercise free of charge: 

 

·         The right to access and receive a copy of the information we hold about you. 

 

·         To rectify any your information held about you that is inaccurate. 

 

·         The right to require us to restrict use of your information in certain circumstances.

 

·         The right to object to processing of your information in certain circumstances. 

 

·         The right to request the deletion of your information held about you. 

 

 

Please note that we may ask you to verify your identity before responding to such requests. 

 

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please complete a request form—available on our website at www.christianantonee.com or email, call or write to us—see below: ‘How to contact us’. When contacting us please:

               provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you, and

               let us know which right(s) you want to exercise and the information to which your request relates.

Keeping your information secure

We have appropriate security measures to prevent your information from being accidentally lost or used or accessed unlawfully. We limit access to your information to those who have a genuine business need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed guidance from Get Safe Online on how to protect your information and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted using the details at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes, we will take steps to inform you, for example via the App or by other means, such as email.

How to contact us

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details

 

43 Lyttelton Road, London N2 0EB

info@christianantonee.com

07715433931