Privacy Policy

1. Introduction

MSN Lifepal Limited, owner of this mobile application ‘Lifepal’, (hereinafter MSN Lifepal or we), respects your privacy and is committed to protecting your personal data.

This privacy policy (together with our Terms of Use as set out in www.lifepal.app and any additional terms of use incorporated by reference into the Terms of Use) applies to your use of:

• the mobile application software (App), once you have downloaded a copy of the App onto your mobile telephone or handheld device (Device) and have validly registered thereon, and
• any of the services accessible through the App (App Services).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This privacy policy:

• Provides an overview of how we collect and process your personal data;
• Informs you about your rights under the General Data Protection Regulation 2016/679 (GDPR) and any national laws supplementing or implementing the GDPR (where relevant);
• Contains important information about what personal data we collect, what we do with such personal data, who we may share it with and your rights in relation to the personal data you have given us.

For the purposes of this privacy policy:

• When we refer to “personal data” or “personal information” we mean data which identifies or may identify you and which may include, for example, your name, address and telephone number. It does not include data where your identity has been removed (anonymous data).
• When we refer to “processing” we mean the handling of your personal data by us, including collecting, protecting and storing your personal data.

2. Who we are

MSN Lifepal, who owns, operates and manages the App, is the controller and is therefore responsible for your personal data.

If you have any questions or concerns regarding the collection and processing of your personal data by us or if you wish to exercise any of your rights (as set out in section 9 of this privacy policy), please do not hesitate to contact us using the details set out below and we will be happy to provide you with a response as soon as possible.

• Email address: [email protected]
• Postal address: 15 Themistokli Dervi Street, 1^st floor, 1066 Nicosia, Cyprus
• Telephone number: +35722445500

MSN Lifepal takes the protection of your personal data very seriously. However, if you are of the opinion that we have not dealt with your concerns adequately, you have the right to submit a complaint to the Office of the Commissioner for Data Protection in Cyprus or to the data protection supervisory authority of the country in which you reside.

3. How we collect your personal data

We obtain your personal data mainly through any information you provide directly to us or through information we collect from your Device. Below is a list of ways in which we collect your personal data:

1. Personal data collected directly from you. This is information you submit to us directly by using the App or by corresponding with us (for example, by email or phone). It includes information you provide when you register to use the App, when you use the App Services and when you report a problem to us in connection with the App or the App Services. If you contact us, we will keep a record of that correspondence.
2. Information we collect from your Device. Each time you use the App, we will automatically collect data in connection to your Device as well as details of your use of the App.

4.  The data we collect about you

We may process the following personal data about you:

• Identity Data including your full name, date of birth and country of residence.
• Contact Data including your e-mail address.
• Profile Data including information we request when you initially register on the App, such as your height and weight, as well as information you subsequently volunteer to input on the App including medical information such as any symptoms you may experience as well as the date and type of medical examinations you may have undertaken from time to time.
• Device Data including the type of mobile device you use, a unique device identifier, your mobile network information, your mobile operating system and your mobile device model.
• Usage Data including details of your use of the App, including but not limited to, the pages you viewed, information about the links you have clicked on (including date and time), services you viewed or searched for, page response times, download errors, length of visits to our App and page interaction information (such as scrolling and clicks).
• Marketing and Communications Data including your preferences in receiving marketing from us and third parties with which we partner from time to time as well as your communication preferences (i.e. whether you wish to receive communications from us through email, push notifications or otherwise).
• Records of any correspondence and/or communications we have with you (whether to resolve a query, to handle a complaint or for the management of our business relationship).

We also collect, use and share Aggregated Data such as statistical 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 Profile Data for scientific research purposes such as for example to identify whether there are patterns in one’s health signalling the development of cancer. 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.

5. 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 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. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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).
• Where you have provided your explicit consent before the processing. 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 using the contact details set out in section 2 of this privacy policy.
• Where we need to comply with a legal or regulatory obligation that we are subject to, such as for example a tax obligation.

We provide further details in connection to each legal basis on which we rely below, as follows:

Performance of a contract

When you register as a new App user and agree to the Terms of Use, we will process your personal data in order to:

• provide you with the App Services (as applicable), including providing you with a recommendation on when to visit a doctor and reminding you of when to retake certain medical examinations. We will do this by analysing medical information you provide to us, as described in more detail in the “Doctor Visit Recommendation” section of the Terms of Use; and
• manage our relationship with you in accordance with the Terms of Use, including notifying you of changes to the App, or App Services (including changes to this privacy policy and/or the Terms of Use) and liaising with you in order to resolve any issues or concerns you may have.

Where we need to collect personal data in accordance with our Terms of Use, and you fail to provide that data when requested, we may not be able to provide the App Services to you.   

Legitimate interests

We may process your personal data on this basis in order to:

• administer and protect our business, including the App, and develop our services (including the App Services). To this end, we may keep track of any contact we have with you, including through email or through other forms of communication. Records of such communications will assist us in checking your instructions to us (or vice versa), assessing, analysing and improving the App Services, training our people and preventing fraud and other crimes,
• manage the security of our network and information systems,
• perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation) to improve our services marketing, customer relationships and experiences,
• identify, prevent and investigate fraud and/or any violation of our Terms of Use and manage our risk exposure,
• maintain our accounts and records,
• receive professional advice (e.g. tax or legal advice),
• defend, investigate or prosecute legal claims, and
• provide you with information about other services we may offer from time to time. You will receive marketing communications from us if you have validly registered as a user of the App and have not opted out of receiving push notifications and/or emails from us. You can opt-out of receiving such information by adjusting your marketing options, as explained in further detail below.

Legal obligation

In certain cases, we may need to retain your personal data in order to comply with our legal obligations, such as our tax obligations. 

Consent

We will only request your consent in the following circumstances:

• SPECIAL CATEGORIES OF PERSONAL DATA

When you provide us with medical information on the App, we will be processing special categories of personal data. When we process such special categories of personal data, we will need your prior explicit consent. If you do not give us such consent, you will not be able to input the medical information that we need in order to provide you with recommendations on whether to visit a doctor or undertake a medical examination.  

THIRD PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes and/or before we provide you with any information in connection to offers or promotions of third parties.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging into the App and adjusting the marketing preferences on your profile or by following the opt-out links on any marketing message sent to you or by contacting us by using the contact details in section 2 above.

6. With whom we may share your personal data

We may share your personal data with third parties as listed below for the purposes set out in section 5 above. When we do so, we request from such third parties to have appropriate technical and organisational measures in place to protect your personal data. We will not share any of your personal data for any purpose other than the purposes described in this privacy policy.

• Service providers who provide us with:
• application development, IT and system administration services, and
• banking, financial services and payment services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Tax authorities, regulators and other governmental bodies or agencies who may require reporting of our processing activities in certain circumstances.
• Communications service providers.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business then we will ensure that the new owners will use your personal data in the same way as set out in this privacy policy.

INTERNATIONAL TRANSFERS

Some of the third parties we work with are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, 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 by the European Commission.
• Where we use specific service providers or share your personal information with third parties, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

7. Safeguarding your data

All information you provide to us is stored on our secure servers.

Where we have given you (or where you have chosen) a password for the App, you are responsible for keeping this password confidential. Please do not share it with anyone.

Unfortunately, we cannot guarantee 100% protection against unauthorized access in the case of data transfers across the internet, but we and our business partners do our utmost to protect your personal data in line with the prevailing data protection regulations by means of physical, electronic, and process-oriented security precautions.

8. How long we keep your personal data

We will only retain your medical information for as long as we have your consent. All other personal data we have collected from you during your use of the App will be retained for as long as you continue being a user of the App and, once your account is terminated for any reason, for as long as we are required to do so by law or for one or more of our business purposes, in accordance with the retention criteria set out below.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research purposes as described in section 4 above, in which case we may use this information indefinitely without further notice to you.

If you have tried to register as a user on the App but have been unsuccessful (due to the fact that you have not provided us with all the information we have requested or you have not verified your email or you are not eligible to become a user or for any other reason), we will delete any personal data you have provided to us prior to registration (i.e. your email address) within ten (10) calendar days from your unsuccessful attempt to register.  

9. Your legal rights

You have the following rights in terms of the personal data and information we hold about you:

Receive access to your personal data

This enables you to receive a copy of the personal data we hold about you and to be informed on how we are lawfully processing it.

Request correction of the personal data we hold about you

This enables you to have any incomplete, inaccurate or out of date information we hold about you corrected. You can do this yourself by updating your personal data on your account profile in the App.   

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 or contractual reasons which will be notified to you, if applicable, at the time of your request. You may request your data to be deleted by contacting us at [email protected].

Object to processing of your personal data

You can object to the 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 the 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.

The right to ‘data portability’

Where you request a 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 your consent

In cases where you have given your consent to us, you will be able to withdraw that consent at any time. 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 the App Services as described in this privacy policy and in the Terms of Use. We will advise you if this is the case at the time you withdraw your consent.

10. How to exercise your rights

To exercise any of your rights as set out in section 9, you can use the contact details set out in section 2 above.

For security reasons, we may need to request specific information from you to help us confirm your identity and ensure your right to access to your personal data (or to exercise any of your other rights). We may also contact you to ask you for further information in relation to your request to speed up our response.

11. Third Party links

Our App may, from time to time, contain links to and from the websites of our partner networks and/or advertisers. Please note that these websites and any services that may be accessible through them have their own privacy policies. We do not accept any responsibility or liability for these third-party privacy 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.

12. Children

We do not intend to solicit or collect personal data from anyone under the age of eighteen (18). If you are under eighteen (18), do not enter information on the App or engage the App Services. If you believe a child of yours under the age of eighteen (18) has entered personal data, please contact us using the contact details in section 2 above to have the data removed and terminate the child’s account.

13. Changes to our privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version of the privacy policy was last updated on the 8^th of April 2021.

If we update our privacy policy in the future, the changes will be posted on the App and, where appropriate, notified to you either by email or when you next start the App. 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 App Services.

We do however encourage you to review this policy periodically so as to be always informed about how we are processing and protecting your personal information. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed of your personal data changes during our relationship with you.