Privacy Policy

MYLIFE365.ME APP PRIVACY POLICY

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in our terms here and it is important that you read that information.

Before installation of this App (as defined below), please indicate your consent to our processing of your personal data (including your name, contact details, financial, health, special category data and device information) as described in this policy by ticking the ‘I agree to the Privacy Policy’ box when signing up to the MYLIFE.365 App.

How you can withdraw consent

Once you provide consent you may change your mind and withdraw consent at any time by contacting us but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Consent to processing Location Data

By ticking the ‘I agree to the Privacy Policy’ box, you consent to processing of your Location Data (including details of my current location disclosed by GPS technology so that location-enabled Services are activated.

Introduction

This policy applies to your use of:

• • MYLIFE365.ME mobile application software (App), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

• • Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). 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.

Important information and who we are

TAWAZUN HEALTH LTD (company number 11713177) of 67 Westow Street, London, England, SE19 3RW is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).

Contact details

Our full details are:

• • Full name of legal entity: TAWAZUN HEALTH LTD

• • Postal address: 67 Westow Street, London, England, SE19 3RW

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 on 28 September 2022. It may change and if it does, these changes will be posted when you next start the App or log onto one of the Services Sites. 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. You agree to 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, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

You agree that we may collect, process, 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

• • Special Categories of Personal data

‘Special Categories of Personal Data’ includes personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). This data can directly or indirectly identify you, we treat this as personal data which will be used in accordance with this privacy policy.

How is your personal data collected?

You agree to and acknowledge that 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 App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.

• • Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps 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.

• • Location Data. We also use data sent from your device to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

Cookies

We use cookies to distinguish you from other users of the App, the distribution platform Appstore or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. 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 to deliver the health reporting services provided by MYLIFE365.ME.

• • 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.

Purposes for which we will use your personal data

You acknowledge and agree that we shall use your personal data for the following reasons:

Purpose/activity	Type of data	Lawful basis for processing
To install the App and register you as a new App user	Identity Contact Financial Device	Your consent
To process in-App purchases and deliver Services including managing payments and collecting money owed to us	Identity Special Categories of Personal Data Contact Financial Transaction Device Marketing and Communications Location	Your consent Performance of a Contract with you Necessary for our Legitimate Interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services	Identity Contact Financial Profile Special Categories of Personal Data Marketing and Communications	Your consent Performance of a Contract with you Necessary for our Legitimate Interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to Comply with Legal Obligations (to inform you of any changes to our terms and conditions)
To administer and protect our business and this App including troubleshooting, data analysis and system testing	Identity Contact Device	Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App	Identity Special Categories of Personal Data Contact Device Content Profile Usage Marketing and Communications Location	Consent Necessary for our Legitimate Interests (to develop our products/Services and grow our business)

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 above:

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

• • Internal 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.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you, or 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.

Data retention

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

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.

Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.

• • 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 67 Westow Street, London, England, SE19 3RW.

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 a 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.

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 the personal data that we hold about you. 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:

• • Request the transfer of your personal data to you or to a third party. 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.

• • Special Categories of Personal Data – please see the data we collect about you section above.

• • Contact Data: billing address, delivery address, email address and telephone numbers.

• • Financial Data: bank account and payment card details.

• • 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 (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.

• • Content Data: includes information stored on your Device, including friends’ lists, login information, photos, videos or other digital content, check-ins and other information.

• • 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 and the resources that you access.

• • 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 your device.

• • Internal Third Parties: includes but is not limited to our subsidiaries, parent companies, advisors and consultants.

• • External Third Parties: includes but is not limited to our commercial partners, sponsors, health service providers, manufacturing partners and app/website developers.