Salter Health App Privacy Notice

Date: October 2022

Who We Are

Salter Health mobile application is part of UP Global Sourcing UK Limited, which is a company under the group UP Global Sourcing Holdings PLC, (‘we’ or ‘us’ or ‘our’) and we gather and process your personal information in accordance with this privacy notice and in compliance with the relevant Data Protection law. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data with reference to this app. If you require wider information about how our business manages your personal data, please visit https://salter.com/privacy-policies/

UP Global Sourcing UK Limited’s registered office is at Manor Mill, Victoria Street, Manchester OL9 0DD and we are a company registered in England and Wales under company number 05432142. We are registered on the Information Commissioner's Office Register of Data Controllers under registration number ZA269152, and act as the data controller. Our designated contact for data protection is our Compliance Officer, and contact details are available at the foot of this notice.

 

Information That We Collect

We process your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than specified in this notice. We may update this notice from time to time and the date it was last updated appears at the top of the page.

The personal data that we collect is: -

  •     Username
  •     Email
  •     Date of birth
  •     Sex
  •     Connected app usernames (i.e. Apple health/Google fit)
  •     Profile Picture (optional)
  •     Athlete Mode Status (details of activity levels)

Special Category Data (data related to Health)

  •     Height
  •     Pregnancy Status (if appropriate)
  •     Weight
  •     Blood Pressure
  •     Heart Rate
  •     Body Measurements (such as waist, chest, hip, thigh, calf, neck and upper arm)
  • Scales Calculated health metrics (such as body water %, body fat %, Muscle Mass %, Bone  Mass % Body Mass Index (BMI), Basal Metabolic Rate (BMR), Relative Fat Mass (RFM), Lean Body Mass (LBM)

The data detailed above is also stored on your phone. We only collect the data on our servers so that if you want to move to a new mobile phone, the data previously collected can be uploaded when you download the app on to your new device. This data is also used to assist us when you want to connect to another user in our “linked Accounts” feature.

We do not collect any data from public sources.

 

Children’s data

We understand that children may use our products and services. However, children under the age of 13 are not allowed to register for the app unless they have obtained parental consent. Parents should register and manage their child’s account for them. Parents who believe that their child has submitted their information to us without parental consent should contact us to have it deleted or to revoke parental consent at any time. We will action any requests for deletion within 30 days.

We collect information in the below ways: -

  •     When you enter information as part of the registration process
  •     When you use our connected products that send information to the mobile app
  •     When you connect to a device (i.e. scales)
  •     When you contact us
  •     Information received from any third-party apps, such as Apple Health or Google Fit,      that you choose to link with the mobile app

 

How We Use Your Personal Data (Legal Basis for Processing)

We take your privacy very seriously and will never disclose, share or sell your data without your consent, unless required to do so by law or detailed herein as part a requirement to provide the services you have requested. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw consent at any time.

If you have chosen to allow us to use your email address for marketing purposes, we rely on consent for this purpose.

We use your information collected as part of the registration process to provide you with our services and for our legitimate interests to ensure that our services are secure, suitable and accurate. The information you provide us with allows you to maintain a profile on our mobile app and connect with other users. The information also allows us to continue to develop and improve our services and to communicate with you.

Any special category data as detailed above is collected, and used, with your explicit consent prior to being collected. We will request your explicit consent via the app at the point that you link a device with the app. Special category data is collected to allow you to link a product with your account, record your results and view graphs, graphics and tables to help you to interpret your results, track your goals and give you the ability to share your health data with other users of your choosing. We obtain special category data directly from you when you provide it to us and via your product when it’s linked to the app. You are free to withdraw your consent at any time by contacting us. Please note that the device will no longer collect special category data and functionality will be limited.

 

Your Rights

You have the right to access any personal information that we process about you and to request information about: -

  •     What personal data we hold about you
  •     The purposes of the processing
  •     The categories of personal data concerned
  •     The recipients to whom the personal data has/will be disclosed
  •     How long we intend to store your personal data for
  •     If we did not collect the data directly from you, information about the source

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 update/correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You may have the right to request erasure of your personal data or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use. Please note, we do not process your data using automated decisions for marketing purposes.

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 relevant request; this is to ensure that your data is protected and kept secure. Any such requests will be responded to within one month, but if a request is particularly complex, we may need longer time and will notify you of this if relevant.

 

 

Sharing and Disclosing Your Personal Information

We do not share or disclosure any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement.  We do not transfer your personal information outside of the UK or the European Economic Area.

We use third parties to provide the services and business functions below, however all processors acting on our behalf only process your data in accordance with contractually agreed instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

We use partners to provide the following services:

  •     Undertake legally required accountancy services
  •     Developing the mobile app
  •     Hosting services
  •     Legal Services

Your personal information may also be shared:

  • If we are required to do so by law or to comply with any applicable rules or regulations, or in response to a legitimate request from a law enforcement authority or other government official.
  • If we sell or transfer all or a portion of our business or assets, in accordance with applicable law. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use data you have provided to us in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your data with any inquiries concerning the processing of that data.
  • With our advisors and insurers require the personal information due to a claim, dispute or where otherwise necessary.
  • With UP Global Sourcing Holdings PLC or any subsidiaries.

 

Social Media

We also use various social media channels to provide support and answers any questions you might have. We never add anyone’s personal data into any social media channel or use their audience or category advertising features, however we act as joint controllers as they determine how your data is managed.

We also sometimes run competitions on these social media channels, however we never take your personal data from these companies, except to send you prizes. You should be aware of the privacy notices of these social media channels to see how they manage your data:

Safeguarding Measures

We take your privacy seriously and we take 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: -

  •     Firewall
  •     Encryption
  •     Strict Access Controls (physical and electronic)
  •     SSL certificates
  •     Full Privacy Governance structure

 

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to us, however, as this information may be required for us to provide you with our services, this app will not work without it and the functionality of any connected devices such as smart scales may be limited.

 

How Long We Keep Your Data

We only ever retain 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 details for direct marketing, we regularly review consent given and will keep such data until you notify us otherwise and/or withdraw your consent.

If you delete your account, we will permanently delete it along with your personal information after 60 days. This allows you the opportunity to reactive your account during that time period. 

 

Lodging A Complaint

We only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority. We would be grateful if you would give us the opportunity to deal with any complaints in the first instance.

UP Global Sourcing UK Limited Compliance Officer

Manor Mill

Victoria Street

Manchester

OL9 0DD

UNITED KINGDOM

Email: data-protection@upgs.com

Telephone: 0161 934 2240

 

UK Data Protection Authority

Information Commissioners Office (ICO)

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113

Email – via their website – www.ico.org.uk

 

 

UP Global Sourcing UK Limited is a company under the group UP Global Sourcing Holdings PLC.