Privacy Notice

Your privacy is very important to us.  When you interact with us you are trusting us with your information.  This Privacy Policy explains what data we collect, how we use it, how we protect it, and how you can manage your privacy settings and rights in connection with our products and services.

Smartlife is a trading name of Smartlifeinc Limited which is headquartered in Manchester, UK.  Smartlifeinc Limited is the controller of your personal data for the purposes of EU data protection law.

If you have any questions, suggestions, or concerns about this policy, or about our use of your information please contact us by email at support@smartlifeinc.com or by post by writing to:

Smartlifeinc Limited, 1st floor, 31 Princess Street, Manchester, M2 4EW

We may modify our Privacy Policy from time to time.  If we do this we will make an up-to-date version available on our website and, if the changes are significant, we will provide a prominent notice.  If you object to any of the changes to our Privacy Policy you should stop using our products and services and delete your account(s).

If we update our Privacy Policy we will make previous versions available in an archive.

 

+ Information we collect

We collect personal data to offer you services and/or communicate with you, such as when you:

  • use our app and website;
  • register as a tester or to take part in a study;
  • sign up to receive news about our company, products and services.

Direct from you

You provide some of this information directly when you create an account or record an exercise session in our app, complete a registration form on our website, or respond to a survey or questionnaire. This includes:

  • Name and contact details such as your address, phone number and email address;
  • Profile data including your date of birth, gender, height, weight, and a photograph;
  • Information from 3rd party services that you link to your Smartlife account and choose to share with us e.g. Facebook profile data;
  • Credentials i.e. passwords and security information for authentication and account access;
  • Additional information relating to the specific purpose of your interaction with us, for example we may ask about your medical history before you take part in any of our studies.

From your use of our services

We collect other information about you when you use our services, which could include:

  • Biophysical data, such as your heart rate and breathing rate;
  • Activity data, such as your steps, calories, and distance;
  • Location data, including your country and actual location during an exercise session;
  • Usage information, such as when you install software, create an account, or interact with a Smartlife application;
  • Device information, like the model and operating system of the phone you use to access our products and services.

+ How we use it

There are two key reasons we use your information:

  1. To develop, deliver, and improve the products and services we offer;
  2. To communicate with you.

Providing products and services

We need to use your biophysical, activity, and location information to provide you with insight about your exercise session. We use your profile information to improve the accuracy of these measures and insights.

We recruit participants to carry out research and use the biophysical data and additional information we collect during the study to develop new measures and insights.

We use device and usage information as well as crash reports to improve the stability of the devices and apps that we offer.

We use your credentials to maintain your security and prevent unauthorised access to your account.

We may de-identify and aggregate data for analysis so that we can identify patterns and trends that are useful to users and community. For example we may calculate statistics for benchmarking your performance such as an average fitness score by age group. Or, we may use aggregated data to write reports or articles on the subject of health and fitness.

Communication

We use your name, contact, and location information to communicate with you about the products and services you use. Where you have agreed to receive such messages, we may also communicate with you to promote other products and services or share news about our company. You can choose whether you want to receive these communications by updating your privacy settings or using the ‘unsubscribe’ link in an email from us.

+ How we share information

We share your personal information only under the following circumstances:

  • You have agreed to disclose your information for a specific purpose;
  • We employ vendors or agents to fulfil on our behalf the services that you use;
  • We are required to share your information to comply with the law;
  • We engage in a legitimate business transaction such as an acquisition or dissolution.

We may share with our community or third parties non-personal information that is aggregated or de-identified so that it cannot be used to identify an individual. This could include an analysis of patterns of trends that is included in a publicly available report or article about health and fitness. You may choose to opt out of using your data for this purpose.

With your consent

You may direct us to disclose your information to others, such as if you use tools that grant access to a coach or doctor, or if you participate in our research and give permission for your data to be shared with our academic partners.

Please note that if you choose to provide your data to third parties via API or other integrations with Smartlife then your data will be governed by their privacy policy which may differ from Smartlife’s.

Providing products and services

We may share your information with third parties who provide services to Smartlife such as employee wellness schemes, information and communications technology, customer service, data analysis, and marketing agents. These service providers will only have access to the information that is necessary to perform these limited functions on our behalf and must protect and secure it in compliance with this policy.

Legal requirements

We may preserve or disclose information about you to comply with a common law or statutory obligation, or to protect the rights and safety of our members and third parties, as well as our own.

Business transactions

If Smartlife becomes involved in a merger, acquisition or sale of assets sale, we will continue to protect the confidentiality of your personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

+ How we protect your information

Smartlife works hard to keep your data safe, both to restrict access to your data and to prevent identification of your data wherever possible.

Biometric data from the sensor pathways is non-identifiable and can only be accessed by a physical connection to both sensor pathways.

The Smartlife Brain does not receive, store, or process any data that is identifiable to the user. Any data stored temporarily is cleared as soon as it is no longer needed. In addition, the brain uses a proprietary operating system which reduces the risk of unauthorised data access.

Smartlife currently uses Core Bluetooth 4.0 (specifically the Bluetooth Low Energy Protocol) to transmit data from the brain to your receiving device (e.g. mobile phone) and plans to upgrade to Bluetooth 4.2 as soon as possible to ensure the highest standards of security. No method of transmitting or storing data is completely secure, however the data is still non-identifiable at this stage.

Data is held in the iOS mobile app using Core Data and NSUserDefaults.

Information transmitted between the apps and browsers on your devices (mobile phone, computer etc) and our databases are protected by the well-established HTTPS protocol, which uses public/private keys to encrypt data. Alphanumeric identifiers are used instead of sensitive information (e.g. name) during this communication.

Smartlife databases are hosted and protected by Amazon Web Services. This includes encryption of data, firewalls, and physical security. Access to sensitive data is restricted as far as possible.

Smartlife’s mailing lists are hosted and protected by MailChimp's secure servers.

+ Your rights and control of your personal data

The GDPR provides a number of rights for individuals and we give you account settings and tools to access and control your personal data in accordance with these rights. For more information or assistance regarding your rights in relation to EU data protection law you should contact your national Data Protection Authority.

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling.

Be Informed

Within this Privacy Policy we explain our purposes for processing your personal data, the retention periods for that personal data, and who we share it with.

Access & Export

As a user of Smartlife’s apps you can access much your personal information by logging into your account on our websites: my.smartlifeinc.com and forum.smartlifeinc.com. Here you can download your session data in a commonly used file format.

Any requests for data that cannot be fulfilled by this method can be emailed to support@smartlifeinc.com. We will review your request and provide your data within one month.

Rectify or Erase

App users can amend their personal information or delete their account by logging into their accounts on our websites detailed above.

You can unsubscribe from a mailing list by clicking ‘unsubscribe’ at the bottom of an email sent from us.

Any data amendments, deletions, or restrictions that cannot be fulfilled by this method can be requested by emailing support@smartlifeinc.com. We will review and action your request within one month.

Restrict or Object

Within your account settings you can limit the ways in which your information is processed by selecting or deselecting the options. In addition to these controls, in certain circumstances, unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons, you may request that we stop processing all of your information in accordance with our legitimate interests as described in this policy.