Privacy Policy

This Privacy Policy, together with our Terms and Conditions and Cookie Policy, sets out the basis on which any personal information that Smart Capex Limited, Suite 3, Second Floor, 760 Eastern Avenue, Newbury Park, United Kingdom, IG2 7HU (“we”, “our”, “us”) collects from you (“your” and “you” refer to you and any person for whom a registered account has been created by you, or who uses the site on your behalf), or that you provide to us, will be processed by us and how we will treat it.

Use of personal information

To the extent that processing of your personal information is necessary in order for us to provide a service you have requested under a contract we have with you, we rely on that contract as the legal basis on which we process your personal information.

Otherwise, we rely on your consent as the legal basis on which we process your personal information. We will seek your consent when you register for the Site and we may seek further consents from you from time to time on the Site or by contacting you in other ways, including by email.

Where and how we store your personal information

Except as set out below, the information we collect from you is held on servers physically located within the UK or the European Economic Area (“EEA”).

If you ask us to link personal health and activity information collected using third party applications and/or devices to your Healthbit account, we will seek your consent to use a partner operating outside the UK and EEA to help us  extract and download the information to our Site. If you do not give us your consent we will be unable to link such information to your account. If you give us your consent, by doing so you agree to the transfer, storing and processing of your information outside the UK and EEA. We will remind you of this when we seek your consent. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

We will use appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage of your personal information.

Disclosure of your personal information

• We will not sell your personal information in a personally identifiable format to third parties without your prior consent.

• to the extent that disclosure is required by law or any regulatory authority.

Personal information of minors

Our Site is not directed to minors and we do not knowingly collect any personal information from children under 16 years of age through the Site. If you are the parent or guardian of a child under the age of 16 from whom you think we have collected personal information, please contact us. If we become aware that a child under 16 has provided us with personal information about themselves without our having received the consent of their parent or guardian, we will take reasonable steps to attempt to remove the information from our Site and terminate the child’s account.

The internet

• Given that the internet is a global environment, using the internet to collect and process personal information necessarily involves the transmission of information on an international basis. Therefore, by browsing the Site and communicating electronically with us, you acknowledge and agree to our processing of personal information in this way.
• The transmission of information via the internet is not completely secure. Although we do our best to protect personal information, we cannot guarantee the security of your information transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access or processing.
• Our Site may, from time to time, contain links to other websites or applications which are outside of our control and are not covered by this Privacy Policy. We do not accept any responsibility or liability for other sites’ or applications’ privacy policies. If you access other websites or applications using the links provided, please check their policies before submitting any personal information.

Cookies

We use cookies to help improve the Site in a variety of different ways. Please check our cookie policy for details of the cookies that we are currently using on the Site and for details of how to manage them.

Changes to our Privacy Policy

We will post any material changes that we may make to our Privacy Policy in the future on the Site, and, where appropriate, we will notify you of the change by email or by posting a notice on the Site This will ensure that you are always aware of the information we collect, how we use it and the circumstances under which we may disclose it.

Access to information

Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with Data Protection Legislation. We will respond to any valid access request within 30 days and will make available your information to you in a commonly used electronic format (normally a single csv file which may be downloaded from a link activated in your user account). To obtain a copy of the information we hold about you please contact us in the manner set out at the end of this privacy policy.

Erasure or rectification of information

Data Protection Legislation gives you the right to ask us to erase information held about you if it is no longer necessary in relation to the purposes for which it was collected or processed. You also have the right to ask us to rectify inaccurate information we hold about you or to complete incomplete information about you. Your right of erasure and/or rectification can be exercised in accordance with Data Protection Legislation. If you make a valid erasure or rectification request we will take reasonable steps to erase or rectify your information so far as required by Data Protection Legislation. However, Data Protection Legislation allows us to retain and continue processing your information in certain circumstances and if any of those circumstances apply we may continue to hold and process your information (in accordance with this privacy policy) despite your request for us to erase it. Such circumstances include (but may not be limited to) where our continued holding and/or processing of your information is necessary:

• for exercising the right of freedom of expression and information.
• for compliance with a legal obligation that requires processing of personal data by EU or member state law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
• for reasons of public interest in the area of public health.
• for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes in so far as the erasure of the information would be likely to render impossible or seriously impair the achievement of the objectives of the archiving purposes in the public interest, or the scientific and historical research purposes or the statistical purposes.
• for the establishment, exercise or defence of legal claims.

Right to complain

If you consider that we have failed to comply with this privacy policy and/or Data Protection Legislation in relation to information about you which we hold or process, you have a right to make a complaint to the relevant supervisory authority, which in the UK is the Information Commissioner’s Office: https://ico.org.uk

Contact

If you have any requests or queries concerning your personal information or any queries with regard to our practices, please send us an email or write to us at the following address: Smart Capex Limited, Suite 3, Second Floor, 760 Eastern Avenue, Newbury Park, United Kingdom, IG2 7HU or contact us by using the contact us facility on our Site.

Last update:  August 2023