INTRODUCTION

iPlaySafe App Website Privacy Policy

iPlaysafe App respects your privacy and is committed to protecting your personal data in accordance with your rights and our obligations under the UK General Data Protection Regulations (UK GDPR) and Data Protection Act 2018. This Privacy Policy will inform you as to how we look after your personal data when you visit our Site and download our App and tell you about your privacy rights and how the law protects you. Please take the time to read it as it contains important information about your personal data.

Defined terms used in this Privacy Policy have the same meaning as those terms used in the Terms and Conditions of Use and Terms and Conditions of Sale.

1. Important information and who We are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process (which means collect, record, store, use, analyse, combine, disclose or delete) your personal data through your use of our Site or App, including any data you may provide through when you sign up to receive news, information and updates about our Products and Services and when you register for an Account and purchase Products and Services from us.

Our Site and App are not intended for children, and we do not knowingly collect data relating to children. You must be 18 years and over to access and use this Site or App.

It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Data Controller

eWellness Limited is the data controller and responsible for your personal data (collectively referred to as "iPlaySafe App", "we", "us" or "our" in this Privacy Policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this Privacy Policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: eWellness Limited

Email address: support@iplaysafe.app

Postal address: PO BOX 976, Richmond Upon Thames, TW9 9JH

Telephone number: +44 (0) 3700422200

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review. Historic versions can be obtained by contacting us.

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

Third-party links

This Site and our App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site or App, We encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you when you use our Site and App, buy Products and Services from us, which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Health data includes health, biological samples, test information, results, data or other information relating your medical history or status as well as any health questionnaire you are required to complete for the purposes of receiving the Products and Services provided.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of Products and Services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Site, App, Products and Services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic 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 Usage Data to calculate the percentage of Users accessing a specific website feature. 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.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, online or otherwise. This includes personal data you provide when you:
• purchase our Products or Services
• create an Account on our App
• subscribe to receive communications or publications
• request marketing to be sent to you
• enter a competition, promotion or survey or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU;

(b) Third party tools used for monitoring app performance and supporting app functionality such as Google based outside the EU

(c) inbound paid advertising or social media links such as Facebook or Instagram,based inside and outside the EU; and

(d) search information providers such as Google based outside the EU;

(e) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.

4. How We use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into 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 obligation.

We rely on your explicit consent to process your personal information as follows:

• To receive, share, store and analyse your Samples at our Affiliated Laboratories;
• To receive, store, review and communicate your Test Results to you and provide this and any other reported history in and through the iPlaySafe App secure environment.
• To provide you with your Test Results and where appropriate, relevant follow-up guidance.
• To share your Results, with other iPlaySafe Users, as specified by you.
• To de-personalise your information for service improvement, product or experience quality improvement and/or research, as relevant.

You have the right to withdraw consent to this processing at any time. Withdrawing your consent will stop all future processing and does not affect any processing undertaken however it means we may not be able to perform the contract we have (or are trying to enter) with you for the provision of our Products and Services. In this case, we may have to cancel a Product or Service you have with us but we will notify you if this is the case at the time.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Products, Services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the purchase of Products and Services from us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site or App may become inaccessible or not function properly. For more information about the cookies we use, please see www.iplaysafe.app/cookie-policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the following purposes:

• Service providers acting as processors based in the UK and Ireland who provide IT and system administration services, including hosting, data testing, payment processing and communication and marketing, testing kit and courier companies.
• Professional advisers acting including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Affiliated Laboratories acting as processors based in the UK who provide medical testing analysis and storage services.
• 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.

We would like to ensure that you understand how your personal data will be processed in particular with regards to your Health Data so please read the next section carefully. In order to fulfil your contract for the Products and Services, we will share your Health Data with our Affiliated Laboratories. This means they will have access to your first and surname, date of birth, gender, address and postcode, Samples, information relevant to your test and Test Results strictly in order to carry out the Services. You can contact us direct if you have any questions regarding your data.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

App share Status feature

A unique feature of our App is the ability to share your Test Results Status with other Users selected by you. Any Status share sent or received is at your discretion and relies on your explicit consent to share. You agree that you will comply at all times with the Terms of Use and Privacy Policy together with any and all user guidance and guidelines. Features built into the design of the Status share to protect your privacy includes a technical measure preventing screen grabbing or screenshotting (where your device and operating system permits) and a time-limit on the availability of the share. No profile details such as User name or photo is available on a share. A Status share can be deactivated or withdrawn by you at any time during the share.

6. International transfers

We do not currently transfer your personal data outside the UK and European Economic Area (EEA).

7. Data security

We have put in place and maintain appropriate physical, electronic, standard security practices including encryptions, passwords and physical security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

We will only retain your results data on the iPlaySafe App platform for two (2) years from the date your Test Results are received. Your original Test Results, as reported by our Affiliate Laboratory, may be retained by them for longer in accordance with their legal obligations defined by their own policies in accordance with the Royal College of Pathologists Retention and Storage of Pathological Records and Specimens (5th Edn, 2015)

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 unauthorised 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.

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 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 consent form or online consent history will be retained indefinitely under strict access control on our database to prove your consent to the processing of your Health Data.

Unless required to do so by law, we will never otherwise share, sell or distribute any of the information you provide to us without your consent.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below:

Request access to your personal data (or "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:

• 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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.

If you wish to exercise any of the rights set out above, please contact us at contact@iplaysafe.app

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

This Policy is dated: 08 July 2021