OVE CARE LIMITED – DATA & PRIVACY POLICY

Ove Care Limited, a company registered in England and Wales, with company number, 15007682 (Ove, we, us or our), understands that protecting your personal data is important.

At Ove, we believe that technology and data present a groundbreaking opportunity to empower people to take control of their health. The Ove app gives people the ability to understand what is going on inside of their bodies and minds based on individual tracked health data, providing self-insight and self-advocacy that’s powered by data processing.

We also fully acknowledge the responsibility that comes with being the safe keepers of intimate personal data which is tracked by people using Ove. Which is why we are always striving to achieve the highest standards of privacy and security. Keeping your data safe is at the core of everything we do.

We see it as our job to be clear and transparent so that you can truly understand what we do with your data, even though the digital ecosystem of an app is complex. To provide our service as a health education app, we rely on a number of other providers as summarised below to help us.

This Data & Privacy Policy sets out our commitment to protecting the privacy of personal data provided to us, or otherwise collected by us when providing our Ove app and website for you to use (Services) or when otherwise interacting with you.

It is important that you read this Data & Privacy Policy together with any other detailed privacy notices we may provide when we are collecting or processing personal data about you so that you understand our privacy practices in relation to your data.

If you have any questions, reach out to us at ovecare.com

The information we collect

Personal data: is information that relates to an identified or identifiable individual.

We may collect, use, store and disclose different kinds of personal data about you which we have listed below:

Identity Data including first name, middle name, last name, title, date of birth, gender.

Contact Data including billing address, email address and telephone numbers.

Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.

Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and approximate location data (but not your precise location), device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.

Profile Data including your username and password for the Ove app, purchases or orders you have made with us, support requests you have made, content you post, send, receive and share through the Ove app, information you have shared with our social media platforms, your interests, preferences, feedback and survey responses.

Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys, contests, promotions, activities or events.

Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

Special Categories of Personal Data is a special category of personal data that 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.

In order to provide our service as a health education app, the types of special categories of data we may collect are those which you choose to track in the Ove app (if allowed through the Ove app), including your menstrual cycle information (e.g. period length, pain, or spotting), and depending on the data you provide, it may also contain other sensitive data about your experiences (e.g. weight, body temperature and hair quality). We only process the health data you choose to share with the Ove app via tracking. You may use different methods provided by the app to track your health data in the Ove app. This can include manually entering your data into the Ove app, or importing your data from other integrations or devices supported by Ove (such as Apple Health or fitness trackers).

How we collect personal data

We collect personal data in a variety of ways, including:

Directly: We collect personal data which you directly provide to us, including when you register for an account (via the Ove app or on our website), through the ‘contact us’ form on our website or when you request our assistance via email, social media or over the telephone.

Indirectly: We may collect personal data which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.

From third parties: We collect personal data from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

From publicly available sources: We collect personal data from publicly available resources.

Purposes and legal bases for processing

We collect and process personal data about you only where we have legal bases for doing so under applicable laws. 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 reach out to us if you need further 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.

Purpose of use / disclosure Type of Data Legal Basis for processing
To enable you to access and use the Ove app, including to provide you with a login.
  • Identity Data
  • Contact Data
  • Performance of a contract with you
To provide our Services to you.
  • Identity Data
  • Contact Data
  • Performance of a contract with you
To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us and via our AI chat bot in the Ove app.
  • Identity Data
  • Contact Data
  • Profile Data
  • Performance of a contract with you
To contact and communicate with you about any enquiries you make with us via our website.
  • Identity Data
  • Contact Data
  • Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions.
For internal record keeping, administrative, invoicing and billing purposes.
  • Identity Data
  • Contact Data
  • Financial Data
  • Transaction Data
  • Performance of a contract with you
  • To comply with a legal obligation
  • Legitimate interests: to recover debts due to us and ensure we can notify you about changes to our [terms of business] and any other administrative points.
For analytics including profiling on the Ove app, scientific research and business development, including to operate and improve our Services, associated applications and associated social media platforms.
  • Profile Data
  • Technical and usage Data
  • Legitimate interests: to keep our website updated and relevant, to develop our business, improve our Services and to inform our marketing strategy
For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.
  • Identity Data
  • Contact Data
  • Technical and usage Data
  • Profile Data
  • Marketing and communications Data
  • Legitimate interests: to develop our Services and grow our business
To run promotions, competitions and/or offer additional benefits to you.
  • Identity Data
  • Contact Data
  • Profile Data
  • Interaction Data
  • Marketing and communications Data
  • Legitimate interests: to facilitate engagement with our business and grow our business
To help you track your health in the Ove app, either manually or through import integrations, in order to provide our core service as a health education and tracking app.
  • Special categories of personal data
  • Consent
To provide you with recommendations based on the health information you decide to track.
  • Special categories of personal data
  • Consent
To provide you with customer service, including through the AI chat bot in the Ove app.
  • Special categories of personal data
  • Consent
For analytics, to help us build more valuable features in Ove, so that we can better understand how our community uses the Ove app and further tailor the experience to fit their needs.
  • Special categories of personal data
  • Consent
To allow recommendations and deliver you more personalised insights from the Ove app based on how you interact with the Ove app, via in-app messages, emails, and push notifications (if you’ve enabled permissions on your device).
  • Account data
  • Special categories of personal data
  • Consent
To allow our scientific and research partners to carry out scientific research and studies. See section below.
  • Special categories of personal data
  • Consent
To comply with our legal obligations or if otherwise required or authorised by law.
  • All relevant Personal Data
  • To comply with a legal obligation

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services. Further information about your rights is available below.

We may use your health data to help advance scientific research

To help advance menstrual and reproductive health studies, we share relevant de-identified health data you’ve tracked in the Ove app with carefully selected research partners to be used in their scientific studies.

When you track in Ove, your data becomes something powerful. It can help answer questions to better understand menstrual and reproductive health. Women and people with cycles are still widely underrepresented in health research. We believe that the data tracked in Ove can change this. By teaming up with our trusted research partners we can advance research, break harmful taboos and lay the groundwork for better healthcare.

We only share data that is directly relevant to the research question and follow strict protocols to ensure your data always remains anonymous to the researchers. We use a de-identification technique which means all personal identifiers like your name and email address are erased. Your dataset is then assigned a random ID, making sure you can’t be identified by the researchers.

If you are a participant in a scientific study that is run by a research facility using Ove as a tool to collect information for that study, then Ove will share your personal information with the research facility only under the terms of your consent as given to that research facility. When you use Ove as part of a scientific study, we will otherwise treat your personal data with the same care as we do all user data. The research facility will be solely responsible for the usage of your personal data, including health data, in the context of their scientific study. We consider that Ove and our partnered research facilities have joint responsibility ("joint controllership" under GDPR) in this case.

Our disclosures of personal data to third parties

We may disclose personal data to:

our employees, contractors and/or related entities;

IT service providers, data storage, web-hosting and server providers such as Amazon Web Services EMEA SARL, Google Firebase, Sparkpost (for transactional emails (such as “I lost my password” or “Verify your Ove account” emails), Twilio for our messaging gateway via the Ove app;

our partners, such as Amazon Affiliate;

marketing or advertising providers;

professional advisors, bankers, auditors, our insurers and insurance brokers;

payment systems operators;

our existing or potential agents or business partners;

sponsors or promoters of any promotions or competition we run;

anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;

courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time); and

any other third parties as required or permitted by law, such as where we receive a summons.

Google Analytics: We have enabled Google Analytics Advertising. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Overseas transfers

Where we disclose personal data to the third parties listed above, these third parties may store, transfer or access personal data outside of the United Kingdom, including United States (twilio). The level of data protection in countries outside of the United Kingdom may be less comprehensive than what is offered in the United Kingdom. Where we transfer your personal data outside of the United Kingdom, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal data in accordance with this Data & Privacy Policy. This includes:

only transferring your personal data to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal data; or

including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

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.

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.

Your rights and controlling your personal data

Your choice: Please read this Data & Privacy Policy carefully. If you provide personal data to us, you understand we will collect, hold, use and disclose your personal data in accordance with this Data & Privacy Policy. You do not have to provide personal data to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal data about you from a third party, we will protect it as set out in this Data & Privacy Policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have such person’s consent to provide the personal data to us.

Access, correction, processing and portability: You may request details of the personal data that we hold about you and how we process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal data rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal data to a third party and, in some circumstances, to have personal data relating to you transferred to you or another organisation.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Withdraw consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. 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.

Complaints:If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. 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 (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.

Storage and security

We are committed to ensuring that the personal data we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal data and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our website in the future. Cookies are text files placed in your computer's browser to store your preferences.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal data which you provide whilst visiting those websites. Those websites are not governed by this Data & Privacy Policy.

Personal data from social network accounts

If you connect your account with us to a social network account, such as Facebook / Google, we will collect your personal data from the social network. We will do this in accordance with the privacy settings you have chosen on that social network

The personal data that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or follows and any other personal data you choose to share.

We use the personal data we receive from the social network to create a profile for you on the Ove app.

If you agree, we may also use your personal data to give you updates on the social network which might interest you. We will not post to your social network without your permission.

Where we have accessed your personal data through your Facebook account, you have the right to request the deletion of personal data that we have been provided by Facebook. To submit a request for the deletion of personal data we acquired from Facebook, please send us an email at the address at the end of this Data & Privacy Policy and specify in your request which personal data you would like deleted. If we deny your request for the deletion of personal data, we will explain why.

Use of geo-localisation data

We collect your approximate location via our mobile application for the following purposes:

for statistical and analytics purposes;

for regulatory compliance in different countries; and

as permitted by law.

We collect this information when our mobile application is open (whether on-screen or not). If you do not want us to use your location for the purposes above, you should turn off the location services in your account settings in the mobile application or in your mobile phone settings. If you do not provide location information to us, we may not be able to provide our Services to you.

Amendments

We may change this Data & Privacy Policy from time to time. We will notify you if we make a significant change to this Data & Privacy Policy, by contacting you through the contact details you have provided to us and by publishing an updated version on our website. For any questions or notices, please contact our data protection officer (DPO) or our EU Representative if you are based in the European Union at:

Ove Care Limited, a company registered in England and Wales, with company number, 15007682.

Privacy manager: libbytg@ovecare.com

Last update: 20 May 2024

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