Intempo Fit Privacy Notice

Intempo Fit Privacy Notice

Intempo / Ultimate Products UK Limited – Privacy Notice

Date: October 2023

Who We Are

Intempo Fit mobile application is part of Ultimate Products UK Limited (‘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://intempo.co.uk/privacy-notice/.

Ultimate Products 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 GDPR Company Representative, and contact details are available at the foot of this notice.

Information That We Collect

Your device is what is known as an Internet of Things Device (IoT device), this means that you can control itusing our App on your smart phone or other device through the internet as long as you have a connection to the internet. 

For this to work the App needs to collect personal information, which is information that may identify you directly or indirectly. We are committed to protecting the privacy and security of your personal information and this document is designed to explain to you what types of personal information is collected, why it is collected and what happens to it. This document is aimed at users of the App only, if you have purchased a product directly from us there is further privacy information available relating to that sale. For this further information please follow the “Privacy” link at the bottom of our website. 

It is important that you read this document thoroughly along with any other privacy information we have provided and if you have any questions or if there is anything you do not understand please do not hesitate to contact us using the contact details at the end of this document.

Please note it is very important that you only download the App from an official App stores and not from any websites and that you keep the App updated at all times via the official App store in order for you to receive the best and most secure of experiences. It is also important you never share your password with anyone else or let anyone else use the App.

 

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: -

  • Name, Email address, password and a unique identifier of your IOT device, the device in which you install the App and any IP or Mac addresses – This is collected and used to ensure you can securely connect your App to your IOT device and to securely use its functionality.
  • Location Data – in certain circumstances, where you have allowed this in the App, location data is collected. This is so certain features of the App functional correctly. 
  • App usage – We may also monitor App usage and use any of the above information in order to ensure network, App and information security and availability, including preventing unauthorised access to or attacks on the App or any of its associated infrastructure and to prevent any malicious software distribution. 
  • Smart Device Data: When the users use Smart Devices that are connected to our Services, depending on the capability of your Smart Devices, we may collect certain types of your data in order to provide your services you have requested or purchased, such as videos, images, health related data etc. “Smart Devices” refers to those nonstandard computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc.
  •    Date of birth
  •     Sex
  •     Athlete Mode Status (details of activity levels)

Special Category Data (data related to Health)

  •     Height
  •     Weight
  •     Blood Pressure
  •     Heart Rate
  •     Sleep
  •     SPO2
  •     Fatigue

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 18 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
  •    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 and track your goals. 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 have teamed up with world leading App developers based in China, these help us administrate and further develop the App. In addition, the App uses Amazon Web Servers; a leader in cloud computing, to store your personal data, this data is stored on servers based within the European Union.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. 

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 Ultimate Products 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 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.

Ultimate Products UK Limited

Compliance Department

Manor Mill

Victoria Street

Manchester

OL9 0DD

UNITED KINGDOM

Email: data-protection@upplc.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