Pogo Studio Ltd Privacy Policy for Tailored Talks
Introduction
This is the privacy policy for Pogo Studio Ltd.
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our Tailored Talks service (“Tailored Talks”) either via the mobile or website app. .
We reserve the right to change this privacy policy from time to time by changing it and notifying you next time you access Tailored Talks.
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 your personal data. This website is not intended for children and we do not knowingly collect data relating to children.
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.
Controller
Pogo Studio Ltd (Company Number SC542667) with its registered office at Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, EH4 2HS is the controller and responsible for your personal data (collectively referred to as "Pogo", "we", "us" or "our" in this privacy policy).
We have appointed a data privacy manager 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 data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Pogo Studio Ltd Email address: info@pogo-studio.com
Postal address: Pogo Studio, 37a Castle Terrace, Edinburgh EH1 2EL
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. This version was last updated in May 2022.
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.
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 which we have grouped together as follows:
-
We store the following data for both patients and clinicians:
- Email Address
- CHI Number
- First Name
- Last Name
- Title
- Date of Birth
- Gender
- Address
- Telephone Number
- Secondary Telephone Number
- Device Platform
- Device ID
- Medical Information (may include details such as: current health condition, pre-existing conditions, date of diagnosis, GP/surgery registration, severity of condition(s), work/life information such as employment status and accessibility requirements)
- Technical Data includes internet protocol (IP) address, 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 website.
- Usage Data includes information about how you use Tailored Talks.
- 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 feature within Tailored Talks. 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.
We do not collect any Special Categories of Personal Data about you as a Controller (this 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). Nor do we collect any information about criminal convictions and offences.
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 and Contact Data when you register to use Tailored Talks.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies.
4. HOW WE STORE YOUR PERSONAL DATA
Our product uses the following security policies for securely storing data:
Patient personal information is stored with encryption at rest using AES-256 and all data is encrypted for data transfer via SSL TLS 1.2.
We use Microsoft Azure for data storage and processing.
5. 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 for use of Tailored Talks.
- 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.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Where we need to collect personal data by law or to provide our services to you under a contract we have with you, and you do not agree to us collecting your personal data, we will not be able to perform our services. In this case, we will have to cancel the services you have with us.
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 grounds we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as an authorised user of Tailored Talks |
|
Performance of a contract Legitimate interests |
|
To manage our relationship with you which will include:
|
|
|
|
To use data analytics to improve our business, marketing, customer relationships and experiences |
|
Necessary for our legitimate interests (to define types of customers for our products and services, to develop our business and to inform our marketing strategy) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical and Usage 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 or purchased goods or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will not share your personal data with any third party for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by contacting us at info@pogo- studio.com.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transaction.
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.
Your user data will not be shared with any third-parties without your explicit consent. Where you have provided explicit consent, this can be withdrawn at any time by contacting us or the relevant third party.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the tables at paragraph 4 above.
- Service providers who provide payment, marketing, IT and system administration services.
- Regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances, especially in the prevention of money laundering and fraud.
- 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 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.
7. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside of the UK.
8. DATA SECURITY
We have put in place appropriate 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.
9. 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.
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.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Access to information: You have the right to request a copy of the information we hold about you.
- Ensuring accuracy of information: We want to make sure that your personal information is accurate and up-to-date. You may ask us to correct or complete information that is inaccurate or incomplete.
- Right to erasure: You may have a right to erasure, which is more commonly known as the ‘right to be forgotten’. This means that in certain circumstances you can require us to delete personal information held about you.
- Ability to restrict processing: You may also have the right to require us to restrict our use of your personal information in certain circumstances. This may apply, for example, where you have notified us that the information we holds about you is incorrect and you would like us to stop using such information until we have verified that it is accurate.
- Right to data portability: You may have the right to receive personal data we hold about you in a format that enables you to transfer such information to another data controller (e.g. such as another service provider).
- Review by an independent authority: You will always have the right to lodge a complaint with a supervisory body, including ICO as listed above.
- Preventing direct marketing: We do not sell your personal data. From time to time, we may send emails containing information about new features and other news about us. This is considered direct marketing. We will always inform you if we intend to use your personal data or if we intend to disclose your information to any third party for such purposes.
- Objecting to other uses of your information: You may also have the right to object to our use of your information in other circumstances. In particular, where you have consented to our use of your personal data, you have the right to withdraw such consent at any time.
If you would like further information on how you can exercise these rights, please email us at info@pogo-studio.com.
No fee is 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.
11. DELETEING YOUR USER DATA
If you would like to delete all of your user data, please email helpdesk@tailoredtalks.com to make this request.
12. IF YOU DISCOVER A CHILD IS USING TAILORED
We do not intentionally collect data on children under 18. If you discover a minor using our product or service, please email helpdesk@tailoredtalks.com to notify us and we will take steps to remedy.
