Privacy Policy – Salus Optima

Welcome to our Privacy Policy. Salus Optima is brought to you by L3M Technologies Limited (t/a Salus Optima) with registered office at 15 Westferry Circus, Canary Wharf, London, United Kingdom, E14 4HD (“we”, “us” or “our”), with company number 11157173.


  1. OUR APPROACH


    Your privacy is critically important to us. This Privacy Policy sets out how we process personal information about you when you use any part of the Salus Optima mobile application (“App”), including the related online documentation, including any questionnaires and all other content and media provided to you on the App, for example:

  2. THE INFORMATION WE COLLECT AND HOW WE COLLECT IT


    Personal data, or personal information, means any information about a person from which they can be identified. We may collect, store, and use some or all of the following categories of personal information about you:


    Identity Information


    Subject to your explicit consent, we may also collect, store and use your health data. This is considered a special category of more sensitive data. Where we process health data, it will be treated confidentially and will never be used for direct marketing purposes.


    System Information


    When you log on to and interact with our App we automatically collect information about your use of the App including details of your visits such as pages viewed and the resources that you access. This information will include traffic data, location data, IP address, browser, operating system, referral source, length of visit, clickstream data and other communication data.


    Identity Information


    We collect Identity Information provided voluntarily by you. For example, when you register with or use our App (by entering training plan details, goals, or making a booking).


    We also collect Identity Information when you fill out a form or questionnaire or contact us (by email or telephone) to ask a question or request information.


    We also collect Identity Information through various other mobile applications (including the Apple Health app and Google Fit app) where you give us explicit consent to do so (detailed further below).


    Location Data


    We also use GPS technology, Bluetooth, crowd-sourced WIFI hotspots and other sensors (such as accelerometers) to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.


  3. HEALTH DATA


    In order to provide our Services to you, we may be required to process special category data, for example your health information. Where we process this special category data, data protection law requires that we satisfy certain additional conditions. We will only process special category data with your explicit consent to the processing.


    In particular, we may ask you to grant us access to the Health app on your Apple device or the Google Fit app on your Android device, as well as other relevant 3rd party devices and services (e.g. Fitbit, Garmin, or others), and to share with us the health data which is collected, processed and stored as part of these products and services. You decide what information goes into the Health or Google Fit app and what information we can get from it. By allowing us access to that health data you are granting us explicit consent to process it in accordance with this Privacy Policy.


  4. HOW WE WILL USE YOUR PERSONAL DATA


    Providing our Services


    As part of the provision of our Services, we may use the personal information that we collect from you to:



    Marketing


    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 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 or purchased goods or services from us and you have not opted out of receiving that marketing.


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


    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 a product/service purchase, product/service experience or other transactions.


  5. GROUNDS FOR PROCESSING


    Data protection law says we only have the right to use your personal information where we can identify a lawful basis for doing so. Please see below for details of the legal bases on which we rely to do so:


    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.


  6. INFORMATION SECURITY


    The Internet is not a secure medium. However, we have put in place various security procedures as set out in this Privacy Policy.


    Please be aware that communications over the Internet, such as emails and online messages are not secure unless they have been encrypted. Your communications may route through a number of

    countries before being delivered – this is the nature of the Internet. We cannot accept responsibility for any unauthorised access or loss of personal data that is beyond our control.


    We believe that we have appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that personal data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.


  7. DISCLOSURE OF YOUR PERSONAL INFORMATION


    We will not share your personal information with or to third parties, except as otherwise provided for in this Privacy Policy and under the following limited circumstances when we want to or are compelled to share your personal information, including:


  8. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION


    We may transfer the personal information we collect about you outside the country you are located in in order to perform our contract with you. Where this occurs we will ensure that your personal information receives an adequate level of protection and we will put in place appropriate measures to ensure that your personal information is treated in a way that is consistent with UK laws on data protection. If you require further information about these protective measures, you can request it by contacting us at support@salusoptima.com.


  9. SECURITY AND RETENTION


    We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also have procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.


    We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.


    To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your information, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal requirements.


  10. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION


    Under certain circumstances, by law you have the right to:


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


    We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.


  11. LINKED WEBSITES OR APPLICATIONS


    The App may include links to third-party sites, 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 sites and are not responsible for the privacy policies and practices of other websites even if you accessed the third party website using links from our website. We recommend that you check the policy of each website you visit before deciding whether to proceed and contact the owner or operator of such website if you have concerns or questions.


  12. CHANGES TO THIS PRIVACY POLICY


    We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.


  13. JURISDICTION AND APPLICABLE LAW


    English law governs this Privacy Policy, its subject matter and its formation. The courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.


  14. OTHER IMPORTANT TERMS


This Privacy Policy (together with our Terms of Use) constitute the whole agreement between us and supersede all previous discussions, correspondence, negotiations, previous arrangement, understanding or agreement between us relating to the provision of Services via our App.


If any of the terms of this Privacy Policy are found by any competent authority to be invalid, unlawful or unenforceable to any extent, such term, condition or provision will to that extent be severed from the remaining terms, conditions and provisions which will continue to be valid to the fullest extent permitted by law.


If we delay in taking steps against you when you break this contract, that will not mean that you do not have to do what we ask in order to remedy your breach and it will not prevent us taking steps against you at a later date.


If you have any concerns about this Privacy Policy, please contact: support@salusoptima.com

Last updated: July 2023



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