Privacy Statement for App

Privacy Statement

  1. Introduction

1.1 MOODY is brought to you by We Are Moody Limited (“MOODY”, “our”, “we” or “us”). This privacy statement explains how we use your personal information to provide you with the MOODY mobile application (the “MOODY App”) and other services offered by us (the "Services").

1.2 We are committed to protecting and respecting your privacy. We ask that you read this Privacy Statement carefully as it contains important information about what personal information we may collect from you and how we will use it. Questions, comments and requests regarding this Privacy Statement are welcomed and should be sent to [email protected].

1.3 This Privacy Statement should be read in conjunction with our Terms of Use. We strongly encourage you to review both this Privacy Statement and the Terms of Use carefully and ensure that they contain everything you want and nothing that you are not prepared to agree to, before you decide to accept the Terms of Use and use the MOODY App and Services.

1.4 Unless otherwise stated, any capitalised term used in this Privacy Statement will have the same meaning as the same defined term in the Terms of Use.


2. ABOUT US

2.1 We Are Moody Limited is a company registered in England and Wales with company registration number 10047636. Our registered office is at 24 Greville Street, Farringdon, London, EC1N 8SS.

2.2 For the purpose of the General Data Protection Regulation (EU) 2016/679 and the Data Protection Act 2018 (together “Data Protection Legislation”), we are the ‘data controller’ (i.e. the company which determines the purposes and means of the processing of your personal information).

2.3 Our Data Protection Officer is Louise Marshall of Dragon Argent Limited. She can be contacted at [email protected] .


3. WHAT INFORMATION DO WE COLLECT?

3.1 We collect data to operate effectively and provide you the best experiences with our MOODY App and Services. We may collect and process the following data about you:

  1. Account information. The information that you provide to us when creating and updating an account on the Moody App, including your name, username, and e-mail address. We may also receive voice recordings from you if you use any voice recognition tool available in the MOODY App to update your MOODY Account.
  2. Health and wellbeing information. The information relating to your health and wellbeing which you provide to us via logs, voice notes or notes which you submit through the Moody App or when interacting with us and the MOODY App. This may include health information relating to your:
  3. menstrual and hormonal health, including physical and mental symptoms and conditions (such as mood, depression and anxiety) and the frequency of your period;
  4. diet and weight, including food intolerances and appetite;
  5. lifestyle and wellbeing, such as frequency of exercise, energy levels, sleeping habits, libido, skin and hair conditions, smoking habits, consumption of alcohol and use of drugs; and
  6. exposure to pollution and chemicals. 
  7. Location information. If you allow us to connect to your device’s geolocation functionality, we may collect your location data by use of GPS and wifi data. You can turn off the MOODY App’s ability to access your geolocation at any time through your device’s general or privacy settings.
  8. Device information. This includes information about the device you may use to use the MOODY App and Services, such as the device's identifiers, operating system, and browser type and network information.
  9. Log information. Information relating to your use of the MOODY App, including the full Uniform Resource Locators (URL), clickstream to, through and from the MOODY App (including date and time), products and Services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as clicks), and methods used to browse away from the page.

4. WHY DO WE COLLECT THIS INFORMATION?  

4.1 We use the information we collect to:

  1. provide the MOODY App and the Services;
  2. allow you to create an account on the MOODY App;
  3. provide you with supplement and wellbeing recommendations and other content based on your logs;
  4. communicate with you within the MOODY App and via email with information which we feel is could be helpful to you (please see section 6 (Marketing) for further information);
  5. fulfil your orders for any products or Services purchased on the MOODY App; and
  6. facilitate or contribute to research activities (please see section 5 (Research) for further information on this).

4.2 We also use information that we collect about you for operational purposes, including to:

  1. provide customer services, including responding to your enquiries, fulfilling any of your requests for information and notifying you about changes to our MOODY App and Services;
  2. improve our MOODY App and Services and to ensure that content is presented in the most effective manner for you and your device;
  3. administer our MOODY App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
  4. comply with applicable laws, to enforce our rights or to respond to requests from law enforcement and other government authorities.

4.3 We use your personal data pursuant to one or more of the following legal bases as prescribed by Data Protection Legislation :

  1. to enable us to provide you with access to the MOODY App and the Services, in accordance with the agreement between you and us (as set out in our Terms of Use);  
  2. to comply with a legal obligation and/or 
  3. where it is in our legitimate interest to do so and we have indicated to you what that interest is.

4.4 Where we are processing special categories of personal data logged by you on the MOODY App (such as data revealing information about your health) our grounds for processing are your explicit consent. You provide this explicit consent when you log health and wellbeing information or add voice notes or notes containing health and wellbeing information to your MOODY Account. 



5. RESEARCH

5.1 We may share anonymised data about users of the MOODY App with research institutions. This will help them to carry out research on health and wellbeing, with the intention to improve women’s health. The type of anonymised data that that we might share with those research institutions could include mood, period and sleep data. As the data is anonymised, it will not identify any individual and therefore will not be personal data.

5.2 You are given the choice as to whether you would like your data to be used in this way, by opting in when creating an account on the MOODY App. If you opt in but later change your mind and do not want to your data to be used in this way, please contact us at [email protected].


6. MARKETING

6.1 6.1 Where permitted, we may contact you with information about products and services that we feel may interest you. None of these communications will be informed by or related to HealthKit information.

6.2 You will be given the right to ask us not to process your personal data for marketing purposes. You are given the opportunity to opt in and opt out of marketing emails on creation of an account on the MOODY App. If you change your mind and do not want to receive any marketing emails from us, you can remove yourself by following the unsubscribe directions provided in the footer of our emails, or by contacting us at [email protected].


7. WHO WE MIGHT SHARE YOUR INFORMATION WITH?

7.1 We will never share or sell your personal information to any third parties except in the ways described below, or with your consent:

  1. Suppliers. We employ other companies and individuals to perform functions on our behalf, including data analytics and other IT suppliers (for example, MailChimp). We do not share your personal information with our agents or suppliers except as is necessary in order to enable them to provide us with a service and then only pursuant to our express instructions.
  2. Wellness advisors. We may share your personal information with third party wellness advisors if you participate in a virtual drop in clinic (as explained in our Terms of Use), and you may disclose personal information to them when participating.
  3. Other reasons. We may also share your personal information with a purchaser or potential purchaser of our business and in some circumstances, we may have to disclose your personal information by law, either because a court or the police or other law enforcement agency has asked us for it, to enforce our legal rights, or to prevent fraud.
  4. We may also share anonymised data with research institutions, as described in more detail at section 5 (Research).  


8. Where we store your personal data  

8.1 The data that we collect from you will be transferred to, and stored at, destinations inside and outside the European Economic Area (“EEA”), including the United States of America. It may also be processed by staff operating outside the EEA who work for our suppliers. By submitting your personal data via the MOODY App and using the Services, you agree to the transfer, storing or processing of your personal data outside of the EEA.

8.2 MOODY will comply with its obligation under data privacy laws to ensure appropriate safeguards are in place to provide an adequate level of protection of any personal data transferred to a destination outside of the EEA. If you would like more information as to the safeguards in place, please contact us at [email protected].


9. SECURITY

9.1 We take all steps reasonably necessary to ensure that your personal data is treated securely. In particular, all information you provide to us is stored on our supplier’s secure servers (including within the ‘cloud’) and any information we process relating to your payment transactions will be sent over an encrypted connection or other secure networks. We will also anonymise your personal information before sharing with third parties for research purposes (where you have permitted us to share such data). You should be aware, however, that the transmission of information via the Internet is not completely secure.

9.2 Where you have chosen a password which enables you to access certain parts of our MOODY App, you are responsible for keeping this password confidential.

9.3 Unless you are exercising certain specific legal rights, we will continue to hold your personal information for a period of 12 months after the date on which you terminate your MOODY Account or, if relevant, for as long as is necessary to comply with any legal obligations.


10. THIRD PARTY LINKS

10.1 Our MOODY App contains links to the websites of our partner networks and affiliates. For example, online retailers where you can click through and view and purchase supplements and vitamin products.

10.2 If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.


11. YOUR DATA RIGHTS  

11.1 You may have the following rights:

You may request details of the personal information that we hold about you under Data Protection Legislation . If you would like a copy of the information held about you please write to us at [email protected].

11.2 If you think any information we have about you is incorrect or incomplete, please write to us or email us at [email protected] as soon as possible. We will correct or update any information as soon as reasonably practicable.

11.3 You may have additional rights in relation to our handling of your personal data under Data Protection Legislation. For example, the right to have your personal data erased, the right to object to or restrict us from processing your personal data, and the right to data portability. If the legal basis for our processing your personal data or special category data is consent or explicit consent, as appropriate, you have the right to withdraw your consent at any time. Please note that if you withdraw your consent, the lawfulness of any processing undertaken before such withdrawal will not be affected. If you would like to exercise any of these rights at any time, please write to us or email us at [email protected]. Please be aware that we will have to verify your identity before we respond to any such request.  

11.4 Should you have any complaints about how we handle your personal information, please contact us at [email protected]. Should we be unable to resolve your complaint and you wish to take your complaint further, you may do so by contacting the UK Information Commissioner’s Office. 


12. CHILDREN’S PRIVACY  

12.1 We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected].



13. UPDATES TO THIS PRIVACY STATEMENT

13.1 Any changes we make to our Privacy Statement in the future will be made available to users via the MOODY App Please check back frequently to see any updates or changes to our Privacy Statement. If we make material changes to this Statement, we will notify you, such as by email or through the platform.


Last updated: February 2019

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