(Updated April 2024)

1. Introduction

This notice explains how we process personal data, as a data controller, relating to:

• visitors (“Website Users”) to our website: https://www.insightapplimited.co.uk/ (“Website”); and
• users (“Mobile App Users”) of our mobile apps (“mobile apps”), which are accessible via certain online stores, including:

• the Google Play Store https://play.google.com/store/apps/details?id=life.femin.pregnancy.period

and together the Website Users and Mobile App Users shall be the “Users” (and “you” and “your” shall refer to any User).

We update this notice from time to time, so Users should check back in on a regular basis.

Please note that other websites or services mentioned on the Website or our Apps are not operated by us, and you should refer to the privacy policies on those websites to understand how their personal data is being used.

We are committed to safeguarding the privacy of our website and mobile apps visitors and users. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

In this policy, "we", "us" and "our" refer to Insight App Limited. For more information about us, see Our Details.

2. The personal data that we collect

We collect the following general information when you sign up for our services if you choose to give so:

General:

• Name
• Email address
• Year of birth
• Password
• Place of residence
• Location information, including time zone and language preference
• Inferred information about sex and/or gender based on your usage patterns within the Services

Personal Data Input:

When you use our services, you may choose to input personal data related to your well-being, including:

• Weight
• Height
• Body mass index (BMI)
• Body temperature
• Menstrual cycle dates
• Details of pregnancy (if pregnancy mode is selected)
• Other symptoms related to menstrual cycle, menopause, pregnancy, general well-being, and health
• Symptoms, including information related to your sex life
• Other information related to your physical and mental well-being

Automatically Collected Personal Data:

We automatically collect certain personal data to enhance your user experience and improve our services, including:

Device Information:

• Device model
• Information about the operating system and its version
• Unique device identifiers
• Enabled device accessibility features (e.g., display features, hearing features, physical and motor features)
• Mobile operator and network information
• Device storage information
• Version of your device system

Location Information:

• IP address
• Time zone
• Information about your mobile service provider

Data About Your Use of the Services:

We gather data about how you interact with our services, including:

• Frequency of use
• Areas and features of the services accessed, visited, or used
• Payment information
• Engagement with particular features
• Your actions within the app

3. Purposes of processing and legal bases

Purposes:

We utilize your personal data for various purposes, including but not limited to:

• Functioning: Supporting the existing functions of the App, including customization of content and materials you see when using the App.
• Account Management: Processing transactions and sending you related information, including confirmations and reminders for account management and other administrative purposes.
• Review: Reviewing App content, feedback, and complaints raised to ensure clinical safety and medical accuracy of the App.
• Technical Notices: Sending you technical notices and updates, investigating incidents, and sending security alerts. Sending you support and administrative messages.
• Analysis: Monitoring and analyzing trends, usage, and activities in connection with our App.
• Device Identification: Identifying the device used to access our services.
• Improving Service: Providing better service, making suggestions, and improving the services we offer.
• Syncing Progress: Syncing users' progress across devices when the user logs in to the account with third parties and performing essential business operations.
• Administering and Protecting Services: Administering and protecting our Services, including troubleshooting, data analysis, testing, support, fraud prevention, reporting, and hosting of data.
• Participation in New Features: Allowing you to participate in new features of our services when you choose to do so.
• Personalized Advertisements: Serving personalized advertisements in our services using third-party advertising networks.

Legal Basis:

• Consent:

• We may process your personal data based on your consent, which you provide voluntarily and explicitly for specific purposes. You have the right to withdraw your consent at any time.

• Contractual Necessity:

• We may process your personal data when it is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract. This includes providing the services you requested and fulfilling our obligations under any agreements with you.

• Legitimate Interest:

• We may process your personal data when it is necessary for our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. Our legitimate interests may include improving our services, ensuring the security of our systems, preventing fraud, and conducting marketing activities.

• Legal Obligation:

• We may process your personal data when it is necessary to comply with a legal obligation to which we are subject. This includes fulfilling our legal obligations under applicable laws, regulations, court orders, or governmental requests.

4. Third Parties Processing Your Personal Data / Providing your personal data to others

We may share your personal data with third-party service providers for the following purposes:

Our Apps may include links to third-party websites, plug-ins, and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal data practices of third-party websites and online services or the practices of other third parties. To learn about the personal data practices of third parties, please visit their respective Privacy Policies.

We may disclose your personal data:

Where required by law, government, competent authorities, or the courts or to establish, exercise, or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).

With suppliers and subcontractors, as necessary for the purposes set out in this notice.

With other members of our corporate group and our international network of partners.

If involved in an investment, merger, acquisition, or sale of our organization or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers, and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.

We may disclose or transfer some of personal data to Cookies Analytics and Similar Technologies such as "Analytics services, Cloud computing services, Advertisement business partners (advertisement networks).

We may use ad identifiers, cookies, and similar technologies. Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.

5. Retention, Storage and Security of Your Personal Data

We will retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy.

We take measures to safeguard your personal data and may transfer it to locations outside of your jurisdiction for processing. We retain your data for as long as your account is active or as needed to provide you with the Services. Please note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

We implement technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession. We ensure that only those within our company with a legitimate business need to access your personal information are permitted to do so. Additionally, we take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. While we prioritize the security of your personal data, it's important to note that no method of transmission over the Internet or method of electronic storage is 100% secure.

6. Children’s Privacy

Our services are not directed to individuals under the age of 13, and we do not knowingly collect personal data from children.

7. International Users

USA Residents: If you are a resident of the United States: You have the right to know whether your personal data is sold or shared and the right to opt-out of the sale or sharing of your personal information by us for targeted advertising purposes. We do not sell your personal information; however, we permit specific third-party advertising partners to collect information about our users through our games for various purposes primarily to serve more relevant ads and to detect and report fraud. If this practice might be construed as a "sale" under the CCPA, you can submit a request to opt-out to the email address below

European Residents: If you are a resident of the European Union:

You have the right to lodge a complaint with your local data protection authority.

Information about how to contact your local data protection authority is available here. If you are based in the UK, your local data protection authority is the UK Information Commissioner's Office (link). If you are based in Switzerland, your local data protection authority is the Swiss Federal Data Protection and Information Commissioner (link).

8. Your rights

In this Section, we have listed the rights that you have under data protection law. Your principal rights under data protection law are:

• the right to access - you can ask for copies of your personal data;
• the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
• the right to erasure - you can ask us to erase your personal data;
• the right to restrict processing - you can ask us to restrict the processing of your personal data;
• the right to object to processing - you can object to the processing of your personal data;
• the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
• the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
• the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ .

You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

9. Amendments

We may update this policy from time to time by publishing a new version on our website and mobile apps. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of significant changes to this policy by notification or email (if provided).

10. Our details

This website and mobile apps are owned and operated by Insight App Limited.

We are registered in England under registration number 13653972, and our registered office is at 240 Asquith Boulevard, Leicester, England, LE2 6FB.

You can contact us: by post, to the postal address given above; by email, using the email address published on our website and mobile apps or contact@insightapplimited.co.uk .