Revitive Privacy Notice

General

Actegy Limited takes the privacy of your information very seriously and we are committed to protecting all Personal Data provided to us through the use of the Revitive app (the “App”) any Revitive devices connected to the App (the “Revitive Products”) and the Revitive website (the “Website”).

For the purposes of applicable data protection and privacy laws, Actegy Limited (“our”, “us”, “we”), with its registered offices at 1 West Point, Western Road, Bracknell RG12 1HJ, is considered the “Controller” in respect of the Personal Data that it collects, uses and manages in accordance with this Privacy Policy (“Policy”).

This Policy explains what Personal Data we collect, how we may use and manage it and the rights you have in relation to your Personal Data. Before you provide us with any Personal Data or use our Website and/or App, you should read through this Policy in full and make sure that you are comfortable with our privacy practices. This privacy policy should be read alongside, and in addition to our Licence Agreement Terms and Conditions, which can be found in the settings menu of the App. Please note that the App is not intended to be used by any person under the age of 18.

Please also note that our Website may contain links to other websites, operated by third parties including social media websites. These third party sites are not subject to this Policy and we recommend that you check the privacy and security policies of each website that you visit. We are only responsible for the privacy and security of the Personal Data that we collect and have no control over the actions of any third parties in relation to your Personal Data.

Please refer to the Glossary below for an explanation of the defined terms in this Policy.

Personal Data we collect from you

We collect your Personal Data either when it is given to us by you, for example through signing up to the Website or the App, automatically when you use the Website and App or where provided by third parties.

Personal Data that is given to us by you:

• When signing up and using the services: When you sign up to use the Website and/or App, you may provide us with the following Personal Data about you: first name; year of birth; gender; height; weight; information relating to health conditions and symptoms associated with these; and location data (only upon creating an account in the App in order to determine your region and local language).
• When contacting us. When you contact us through the Website or App we may collect: your contact information, such as an email address; and a record of the communications. We may also collect your contact information when you elect to receive marketing communications from us.

Personal Data that is collected automatically:

To the extent that you access the Website and on account creation for and usage of the App, we may automatically collect the following categories of Personal Data from you automatically:

• Usage Data. We may collect technical data relating to your usage of the Website and App including the date, times and frequency with which you access the Website or App and the way you use and interact with its content (including where you make payments).
• Revitive Product Usage Data. We may collect technical information about your use of Revitive Products where the Revitive Product is connected to the Website or App. For example, we may collect your therapy session data including your usage time and intensity level.
• Device Data. We may collect your IP address, web browser type and version and operating system when using the Website and App.

In order to collect this information, we may use cookies and other tracking technologies in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, please see our Cookie page.

Personal Data collected from Third Parties:

We may also receive Personal Data related to activity and steps data, gathered from Apple Health or Google Fit accounts where you choose to connect the Website or App to these services. Where you connect with such accounts you are subject to the Apple Health or Google Fit privacy policies.

Our use of personal data

We have set out in the table below, a description of the purposes for which we collect and process your Personal Data and the legal bases we rely on to do so. The legal bases that apply to our Processing of your Personal Data are:

• Performance of a contract with you.
• Our legitimate interests.
• Your consent.
• Compliance with our legal obligations.

Where we are Processing your Personal Data on the basis of our legitimate interests, we have identified the relevant legitimate interests.

Use of Health Data

To the extent that any health data is processed by us, we will only process that Personal Data relying on one of the lawful basis identified above, in addition to one of the following conditions:

• Where you have given explicit consent to the Processing of that Personal Data for one or more specified purposes.
• Where the Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services.
• Where Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices.

Who we share your Personal Data with

We may share your Personal Data with people within Actegy Limited and its affiliate companies who have a “need to know” that data for business or legal reasons, for example, in order for your marketing preferences to be stored on our marketing platform, to maintain the App or to direct a query that you have submitted to the relevant team at Actegy Limited. Our affiliates are required to maintain the confidentiality of your Personal Data and are restricted from using it for any purpose other than the purposes set out in this Notice.

We may also disclose your Personal Data to the following third parties:

• Our professional advisors, including lawyers, auditors and insurers to obtain legal or other professional advice.
• Public and government authorities, courts and regulators in order to respond to a legal request or comply with a legal obligation.
• Third party suppliers engaged by us (including suppliers of IT services, analytics providers, our customer support platform and payment providers) for the purposes of providing the Website and App to you or as may otherwise be necessary in connection with the Processing purposes identified in this Policy.
• Prospective sellers or buyers in the event that Actegy sell, buy or merge any business or assets.

Transfers of Personal Data outside the UK and EEA

In order to operate the Website and App, we may transfer your Personal Data and/or store it outside the UK and EEA. Where Personal Data is transferred outside the UK and EEA, we take legally required steps to ensure that adequate safeguards are in place to protect your Personal Data and to make sure it is treated in accordance with the Policy. You can request a copy of the appropriate safeguards which we have put in place to protect your Personal Data in these circumstances by contacting [email protected]

Keeping your Personal Data secure

We will use technical and organisational measures to safeguard your Personal Data against accidental or unlawful destruction, accidental loss and unauthorised access, destruction, misuse, modification or disclosure. We aim to protect your Personal Data but unfortunately the transmission of information over the internet is not completely secure. We cannot guarantee the security of your Personal Data and any transmission of your Personal Data to Actegy Limited is at your own risk.

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 are subject to a duty of confidentiality.

Cookies

Our Website uses cookies to improve your user experience, to understand how the Website is being used as well as to help deliver ads for relevant Revitive Products to you when you visit certain pages on the Website and then visit certain third-party sites. For detailed information on the cookies we use and the purposes for which we use them please see our Cookie page.

Retention

Unless a longer retention period is required by law, we will only keep your Personal Data for the period necessary to fulfil the purposes for which it was collected (outlined in this privacy policy). The amount of time that records are kept for varies depending on the category of Personal Data. Details of retention periods for different categories of your Personal Data are available on request by contacting us at [email protected]

Your rights

Data protection laws gives individuals rights in respect of their Personal Data. You have the following rights in relation to Personal Data held by us:

• Right to access - the right to request copies of the information we hold about you at any time.
• Right to correct - the right to have your Personal Data rectified if it is inaccurate or incomplete.
• Right to erase - the right to request that we delete or remove your Personal Data from our systems.
• Right to object to or restrict our use of your Personal Data - the right to “block” us from using your Data or limit the way in which we can use it.
• Right to data portability - the right to request that we move, copy or transfer your Personal Data.
• Right to withdraw consent – the right to withdraw consent to any Processing where we are relying on your consent to process that Personal Data (this will not affect the lawfulness of any Processing we conducted prior to your withdrawal). For marketing emails, you can exercise your right to opt-out by clicking on the “unsubscribe” link provided at the bottom of each email.

To exercise any of your rights set out above please contact us via this e-mail address: [email protected].

Questions and Complaints

If you have a concern or complaint about this Policy or how we have used your Personal Data, please raise this in writing to us via:

[email protected]. If you are based in the UK and not satisfied with the way a complaint you make in relation to your Personal Data is handled by us, you may be able to refer your complaint to the Information Commissioner’s Office (ICO).

If you are based in the EEA: Actegy Limited has appointed Revitive SAS as its EU Data Protection Representative and should you require assistance, you may contact them by post and email, using the following address:

Revitive SAS
250 bis boulevard Saint Germain
75007 PARIS

E-mail: [email protected]
Telephone: 0805 321 051 / +33 1 75 85 03 74

You may also contact your local data protection authority. A list of local data protection authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

If you are based outside the UK-EEA you can also contact us:

Changes to this Policy

We reserve the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. For the Website, any changes will be immediately posted on the Website. For the App these changes will be, where appropriate, notified to you when you next start the App or log on.

Glossary