Chiptech International Ltd (Chiptech, or “we”, “us” or “our”) takes its obligations in regards to privacy seriously. In this Policy, “you” and “your” means the individual providing Personal Data to us. The terms “you” and “your” also include a Device owner in relation to any Personal Data of that Device owner that any Responder has entered through the App.
This Policy provides information in relation to the basis on which we collect, hold, use and disclose (i.e. process) your Personal Data. Personal Data is data relating to an individual which can be used to identify that individual or which is linked to an identified individual, and any other data that is defined as personal data by any relevant law.
Other terms that are capitalised but not otherwise defined in this Policy carry the same meaning as in the Terms and Conditions applying to the use of this App (App Terms and Conditions).
By using the App you agree to the terms of this Policy.
1. Updates to this Policy
- This Policy will be reviewed from time to time to take into account new laws and technology, changes to our operations and practices and the changing business environment. The most current version of this Policy is located on this website.
- Use and disclosure of Personal Data collected from you is subject to the Policy in effect at the time such Personal Data is collected.
2. Collection of Personal Data
- We collect Personal Data so that you can use the App’s functionality, to enable the App to operate, for us to meet our obligations under the App Terms and Conditions, and to meet our legal obligations.
- In general, the Personal Data we collect and hold includes (but is not limited to): your name, mobile phone number, account password (which we encrypt), the content of all Communications and any other information which assists us to provide the App.
- We will also collect information specific to your Smartphone and the Device to which the App is paired. This includes information such as your Smartphone operating system information and Device identifiers.
- The App functionality requires access to your Smartphone’s camera to scan the barcode of the Device. The barcode information is used to pair the App to the Device and is not collected or stored by us.
- If Personal Data that is required to be entered into the App is not provided you may not be able to use any or some of the App’s functionality. If you limit any Personal Data in a message you send to an Associated App the Associated Responder may not be able to take appropriate action.
3. How We Collect Personal Data
- We collect Personal Data through your use of the App, including when you download, install and access the App, when you register an account, when you pair the App to a compatible Device, and when you send a message. We also collect a Device owner’s Personal Data when a Responder pairs the App to the Device or records or updates the Device owner’s Personal Data in the App. This information includes the name you give to the owner of the Device, the address you associate with it, any notes you want to add and any information included in a message you send using the App.
- When pairing the App to a Device, you must ensure you have first obtained the consent of the Device owner to record any of their Personal Data in the App. If you use the App to record the Personal Data of the Device owner or to send any message to an Associated App and that message contains Personal Data of the Device owner or any other person you must ensure you have obtained their consent to record their Personal Data or to include any of their Personal Data in such a message. In addition, you must ensure that the individual is aware of the information in this Policy. If any information you enter through the App is health information of the Device owner before doing so you must obtain the Device owner’s consent to that health information being processed in accordance with this Policy.
- If you access the App from outside of the United Kingdom, you agree that any Personal Data you provide us is subject to this Policy, the applicable data protection laws in England and the General Data Protection Regulation (EU) 2016/679 (where applicable).
- Your Personal Data may also be collected from any third parties you authorise us to contact, or as otherwise permitted by any applicable data protection laws.
4. Purposes for which We Collect, Hold, Use and Disclose Personal Data
- We may collect, hold, use and disclose your Personal Data for the following purposes:
- where it is necessary for the performance of our contract with you that is formed by the App Terms and Conditions, including so that you can use the App’s functionality, and to enable the App to operate;
- where it is necessary for our legitimate interests of conducting our business, which may include:
- to help support, manage and enhance the App and our offerings;
- to investigate any matter concerned with the use of the App;
- meeting our obligations in, exercising our rights under, or enforcing the App Terms and Conditions;
- selling a substantial part or all of our business to a third party; and
- for the purposes of carrying out the matters noted in the section below on the ‘Management of Personal Data’;
- to otherwise protect our vital interests in our property, our legal rights, or those of others, including to detect, investigate, prevent or address fraud, security or technical issues, or if we have good reason to believe there is an imminent threat of death or injury or a serious threat to health and safety; and
- any other lawful purpose made known to you when collecting the Personal Data.
- Other sections of this Policy also set out other specific situations in which your Personal Data is collected, held, used and disclosed.
- We may use and disclose your Personal Data for any of these purposes, in any other circumstances authorised by applicable data protection laws, or in any other manner with your consent.
- When you enter address details we may disclose those details to Google to enable us to verify the address by Google address lookup.
- Your name and mobile phone number are shared across Associated Responders in respect of the same Device.
- When you use the App to send a message to an Associated App, your name and the content of that message is disclosed to all Associated Responders. Any person in possession of the Responder’s Smartphone receiving a message from an Associated App may also be able to view the messages.
- The App also lets you enter a name and address of the Device owner and store certain information in a notes section. The App functionality shares this information with all Associated Responders and the Responder or any Associated Responder may make changes to it.
- Your activity history is also shared between Associated Responders to enable all Associated Responders to determine whether a response to a Communication sent by the Device has occurred.
- The Device sends certain information concerning missing communications, automated tests and power and battery status changes in relation to the Device to all Apps associated with the Device.
- We use third party communication services in order to send Communications to the App and to communicate with you in relation to your account management in relation to the App, such as to verify password information. While we use reasonable endeavours to use third party services that employ appropriate security safeguards, we are not responsible for a failure or breach of those safeguards.
- We are not responsible for collection, use, disclosure or other processing of Personal Data by any Back-Up Monitoring Service that may be associated with the Device. Such services are contracted for separately by the Device owner. However, if any Back-Up Monitoring Service for a Device is engaged SmartCare Central will notify the relevant Back-Up Monitoring Service if none of the Responders associated with the same Device respond to a Communication sent by the Device to the App on each such Responder’s Smartphone within a predetermined amount of time.
- We do not otherwise share your Personal Data without your consent, except where permitted by any applicable data protection laws, unless we believe it is necessary:
- to enforce the App Terms and Conditions, or where we are legally required to do so;
- so we, or other authorised agencies can detect, investigate, prevent or address, security or technical issues;
- to otherwise protect our property, legal rights, or that of others; or
- for the purposes of carrying out the matters noted in the section below on the Management of Personal Data
5. Management of Personal Data
- Personal Data collected by us is held by us in our cloud based database and monitoring infrastructure (SmartCare Central). SmartCare Central is used to store Personal Data and to send and receive Communications between the Device, the App, Associated Apps, and, if enabled, the Back-Up Monitoring Service. Our address is set out below in the section on Your Rights.
- We may transfer data about you to our New Zealand based parent company, Chiptech Limited, to perform services on our behalf or to the extent necessary for the performance of the App Terms and Conditions. New Zealand has an adequacy decision by the European Commission.
- We may also transfer Personal Data to third parties (including technology providers, and providers of software tools used by us in our business) that we have engaged in order to provide the services described in the App Terms and Conditions and to assist us to support, manage and enhance the App. We only use these third parties to perform services on our behalf, to process the information for us, or hold it on our behalf. We will not authorise any such third party to use such data for their own purposes.
- To the extent any transfer occurs, we have agreements in place with the relevant third party that includes standard data protection clauses or which use an approved protection method. If you would like further information regarding how our agreements with such third parties protect your Personal Data, please contact us.
- We have in place appropriate technical and organisational measures to protect the Personal Data we hold from misuse, loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records. Our personnel are required to respect the confidentiality of Personal Data and the privacy of individuals.
- We will retain your Personal Data for as long as needed to provide you the App services, to manage backups of your Personal Data in accordance with our security practices, to be able to address any claim that might be made after you stop using the App, or to meet any legal obligations we have to retain such data, including managing our obligations to you in respect of the App services. Where we no longer require your Personal Data for a permitted purpose, we will take reasonable steps to delete it. This is likely to be the case where the Device has not been active for a period of 12 months.
6. Your Rights
- It is important that the Personal Data we hold is accurate, complete and up-to-date. We encourage you to use the App to update any Personal Data held about you.
- You have the right to access your Personal Data. Access to all your Personal Data is available through the App and you can use the App to update details that have changed.
- You have the right to request that your Personal Data be rectified if you think it is wrong. If you think your Personal Data is wrong you can rectify the information using the App. If you have not been able to do so through the App first, you may request the rectification of the Personal Data which we hold about you by writing to us.
- You also have the right to restrict the processing of your Personal Data, to object to processing of your Personal Data, to the portability of your Personal Data, and to obtain erasure of your Personal Data, in each case in accordance with applicable data protection laws. If you wish to restrict processing of, or erase, your Personal Data, or you object to the processing of your Personal Data, you will need to stop using the App.
- To exercise any of your above rights, please contact us as follows:
Phone: +44 (0)1524 544427
Address: Chiptech International Limited, InfoLab21, South Drive, Lancaster University, LANCASTER LA1 4WA, United Kingdom
If a dispute were to arise between us and we cannot resolve this with you, then you may lodge a complaint with our supervisory authority, the UK Information Commissioner’s Office.
8. Governing Law
This Policy is governed by the laws of England.