This privacy notice is effective on the 21st June 2024
Moments of Space Ltd (referred to as
Moments of Space,
we,
us, or
our in this privacy notice) respects your privacy and is committed to protecting personal information relating to you (
your personal information). This privacy notice will inform you as to how we look after your personal information when you visit our website, use our app, products or services, and tells you about
your rights and how the law protects you when we use your personal information.
Key points
- We will collect a range of personal information from you when you provide it to us, when you access our website, use our app, products or services. This may include things like your location, your physical activity, your reflection data (about how you feel), how much you use our app, products or services and any other information you share with us.
- We will look after your personal information and only share it with trusted third-parties that we use to deliver our website, app, products and services, and they are accountable to us to take care of it.
- We use artificial intelligence (AI) and machine learning tools to provide you with the most effective and feature-rich tailored content and experience based on the personal information you give us, and to keep improving what we are able to offer you.
- We will only send you marketing relating to Moments of Space based on your marketing communications preferences, and you always have the right to opt-out of receiving it at any time.
- We are transparent about your rights in your personal information, and will always respect them.
Purpose of this privacy notice
This privacy notice aims to give you information on how Moments of Space collects and uses / processes your personal information through your use of our website, our app, products or services.
Our website, app, products and services are not intended for anyone under 18, and we do not knowingly collect information relating to children.
Who we are
Moments of Space is the controller and responsible for your personal information when we are using it. We have appointed a data protection officer (
DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise
your rights, please contact the DPO at:
privacy@momentsofspace.com or
90a High Street, Berkhamsted, Hertfordshire, England, HP4 2BL.
You have the right to make a complaint at any time to the Information Commissioner's Office (
ICO), the supervisory authority for data protection issues in the UK (
www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy notice under regular review. It is important that the personal information we hold about you is accurate and current so that we are always able to provide you with the most effective and feature-rich tailored content and user experience. Please keep us informed if your personal information changes during your relationship with us.
Third-party links
Our website and app may include links to third-party websites, 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 websites and are not responsible for the way in which they use your personal information. When you click on these links, you will leave our website or app and therefore, we encourage you to read the privacy statement of every third-party website you visit.
The personal information we collect about you and our legal basis for doing so
Personal information means any information that identifies you. Special category / sensitive personal information is personal information that may reveal health or ethnicity information about you or your family. If you provide us with personal information about your family members you are responsible for ensuring that they are aware of and okay with you doing so. Personal information does not include information where your identity has been removed (anonymous data) from it.
We will use your personal information (including any special category / sensitive personal information) based on:
- Our legitimate interest: To fulfil our business interests in providing you with our website, app products and services and to ensure you receive an excellent user experience.
- Our Terms: With you under which you have agree for us to provide you with our app, products and services.
- Our legal obligation: To comply with applicable laws when we provide our website, app, products and services to you, and we won’t need additional consent when we use your special category / sensitive personal information for the legal bases above.
- Your consent: Required by law for us to send you marketing communications.
We may collect, use, store, and transfer to third-parties different kinds of personal information about you which we have grouped together as follows:
- Identity data: includes first name, last name, username or similar identifier.
- Contact data: includes billing address, delivery address, email address, and telephone numbers.
- Transaction data: includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting, GPS-based location, security data derived from our security arrangements for all the data / information we use, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website and app, products and services.
- Profile data: includes purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage data: includes information such as cookies about how you use our website, app, products, and services, including interactions, features accessed, and session duration.
- Marketing and communication data: includes your marketing communication preferences in receiving marketing from us.
- User input data such as reflection, health, motion, ethnicity data: includes any information that you provide to us, including when you use our app, such as responses to questions about your health, diary entries, and voice and video recordings in any media.
The app collects reflection data about your physical, mental and emotional state, motion data about your physical movements and activities obtained from sensors on your device, health, gender and ethnicity data in various media such as free form text and voice notes. That data is stored each time and maintained as a historical record about you. The app uses technical measures to filter appropriate content for you, and then AI to check the appropriateness of the content.
If you fail to provide personal information
Except for certain information that is required by law, your decision to provide personal information to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal information, however, please note that if you do not provide certain information, you / we may not be able to accomplish some or all of the purposes outlined in this privacy notice, and you may not be able to use our website, app, products or services which require the use of your information. In this case, we may have to cancel a product or service you have with us, and we will notify you if this is the case at the time.
How is your personal information collected?
We collect personal information from you when you give it to us directly by filling in forms or interacting with our website, app, products or services, or indirectly, such as information we gather about and from the device(s) you use to access our app, such as GPS location and motion data. We may also collect personal information about you from third-parties who you have previously agreed may share your personal information with us.
How we use your personal information and purposes for which we will use it
We will only use your personal information in accordance with our legal bases for doing so, in the following circumstances:
- When you assess our website.
- When we provide you with access to our app and any products or services at your request, to provide you with ongoing technical support, and to contact you with information about them.
- To provide you with an effective and feature-rich tailored content and user experience.
- To let you know about other products and services by post, email, and phone in accordance with your marketing communication preferences and laws relating to direct marketing.
- To analyse how you use our website, app, products and services so that we can improve our levels of service and develop them, including through the use of surveys, to ensure the security of our information technology systems and protecting our / your rights).
- Where you have provided your consent, and we need that consent to use your personal information.
- Where we need to comply with a legal obligation. (e.g., in relation to legal requests by regulators or enforcement bodies).
Marketing
We strive to provide you with choices regarding certain personal information use, particularly around marketing and advertising. You may receive marketing communications from us if you have consented to us doing so. You can ask us to stop sending you marketing communications at any time by contacting us at:
privacy@momentsofspace.com or
90a High Street, Berkhamsted, Hertfordshire, England, HP4 2BL.
or by following the opt-out links in any marketing communications sent to you.
Cookies
We and our third-parties providing our website use cookies and other tracking and storage technologies to:
- Help with website analytics and intelligence about the effectiveness of our website, app, products and services.
- Give you with the best possible user experience.
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. Please see our Cookie Policy
here for more information about the cookies we use.
Sharing your personal information
We as a controller will share your personal information with third-party processors to use it for the purposes set out in this privacy notice as follows:
- To provide access to apps / products / services, system administration services, marketing services, and any other services required to provide and improve them. This includes our tech and data partners who use AI and machine learning tools to process your personal information in order to provide you with effective and feature-rich tailored content and help us provide and improve our app products and services.
- Our professional advisers including lawyers, bankers, auditors, and insurers who provide us with consultancy, banking, legal, insurance, and accounting services;
- To our professional advisers including lawyers, bankers, auditors, and insurers who provide us with consultancy, banking, legal, insurance, and accounting services connected to our business.
- To regulators, law enforcement and other official bodies.
- To third-parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
We require all third-parties to respect the security of your personal information and to treat it in accordance with the Terms we have entered into with you, and applicable law. We do not allow our third-parties to use your personal information for their own purposes and only permit them to use it for the purposes in this privacy notice, and in accordance with our instructions.
International transfers
Your personal information may be used outside of the UK. When we do so we ensure there are adequate safeguards, legal and technical measures in place to protect your personal information. To do this, we make use of data transfer agreements that have been approved by the UK authorities and the European Commission for use with those countries that do not have adequate safeguards.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors, and other third-parties who have a business need to know. They will only use your personal information in accordance with our instructions and they are subject to a duty of confidentiality.
Data retention
We will only keep records of your personal information for as long as is reasonably necessary for the purposes for which we have collected it, and in order to comply with any statutory or regulatory obligations in relation to retention of records. We respect requests to stop processing your personal information for marketing purposes. This includes keeping a record of your request so that we can respect your marketing communication preferences in the future.
Your rights
Under certain circumstances, you have the right to request access to and rectification or erasure of personal information, the right to restrict processing of your personal information, and the right to object to processing of your personal information. You have the right to object to your personal information being processed on the grounds of our legitimate interests. You have the right to object to us sending you direct marketing and profiling you for the purposes of direct marketing. You have the right to lodge a complaint regarding our processing of your personal information with the ICO (as defined above).
Other than your right to object to the use of your data for direct marketing, your rights are not absolute. They do not always apply in all cases and we will let you know in our correspondence with you how we will be able to comply with your request.
If we are able to comply with your request, before providing our response, we will have to remove any information such as our confidential information and any other personal information belonging to our personnel (providing services to you). If we cannot comply with your request, we will explain why.
We may need to request specific information from you to help us confirm your identity and right to access your personal information (or any other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We have one month (from the receipt of a request) to respond to your request, which can be extended by two more months if your request is complex or if there are a number of requests. You will be told within the first month if we need an extension.
If you would like to exercise your rights above please do so at:
privacy@momentsofspace.com or
90a High Street, Berkhamsted, Hertfordshire, England, HP4 2BL.