What is this Privacy Policy for?
This privacy policy is for the MySpira mobile app (iOS & Android) and the website [www.MySpira.com] and served by Orbital Media and Advertising Ltd and governs the privacy of its users who choose to use it.
The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the MySpira app, the website and website owners. Furthermore, the way the MySpira app and website processes, stores and protects user data and information will also be detailed within this policy.
Are there any other privacy policies I need to be aware of?
Yes. The MySpira app is built using Unity3D and utilises Unity Analytics to collect information about gameplay progress and device information to identify problems or app improvements. Unity Analytics privacy policy can be found at https://unity3d.com/legal/privacy-policy and further GDPR related policies can be found here https://unity3d.com/legal/gdpr
The MySpira App
- The MySpira app and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their gaming experience. The app complies to all UK national laws and requirements for user privacy
- We may collect anonymised data that includes:
- Your gameplay progress
- Your achievements unlocked
- Your device operating system in use
- Your play sessions
- Your country location
- Your device ids
- We do not collect personal data that include:
- Your age
- Your gender
- Your email addresses
- Your phone numbers
- Personal data that is saved to the device, includes:
- If you have asthma or not
- If you have access to the premium content which includes the personalised asthma action plan, the personal data that is saved to the device ONLY, includes:
- Your name
- The types of inhalers you use and frequency of use
- Your asthma prescription
- Your asthma review date
- Your asthma consultant’s contact details
- Your peak flow levels
1.4 The medical content in the app will be reviewed annually
Data Use
2.0 Your personal data will not be used for purposes such as Clinical Research
2.1 You can request to download your user data by tapping the ‘Data Privacy’ button in the main menu of the app. You will also have an option to opt-out from sharing your data
2.2 We do not share any data with any other app or service except Unity Analytics
2.3 The app doesn’t contain features that allow the app to share data with other users
2.4 The data will be stored in Unity’s secure servers in the cloud
Data Security
3.0 The data that is transferred to Unity and is stored using recognised secure data technologies that is used by tens of thousands of games globally
3.1 Unity Analytics does not use encryption
3.2 The GDPR requires Data Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject. We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.
3.3 The MySpira app complies with GDPR rules which supersede the ‘Data protection act’.
Data Retention
4.0 Data retention is the GDPR ruling that data should not be kept longer than necessary. There is a degree of flexibility with regards to “longer than necessary”, but this cannot be
an undetermined amount of time or;
forever.
4.1 The MySpira application does not collect personal data, however it does collect analytic data. As analytic data could also potentially be regarded as sensitive data (despite being anonymised), we will still implement a data retention policy guidelines for this data.
4.2 The guidelines are intended to ensure that MySpira processes Analytic data in accordance with the Analytic data protection principles, in particular that:
Analytic data must be collected only for specified, explicit and legitimate purposes. It must not be further processed in any manner incompatible with those purposes.
Analytic data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. When Analytic data is no longer needed for specified purposes, it is deleted or anonymised as provided by these guidelines.
Analytic data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.
Analytic Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.
Analytic Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
4.3 MySpira’s approach to retaining Analytic data is to ensure that it complies with the data protection principles referred to in these guidelines and, in particular, to ensure that:
Analytic data records are regularly reviewed to ensure that they remain adequate.
Analytic data records are kept secure and are protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. MySpira uses anonymization to prevent identification of individuals.
When records are destroyed, whether held as paper records or in electronic format, we will ensure that they are safely and permanently erased.
4.4 Data retention periods for MySpira’s Analytical data is governed by the retention periods outlined in the Data Retention policies for Unity
The Website
5.0 This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies to all UK national laws and requirements for user privacy.
Contact & Communication
6.0 Users contacting this website/app and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in the Data Protection Act 1998. Every effort has been made to ensure a safe and secure form to email submission process but advise users using such form to email processes that they do so at their own risk.
Social Media Platforms
7.0 Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
7.1 Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
7.2 This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Use of the Game
8.0 Orbital Media and Advertising Ltd hereby authorises you to copy documents published by Orbital Media and Advertising Ltd on the World Wide Web for non-commercial and individual reference use only. It is given on the understanding that any copy of these documents that you make shall retain the copyright and other proprietary notices contained herein. Any copies thereafter shall not be re-copied, reproduced, altered or otherwise redistributed.
8.1 Nothing contained herein shall be construed as conferring by implication, preclusion or otherwise any licence or right under any patent or trademark of Orbital Media and Advertising Ltd or any third party. Any product names, whether appearing with or without the trademark symbol are trademarks of Orbital Media and Advertising Ltd or its licensers or joint venture partners. The use of these trademarks or any other materials, except for the uses permitted above, is expressly prohibited and may be in violation of trademark.
Third Party Links
9.0 In an attempt to provide increased value to our visitors, the Orbital Media and Advertising Ltd Web sites and mobile apps may contain links to other Web sites on the Internet that are owned and operated by third-party vendors and other third parties. However, even if the third party is affiliated with Orbital Media and Advertising Ltd, Orbital Media and Advertising Ltd has no control over these linked Web sites, all of which have separate privacy and data collection practices independent of Orbital Media and Advertising Ltd. Orbital Media and Advertising Ltd makes no claim or representation regarding, and accepts no responsibility for the quality, content, nature, or reliability of Web sites accessible by hyperlink from the Orbital Media and Advertising Ltd Web sites or Web sites linking to the Orbital Media and Advertising Ltd Web sites. The linked Web sites are not under the control of Orbital Media and Advertising Ltd, and Orbital Media and Advertising Ltd is not responsible for the contents of any linked Web site or any link contained in a linked Web site, or any review, changes or updates to such Web sites. Orbital Media and Advertising Ltd is providing these links to you only as a convenience, and the inclusion of any link does not imply affiliation, endorsement, or adoption by Orbital Media and Advertising Ltd of the Web site or any information contained therein. These linked Web sites are only for your convenience, and, therefore, you access them at your own risk.
Disclaimer and Limitation of Liability
10.0 Orbital Media and Advertising Ltd makes no warranties or representations about the accuracy or completeness of the Orbital Media and Advertising Ltd MySpira App’s content or the content of any linked Web sites. This publication is provided “AS IS” WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. Orbital Media and Advertising Ltd DOES NOT REPRESENT OR WARRANT THAT MATERIALS ON THIS WEB SITE ARE ACCURATE, COMPLETE, RELIABLE, CURRENT, OR ERROR-FREE. Orbital Media and Advertising Ltd DOES NOT REPRESENT OR WARRANT THAT THIS WEB SITE OR ITS SERVER(S) ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. Some jurisdictions do not allow the exclusion of implied warranties, so the above exclusion may not apply to you.
10.1 IN NO EVENT SHALL Orbital Media and Advertising Ltd BE LIABLE FOR ANY DIRECT, SPECIAL, INDIRECT, OR CONSEQUENTIAL DAMAGES, OR ANY OTHER DAMAGES OF ANY KIND INCLUDING, BUT NOT LIMITED TO, LOSS OF USE, LOSS OF PROFITS, OR LOSS OF DATA, WHETHER IN AN ACTION IN CONTRACT, TORT (INCLUDING, BUT NOT LIMITED TO, NEGLIGENCE), OR OTHERWISE, ARISING OUT OF OR IN ANY WAY CONNECTED WITH THE USE OF THIS WEB SITE OR THE MATERIALS CONTAINED ON, OR ACCESSED THROUGH, THIS WEB SITE.
Applicable Law
11.0 These terms and conditions shall be governed by and construed in accordance with the laws of the United Kingdom, without regard to its choice of law principles.