USE BY MINORS
The App is not directed to individuals under the age of 16, and we request that these individuals not provide personal information through the App. If your child has submitted personal information and you would like to request that such personal information be removed, please contact us as explained below under Contacting Us.
Personal information means data that you submit or is collected through the App that identifies, can be used to identify, or relates to an identifiable individual.
This information may include: age, smoking years, average number of cigarettes per day, price paid for cigarettes, smoking behaviour and certain information concerning health (such as craving intensity) i.e. personal information related to the physical or mental health, which may reveal information about your health status. The App will also link to the name, picture and contact information of the people you select who will support you through your quit journey. In addition, you may store a picture. You will be informed what information is required and what information is optional.
The App does not capture your name or contact information such as email address or telephone number. In a future update, we may allow you to create a personal profile. We will clearly inform you about it when it is made available.
Unless we specifically request or invite it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the App or otherwise to us.
AUTOMATIC INFORMATION COLLECTION AND USE
We and our service providers may collect certain information automatically as you navigate around the App. Such information is non-personal information about your device and your use of the App and may include, for example, your device manufacturer and model, carrier and operating system, as well as information about your use of the App, including features used, times of use and information about technical events such as software crashes or errors. We also may aggregate personal information collected by the App for statistical and analytical purposes. Aggregated personal information does not personally identify you or any other App user.
HOW WE USE AND DISCLOSE INFORMATION
The App stores all personal information you provide on your mobile device. The only data that is transferred to us is certain non-personal information about your device and your use of the App, as described above, under “Automatic Information Collection and Use”.
Where required by applicable law, we will obtain your consent to our use of your personal information at the point of information collection. We may also use information from or about you as necessary to perform a contract, to comply with a legal obligation (for example, due to our pharmacovigilance obligations), or for our legitimate business interests. We may also rely on other legal bases, specifically for:
- Providing the functionality of the App and fulfilling your requests.
- to provide the functionality of the App to you and providing you with related customer service;
- to respond to your inquiries and fulfil your requests, such as to send you documents you request or e‑mail alerts;
- to send you important information regarding our relationship with you or regarding the App, changes to our terms, conditions, and policies and/or other administrative information.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Accomplishing our business purposes.
- for data analysis, for example, to improve the efficiency of the App;
- for audits, to verify that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements;
- for fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- for developing new products and services;
- for enhancing, improving or modifying our website or products and services;
- for identifying App usage trends, for example, understanding which parts of our App are of most interest to users; and
- for determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
- Analysis of personal information to provide personalized services.
- to better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests;
- to better understand your preferences so that we can deliver content via the App that we believe will be relevant and interesting to you.
We will provide personalized services either with your consent or because we have a legitimate business interest.
We disclose information collected through the App:
- to our third-party partners with whom we offer a co‑branded or co‑marketed promotion;
- to our third-party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, e‑mail and direct mail delivery services, auditing, and other services, in order to enable them to provide services; and
- as permitted by applicable law, to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
In addition, we may use and disclose your information as we believe to be necessary or appropriate: (a) to comply with legal process or applicable law, which may include laws outside your country of residence; (b) as permitted by applicable law to respond to requests from public and government authorities, which may include authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others. We may also use and disclose your information in other ways, after obtaining your consent to do so.
In addition, where allowed by applicable law, we may use and disclose information that is not in personally identifiable form for any purpose. If we combine information that is not in personally identifiable form with information that is identifiable (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your personal information
You may stop all collection of personal and other information by the App by uninstalling the App. You may stop the receipt of push notifications through your device settings.
How you can access, change, or delete your personal information
If you would like to update or delete your personal information stored within the App, you may do this directly via the App. For the personal information held by us, you can review, correct, update, restrict, or delete your personal information, or request to receive an electronic copy of your personal information for purposes of transmitting it to another company, by contacting us in accordance with the “Contacting Us” section below. We will respond to your request as soon as reasonably practicable and no later than one month after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response. All requests will be fulfilled to the extent these rights are provided to you by applicable law.
The App stores all personal information you provide on your mobile device. The only data that is transferred to us is certain non-personal information about your device and your use of the App, as described above under “Automatic Information Collection and Use”.
Such information, as well as any personal information that you provide to us by other means than the App (such as by e-mail, phone or post)may be stored and processed in any country where we have facilities or service providers, and by using our App or by providing consent to us (where required by law), your information may be transferred to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. Appropriate contractual and other measures are in place to protect personal information when it is transferred to our affiliates or third parties in other countries.
Some non-European Economic Area (EEA) countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have ensured that adequate measures are in place, including by ensuring that the recipient is bound by EU Standard Contractual Clauses, EU-US Privacy Shield Certification, or an EU-approved code of conduct or certification, to protect your personal information. You may obtain a copy of these measures by contacting our data protection officer in accordance with the “Contacting Us” section below.
We seek to use reasonable organizational, technical, and administrative measures designed to protect personal information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
The App stores all personal information you provide on your mobile device. When you reset or delete the App, your personal information will be removed.
The only data that is transferred to us is certain non-personal information about your device and your use of the App, as described above under “Automatic Information Collection and Use”. We will retain such information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the App to you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
THIRD PARTY SITES AND SERVICES
Foundation Park, Roxborough Way, Maidenhead, Berkshire, UK, SL6 3UG
You may also contact our data protection officer responsible for your country or region, if applicable, at firstname.lastname@example.org.
LODGING A COMPLAINT WITH A REGULATOR
You may lodge a complaint with a supervisory authority competent for your country or region. Please click here for contact information for such authorities.