Mint Diagnostics Privacy Notice for Study Participants and App Users
This Privacy Notice was last updated on 15 July 2020.
What is the purpose of this document?
|Mint Diagnostics Ltd (thereafter “Mint”, “we”, “us” or “our”) is committed to protecting the privacy and security of your personal information. We are carrying out studies related to the use of saliva samples to improve human performance. We operate the Hormonix app (“app”) which gives users access to certain features to support their participation and involvement in our studies. This privacy notice describes how we collect and use personal information about you during and after your participation and involvement in our study, in accordance with the General Data Protection Regulation (GDPR). This privacy notice applies to all individuals who participate in or are involved in our studies.|
Mint Diagnostics Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. Our Information Commissioner’s Office registration number is ZA751912.
Please note this privacy notice only applies where we are the data controller. The organisation which appointed us to carry out the study will be an independent separate data controller so you should consult their privacy notice as well so you fully understand how your personal information will be used.
We are a company registered in England and Wales under company registration number 10212145. Our registered office address is at Unit 1093b Kent Science Park, Galley Drive, Sittingbourne, England, ME9 8GA. You can contact us by writing to us at that address. Alternatively, you can email us at [email protected]
This notice applies to all individuals who participate in or are involved in our studies. We may update this notice at any time but if we do so, we will let you know as soon as reasonably practical.
It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
Data protection principles
|We will comply with data protection law. This says that the personal information we hold about you must be: 1. Used lawfully, fairly and in a transparent way. 2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes. 3. Relevant to the purposes we have told you about and limited only to those purposes. 4. Accurate and kept up to date. 5. Kept only as long as necessary for the purposes we have told you about. 6. Kept securely.|
The kind of information we hold about you
|Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health, genetics, racial or ethnic origin or criminal convictions.|
We will collect, store, and use the following categories of personal information about you:
- Personal contact details such as title, name, surname, job title, phone number and email address.
- Date of birth, gender and measurements.
- Your profession and, where you are an athlete or coach, details of the sport(s) you participate or are involved in.
- Details of the organisation you work for or are engaged by.
- Details and results of the study you are participating in.
- Information relevant to the study you are participating in including information about your sleep routine, diet, training programme and performance.
- Username and password details.
- Your Internet Protocol (IP) address, browser type, browser version, the pages of our app that you visit, the time and date of your visit to our app, the time spent on the pages you visit, your unique device identifiers and other diagnostic data.
Due to the nature of our studies, we will collect some “special category” or “sensitive” personal information about you when you participate in our studies including information about your health and your genetic and / or biometric data.
How is your personal information collected?
We collect personal information about you when you complete registration forms to participate or be involved in our studies and through your use of the app such as when you create a user account on the app.
We will collect additional personal information about you during your participation and involvement in our studies and during your use of our app and services.
How we will use information about you
|We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances: 1. Where we have your consent. 2. Where we need to perform the contract we have with you under which we provide you with access to our app and services. 3. Where we need to comply with a legal obligation. 4. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.|
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to properly carry out our studies and to provide our app and services to you. The situations in which we will process your personal information, and the lawful basis for the processing, are listed in the table below.
|Situations in which we process personal data||Lawful basis for processing|
|To allow you to set up your user account and to access and make use of our app and services.||Our legitimate interests to allow users to subscribe to our app.|
|To provide you with time-based features such as reminders to take, and return, your saliva samples.||Our legitimate interests to ensure the proper participation in our studies. Performance of our contract with you to deliver our app and services to you.|
|To allow you to register the saliva samples with us using the mobile device camera and QR code.||Our legitimate interests to ensure the proper participation in our studies. Performance of our contract with you to deliver our app and services to you.|
|To provide you with support in using our app.||Our legitimate interests to ensure effective use of our app. Performance of our contract with you to deliver our app and services to you.|
|To comply with our regulatory obligations and to bring and defend legal claims.||To comply with our legal obligations. Our legitimate interests to comply with regulatory our regulatory obligations and to bring and defend legal claims.|
|To deal with complaints.||Our legitimate interests to ensure the proper operation of our business.|
|To monitor your use of our app to ensure compliance with our rules, policies and procedures.||Our legitimate interests to ensure the proper operation of our business.|
|For our business management and planning, including accounting and auditing.||Our legitimate interests to ensure the proper operation of our business.|
|To make decisions about your continued use of our app and services.||Our legitimate interests to ensure the proper operation of our business.|
|To keep the app safe and secure.||To comply with our legal obligations. Our legitimate interests to ensure the proper operation of the app and business.|
|To prevent fraud.||To comply with our legal obligations. Our legitimate interests to protect our business from fraud.|
|To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.||Our legitimate interests to ensure the security of our systems.|
|To detect, prevent and address technical issues.||Our legitimate interests to ensure the proper operation of our business.|
|To develop and improve our app, services and technologies.||Our legitimate interests to ensure the continued improvement of our business.|
|To ensure that content on the app is presented in the most effective and relevant manner for you and for your device and to tailor the app’s experience and content based on the way that you use the app.||Our legitimate interests to ensure the continued improvement of our business.|
|To conduct data analytics studies to review and better understand use of our app.||Our legitimate interests to ensure the continued improvement of our business.|
|To notify you about changes to our app and services.||Our legitimate interests to ensure you are aware of changes to our app and services.|
|To store cookies on your device.||Consent.|
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to provide our app or services to you, or we may be prevented from complying with our legal obligations.
We do not need your consent if we use special categories of your personal information in accordance with this privacy notice.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
|We will share your data with third parties, including other entities in our group and our service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the European Economic Area. If we do, you can expect a similar degree of protection in respect of your personal information.|
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or in order for a third-party service provider to provide a service related to your use of our app and services.
Which third parties process my personal information?
“Third parties” include our third-party service providers (including our contractors and designated agents) and other entities within our group.
We will share your personal information with our service providers including those providing administration, IT services and analytics services.
How secure is my information with third parties?
All our service providers and other entities within our group are required to take appropriate security measures to protect your personal information. They must only process your personal data for specified permitted purposes and in accordance with data protection law.
When might you share my personal information with other entities in the group?
We may share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance and support and hosting of data.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the sale or restructuring of our business. In this situation we will, so far as possible, share anonymised data with the other parties.
We may need to share your personal information with a regulator or to otherwise comply with the law.
We may need to share your personal information with our professional advisors, the authorities and the courts in certain situations (for example, to enforce our legal rights or to defend ourselves against allegations or claims made against us, to prevent or investigate wrongdoings or suspected wrongdoings or to protect and safeguard the users who use our app and services).
Transferring information outside the EEA
We may transfer the personal information we collect about you outside the European Economic Area.
However, to ensure that your personal information does receive an adequate level of protection we will make sure that we take steps necessary to protect your data as required by applicable laws. For instance, we may put in place the EU Commission’s approved Model Contractual Clauses or equivalent level protections to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.
|We have put in place measures to protect the security of your information. Our third-party service providers will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.|
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised 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 access your personal information. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
However, you should be aware that the transmission of information and data is never completely secure and there is a measure of risk associated with the use of any online service.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. You can contact us at the postal or email address set out above.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us at the postal or email address set out above.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at the postal or email address set out above. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
The withdrawal of your consent will not affect the lawfulness of any processing carried out before your consent was withdrawn.
We use the stored information in the following ways:
- Account related storage: when you use the app, we store information for the management of the login process and general administration. This data is deleted when you log out;
- Login related storage: We use local storage when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These data is deleted when you log out;
- Offline related storage: We use local storage to store the data you access for offline usage. This allows you from be able to continue using the app when internet connectivity is unavailable. These data is deleted when you log out.
You can clear the local storage by signing out from the app.
The app does not store cookies or any third party cookies on your browser.
Links to other sites
We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third party sites or services.
Data privacy manager
We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact our data privacy manager at the postal or email address set out above. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact our data privacy manager using the postal or email address set out above.