Privacy Policy

Introduction

Entia is committed to protecting our customer’s privacy and takes its responsibility regarding

the security of customer information very seriously. We will be clear and transparent about

the information we are collecting and what we will do with that information.

This Policy sets out the following:

What personal data we collect and process about you in connection with your relationship

with us as a customer:

● Where we obtain the data from

● What we do with that data

● How we store the data

● Who we transfer/disclose that data to

● How we deal with your data protection rights

● And how we comply with the data protection rules

All personal data is collected and processed in accordance with UK and EU data protection

laws.

Data Controller

Entia is the “data controller” of all personal information that is collected and used about Entia

customers for the purposes of the General Data Protection Regulation (GDPR).

What Personal Data we collect

Personal data means any information relating to you which allows us to identify you, such as

your name, contact details and bank details.

Specifically, we may collect the following categories of information:

a. Name, home address, e-mail address, telephone number, credit/debit card, CV, Cover

Letter, References or other payment details.

b. The communications you exchange with us or direct to us via letters, emails, chat

service and calls.

c. Approximate location through your IP Address.

d. Details about your current and past health conditions. We will only collect this data with

your explicit consent.

Personal details about your physical or mental health are considered “sensitive” personal

data under applicable data protection laws. We will process any such data only if you have

given your explicit consent or you have deliberately made it public.

What we use your personal data for, why and for how long

Your data may be used for the following purposes:

a. Providing products and services you request: we use the information you give us to

perform the services you have asked for in relation to our devices and services.

b. Credit or other payment card verification/screening: we use your payment information

for accounting, billing and audit purposes.

c. Customer Services communications: we use your data to manage our relationship with

you as our customer and to improve our services and enhance your experience with us.

d. Administrative or legal purposes: we use your data for statistical and marketing analysis,

systems testing, customer surveys, maintenance and development, or in order to deal with a

dispute or claim. By providing any personal data you explicitly agree that we may use it to

perform profiling activities in accordance with this Privacy Policy.

e. Marketing: from time to time we will contact you with information regarding our devices

and services via e-communications. You will have the choice to opt in of receiving such

communications by signing up via our website. You will also be given the opportunity on

every e-communication that we send you to indicate that you no longer wish to receive our

direct marketing material.

f. Security, health, administrative, crime prevention/detection: we may pass your

information to government authorities or enforcement bodies for compliance with legal

requirements

g. Research: we regularly carry out user research and may collect your personal data in

order to inform our decisions about what products and services we provide.

We will only process your personal data where we have a legal basis to do so. The legal

basis will depend on the reasons we have collected and need to use your personal data for.

In most cases, we will need to process your personal data so we can send you marketing

material you have asked for or part of our recruitment process.

We may also process your personal data for one or more of the following:

● To comply with a legal obligation (e.g. criminal law)

● You have consented to us using your personal data (e.g. for marketing related uses);

● To protect your vital interests or those of another person (e.g. in case of a medical

emergency)

● It is in our legitimate interests in operating as a company (e.g. for administrative

purposes).

We will not retain your data for longer than is necessary to fulfil the purpose it is being

processed for. To determine the appropriate retention period, we consider the amount,

nature and sensitivity of the personal data, the purposes for which we process it and whether

we can achieve those purposes through other means.

We must also consider periods for which we might need to retain personal data in order to

meet our legal obligations or to deal with complaints, queries and to protect our legal rights

in the event of a claim being made.

When we no longer need your personal data, we will securely delete or destroy it. We will

also consider if and how we can minimise over time the personal data that we use, and if we

can anonymise your personal data so that it can no longer be associated with you or identify

you, in which case we may use that information without further notice to you.

Security of your personal data

We follow strict security procedures in the storage and disclosure of your personal data, and

to protect it against accidental loss, destruction or damage. The data you provide to us is

protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method

of encrypting personal information so that they can be securely transferred over the Internet.

We may disclose your information to trusted third parties for the purposes set out in this

Privacy Policy. We require all third parties to have appropriate technical and operational

security measures in place to protect your personal data, in line with UK and EU law on data

protection rules.

International Data Transfer

Entia uses service providers who operate in multiple jurisdictions, some of which are not

located in the European Economic Area (EEA), such as the USA. While countries outside

the EEA do not always have strong data protection laws, we require all service providers to

process your information in a secure manner and in accordance with UK and EU law on data

protection. Entia will avoid where possible transferring your data outside the EEA. We utilise

standard means under EU law to legitimise data transfers outside the EEA.

Sharing your personal data

We may also share your personal data with the following third parties for the purpose

described in this Privacy Policy:

a. Government authorities, law enforcement bodies and regulators for compliance with

legal requirements

b. Trusted service providers we are using to run our business such as bookkeeping

agents, cloud service and email service providers which provide our computing infrastructure

and email marketing service providers assisting our marketing team with running customer

surveys and providing targeted marketing campaigns.

c. Legal and other professional advisers, law courts and law enforcement bodies in all

countries we operate in order to enforce our legal rights in relation to our contract with you

Data Protection Officer

We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this policy.

You have the right to make a complaint at any time to a supervisory authority. The

Information Commissioner's Office is the lead data protection supervisory authority for Entia

as a UK data controller.

Your data protection rights

Under certain circumstances, by law, you have the right to:

● Request information about whether we hold personal information about you, and, if

so, what that information is and why we are holding/using it.

● 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. You

also have the right to object where we are processing your personal information for

direct marketing purposes.

● Object to automated decision-making including profiling, that is not to be subject of

any automated decision-making by us using your personal information or profiling of

you.

● 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 transfer of your personal information in an electronic and structured form to

you or to another party (commonly known as a right to “data portability”). This

enables you to take your data from us in an electronically useable format and to be

able to transfer your data to another party in an electronically useable format.

● 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. 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.

If you want to exercise any of these rights, then please contact our DPO by email: data-

protection@entia.co.

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.

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.

Changes to Privacy Policy

Our Privacy Policy may change from time to time and any changes to the statement will be

communicated to you by way of an email if we have contact details for you and updated on

this page.

Change List

● May 2018:

○ First version.

● September 2018:

○ Changed phone number

○ Added in details in “What Personal Data we collect” to cover user research surveys about health conditions

○ Added in details in “What we use your personal data for, why and for how long” to cover user research surveys about health conditions