We take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data.

 

Effective: 1st March 2024

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1. What this Privacy Policy covers

This Privacy Policy covers how we treat Personal Data that we gather and subsequently process when you access or use our Service. “Personal Data” means any information that identifies or relates to you and also includes information referred to as “personally identifiable information” or “personal information” under applicable privacy or data protection laws. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

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2. What personal data we collect

2.1 Categories of Personal Data we collect

This section is about the categories of Personal Data that we collect and have collected over the past 12 months as well as data we subsequently process. We use your data for different purposes, and we have split this section up so it is clear what our reason for collecting each category of data is.

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2.1.1 Customer Information

This is information about you that we collect in order to manage your account, for example your name and email address. We use this data to:

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• Generally operate an account for you (eg by referring to your name or using your email to permit you to login).

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We need this information in order to deliver our Service to you. For reference: this means our GDPR “legal basis” is article 6(1)(b) “necessary for the performance of a contract”. But, having collected it, we also use it for other purposes that are discussed in more detail in their own section:

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• We may use some of this information to improve our analysis of your self-reported information. If so, we treat it in the same way as other information in the same category.

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We use your email address, first name, last name, birth date, zip or postal code, and country to improve our use of advertising.

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2.1.1.1 Emails 

We may also use your email address, in order to send you emails for the following purposes:

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• Providing you with information about our products or services.

• Keeping in touch with you about the app and its performance as well as about new versions of the app or similar apps we may develop.

• Sending you updates on our latest developments and scientific discoveries.

• Inviting you to register for webinars we host in relation to our research.

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Our legal basis for doing so is our legitimate interest in promoting our services. For more information, see the “User Research” and “Mailing Lists” sections below.

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2.1.1.2 How long do we keep customer information for?

We keep this information for a period of 6 years after the end of your subscription. Keeping it for this length of time allows us to recognise you if you wish to subscribe again, and is also necessary for us in case we need to resolve any legal disputes that might arise.

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2.1.2 Device & Browser Data

Everyone: If you visit our website, or use our app, then we will also collect information about you. Some of this information is sent directly by your device to us, for example: your IP address, the type of browser you are using, the make of your mobile phone and the contents of cookies we set (see our Cookie Policy). We also use third party analytics providers such as Google Analytics, who collect similar information and then supply us with further analysis derived from it.

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We process this data in order to:

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• Locate errors in our systems or problems our systems may be facing with other systems (such as compatibility with a web browser)

• Improve the functioning of our Service

• Prevent fraud or other criminal activity

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This information is automatically sent to us – although there are technical ways you can prevent us from receiving this information (for example by changing the information your browser supplies to us) – the way in which browser and app software works means it is inevitable that we process it.

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We routinely delete our web server logs after 90 days, unless we are aware of any serious problem that requires investigation (for example fraud or a hostile attack to our systems), in which case we may preserve any information necessary for that investigation for as long as it is needed. Once the investigation is concluded, we will delete the data.

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Our legal basis for collecting and using device and browser data is our legitimate interests in running and improving a commercial service over the Internet, and in providing a better quality of service than we would otherwise be able to if we were not analysing device and browser data.

Cookies: Our use of cookies is a little more complicated, so we have written a detailed Cookie Policy, explaining what cookies are; our additional reasons for processing them and explaining in detail how we process different kinds of cookies.

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URLs we share: We may also include information linked to you in any URL (web link) that we share with you. We use this to enable us to present personalised information to you when you visit our website. 

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2.1.3 Payment Information

This is information that is necessary in order for payments to be processed by our third party payment processor. For example the amount of the payment, payment card type, payment card number, and your billing address. 

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For your security our payment processor only shares the last 4 digits of your payment card number with us.

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We retain this data as long as necessary to comply with our legal obligations under tax and corporate law. As soon as we no longer need the information, we delete it.

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2.1.4 Correspondence

Where you directly correspond with us (such as sending us an email, online chat message, or call us) we will process information about you concerned with that correspondence, including your email and our responses. We keep that information for as long as necessary to deal with the correspondence – for example if you have made a complaint, as long as needed to deal with the complaint – and then for a further 6 years, in case we need it to defend or establish a legal claim.

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2.2 Our purposes for using Personal Data

We have explained specific reasons for processing categories of personal data above.  We may also process any of the information you provide us for the purposes of providing support and assistance in using the Service.

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We may also process your personal information if we are legally required to do so in circumstances where this cannot be reasonably resisted.

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We will not collect additional categories of Personal Data or use the Personal Data we collected for different purposes without providing you notice.

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3. How we share your Personal Data

We share information about you only with the following:

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• Contractors providing us services we use for processing Personal Data, which include:

  • Hosting, technology and communication providers.

  • Security and fraud prevention consultants.

  • Analytics providers. 

  • Support and customer service vendors.

  • Payment processors.

• Our professional advisors, such as if we need to consult a solicitor for legal advice. In all cases these will be advisors under a professional duty of confidence.

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Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

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Data that is not Personal Data

We may convert Personal Data into anonymous data, that is data which can no longer be linked with identifiable individuals, for example by aggregation of data about multiple individuals. We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. 

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For example, we use your self-reported information and some of your customer information to improve our models of the interaction. The models we create have no individual information about you, being the aggregation of data from many individuals. 

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We may use such anonymous data and share it with third parties for our lawful business purposes, including to analyse, build and improve the Service and other future products and services, and promote our business, provided that the data remains anonymous. We do not delete anonymous data on any particular timetable. You may assume that we could keep it indefinitely.  

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4. Tracking tools, advertising and your rights to opt-out

4.1 General tracking

The Service uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Service, analyse trends, learn about our user base and operate and improve our Service. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Service. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Service does not support “Do Not Track” requests sent from a browser at this time.

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For more information about our use of cookies, please see our Cookie Policy.

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4.2 Mailing Lists

You can subscribe to our mailing lists to get the latest updates on our discoveries or information about our products and services without creating a MoxieCoach account and we will use the data you provide us with for these purposes. 

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We process this data because you have consented to us doing so.

If you do not wish to receive emails from us regarding this information, then you can opt out by clicking “unsubscribe from this list” at the bottom of our email.

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If you unsubscribe from our mailing lists, we will need to keep just enough information on file to make sure we respect your preferences in the future. 

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4.3 User Research

If you are a MoxieCoach customer, we may email you to invite you to answer some questions regarding our products or services, participate in new product or service trials, or share feedback with you from customer surveys, interviews or focus groups.

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5. Data security and retention

We seek to protect your Personal Data from unauthorised access, use and disclosure using appropriate physical, technical, organisational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

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The periods for which we retain individual categories of Personal Data are explained under the heading “Categories of Personal Data we collect”, but in some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.

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6. Personal data of children

As noted in our Terms of Service, we do not knowingly collect or solicit Personal Data about children under 18 years of age. If you are a child under the age of 18, please do not attempt to register for or otherwise use the Service or send us any Personal Data. 

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If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at info@moxiecoach.org.

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7. Your rights as a European Union Data Subject 

7.1 Introduction

Our headquarters, at MoxieCoach Limited, are in the United Kingdom. As a result, you are protected by the United Kingdom’s General Data Protection Regulation ("GDPR"), regardless of your citizenship or where you live in the world. You may have additional rights under the GDPR with respect to your Personal Data, as outlined below.

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For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information about a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage, amendment, deletion and disclosure. MoxieCoach will be the controller of your Personal Data processed in connection with the Service.

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If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.

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If you have any questions about this section or whether any of the following applies to you, please contact us at info@moxiecoach.org.

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7.2 Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

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7.3 Personal Data Use and Processing Grounds

The “Our Purposes for Using Personal Data” section above explains the purposes for which we process your Personal Data.

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We will only process your Personal Data if we have a lawful basis under the GDPR for doing so. Lawful bases for processing include:

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• Consent: Except for the specific situations explained below, we process your customer information by consent. You may withdraw your consent at any time and we will stop processing your Personal Data in this way.

• Contractual Necessity: In order to be able to perform our contract, we need to collect customer information we have marked as required and all payment information.

• Compliance with a legal obligation: As explained above, we will sometimes have to process personal data in order to comply with a legal obligation imposed on us. Where those obligations are imposed by UK law, that law will provide us with a lawful ground for processing.

• Legitimate Interest: We process the following categories of Personal Data when we believe it is in our legitimate interest to do so and we do not believe that your rights of freedoms will be unduly interfered with by our processing:

  • Device data is justified by our legitimate interest in maintaining a reliable and secure system, free from errors and external security threats.

  • Where we are required to process personal data due to a legal obligation in the UK, we believe that justifies our processing your data. We believe your rights and freedoms are protected by a combination of UK law.

  • Cookies, for the reasons set out in our Cookie Policy.

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All information about your health, which we would normally be forbidden from processing by the GDPR, is processed by us because you have consented to us doing so.

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7.4 Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

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7.5 Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights please see the UK Information Commissioner’s guide to data subject rights. To submit a request to exercise any of these rights, or to ask for more information, please email us at info@moxiecoach.org. 

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Some of the rights below apply only in specific circumstances. In other situations, we may not be able to fully comply with your request, for example if it would be impossible or would involve a disproportionate effort; or if it jeopardises the rights of others; but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

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• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.

• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. 

• Erasure: In some situations you may have a right to request that we erase some or all of your Personal Data from our systems.

• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilise some or all of our Service. 

• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible. 

• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

• Right to File Complaint: You have the right to lodge a complaint about Moxie Coaches' practices with the UK’s Information Commissioner.

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Our Data Protection Officer is contactable at info@moxiecoach.org.

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8. Changes to this Privacy Policy

We’re constantly trying to improve our products and services, which includes collecting new kinds of data or carrying out new analyses on that data, so the information on this page may need to change from time to time.

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9. How to contact us:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at info@moxiecoach.org.  

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