HRV Fit Ltd is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
HRV Fit Ltd may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 1 March 2012.
What we collect
We may collect the following information:
- name and job title
- contact information including email address
- demographic information such as postcode, preferences and interests
- other information relevant to customer surveys and/or offers
- personal characteristics including ethnicity and health information. Health information includes health conditions identified as risk factors for COVID-19; information relating to COVID-19 (symptoms, test results and hospitalisation details (where applicable); history of organ transplant; history of surgery (within 14 days of COVID-19 symptoms) and smoking history.
How we get the personal information and why we have it
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- To contribute your information to the COVID-19 project ‘Using daily heart rate variability measures to identify the onset and severity of COVID-19’.
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
- We may periodically send promotional email about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
- From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.
- We may use the information to customise the website according to your interests.
- We use the information that you have given us in order to investigate the relationship between heart rate variability (HRV), heart rate, wellness metrics (e.g. tiredness), and symptoms of COVID-19. We will use the data to create a report summarising the findings and an anonymised database (where you would no longer be identified).Your personal data will be shared with HRV Fit Ltd subcontractors conducting the analysis. Personal data will not be shared with any third parties. The anonymous report and database (where individuals are no longer identifiable) could be shared/sold with third parties.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are because we have a legitimate interest.
Your data will be collected after completion of the COVID-19 survey (the Data Processor is SurveyMonkey), and when individuals email data files form their HRV app to firstname.lastname@example.org. Individuals will be asked to provide explicit consent, and opt-in to this method of data collection. Consent can be withdrawn without providing a reason by emailing email@example.com. All personal data will be deleted on request. This is possible up until the data has been anonymised, and individuals can no longer be identified from the data.
The lawful basis for processing this data is ‘legitimate interests’. The condition for processing data relating to your ethnicity and health is ‘explicit consent’. We will process this data with the aim of investigating the relationship between HRV, heart rate, wellness metrics and COVID-19 symptoms and severity. Personal data will be held until 31/08/20 at the latest. Email is needed to be stored until this point so that we can match survey responses to the data submitted by email, and so that we can contact individuals for clarification on submitted data. All data will be fully anonymised by 31/08/20.
Personal data will be shared with HRV Fit Ltd staff members, and authorised sub-contractors. Data will be pseudonymised when possible, meaning identifiable information fields will be replaced with an artificial identifier, with access to the ‘key’ allowing identification being restricted. This key will be deleted as part of the anonymisation process.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Your information is securely stored on password protected computers, and password protected cloud based storage (Dropbox)
Free text comments included within app data, and any app data from over 12 months before the date of COVID-19 symptom onset will be removed as soon as possible after receipt by HRV Fit Ltd.
We keep personal data including email, personal characteristics, ethnicity and health information until 31/08/20. We will then dispose of personally identifiable information by deleting all data which could enable re-identification including email addresses and all emails received or sent to the email address. Questionnaire data will be minimised to prevent possible re-identification. Any dates associated with the data (e.g. date of COVID-19 symptom onset) will be deleted and replaced with relative dates (e.g. day 1, day 2, day 3). Age will be changed to bands of years if required (e.g. where only one individual reports a particular age, the age will be removed and replaced with an age band including other individuals).
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at firstname.lastname@example.org if you wish to make a request or a complaint.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office, Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF UK
Helpline number: 0303 123 1113 ICO website: https://www.ico.org.uk
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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Used by Google Analytics. Each unique browser that visits a page on the site is provided with a unique ID via the __utma cookie. In this way, subsequent visits to the website via the same browser are recorded as belonging to the same (unique) visitor. Thus, if a person interacted with the website using different browsers, the Analytics reports would track this activity under two unique visitors. Similarly if the same browser were used by two different visitors, but with a separate computer account for each, the activity would be recorded under two unique visitor IDs. On the other hand, if the browser happens to be used by two different people sharing the same computer account, one unique visitor ID is recorded, even though two unique individuals accessed the site.
__utmb & __utmc
Google Analytics uses these two cookies to establish a session. If either of these two cookies is absent, further activity by the user initiates the start of a new session.
When visitors reach the site via a search engine result, a direct link, or an ad that links to the page, Google Analytics stores the type of referral information in a cookie. The parameters in the cookie value string are parsed and sent in the GIF Request (in the utmcc variable). The expiration date for the cookie is set as 6 months into the future. This cookie gets updated with each subsequent page view to the site; thus it is used to determine visitor navigation within the site.
End of session
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Links to other websites
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
- whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
- if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at email@example.com
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to HRV Fit Ltd, Brookwood, Hazel Grove, Southampton, SO40 7AJ United Kingdom.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
When using our Applications and Cloud Services (such as ithlete on iOS, ithlete on Android, ithlete Coach, ithlete Pro & ithlete Team), we pledge to respect your privacy, to be transparent about our data practices, to keep your data safe, to never sell your personal data, to let you decide how your information is shared, and to only collect data that helps us improve our products and services.
WHEN YOU SYNC YOUR DEVICE
When you sync your device, data about your heart rate measurements, subjective assessments and activity is securely transferred from your device to our servers. This data is stored and used to provide the ithlete Coach, Pro & Team services. Each time a sync occurs, we also log data about the transmission. Some examples of the log data are the sync & reading time and date, device type, and the IP address used when syncing.
HOW WE USE YOUR ACTIVITY DATA
HRV Fit Ltd uses your data to provide you with the best experience possible, to help you make the most of your fitness, and to improve ithlete. Here are some examples:
- Your anonymized data is used for research including collaborations with Universities & third parties to understand and improve ithlete products and services.
- Logs and other data are used to troubleshoot ithlete services; detect and protect against error, fraud or other criminal activity.
- De-identified data that does not identify you may be used to inform the health community about trends; for marketing and promotional use.
In the cases of ithlete Coach, ithlete Pro & ithlete Team the data is kept on our servers and is subject to the Data Protection Act 1998. By submitting data onto either of these systems the user consents to this anonymized use.