Welcome to our Privacy Policy. Salus Optima is brought to you by L3M Technologies Limited (t/a Salus Optima) with registered office at 15 Westferry Circus, Canary Wharf, London, United Kingdom, E14 4HD (“we”, “us” or “our”), with company number 11157173.
Your privacy is critically important to us. This Privacy Policy sets out how we process personal information about you when you use any part of the Salus Optima mobile application (“App”), including the related online documentation, including any questionnaires and all other content and media provided to you on the App, for example:
our onboarding process where you can tell us about your symptoms and your lifestyle through a series of questions;
data and information collected from wearable devices and other 3rd party integrations (as detailed below);
lifestyle habits and suggestions around diet, hydration, mental health, movement, sleep and other relevant areas (each based on your questionnaire responses and ongoing App usage);
daily activities and/or symptom tracking;
a journal of activities and/or symptoms that have been tracked;
daily education articles;
a live chat with our coaches, experts or other professionals; and
an ability to earn rewards through App engagement, collectively the “Services”.
The App is not intended for children (anyone under the age of 18) and we do not knowingly collect data relating to children.
We are a data controller of the personal information we process and are therefore responsible for ensuring our systems, processes, suppliers and staff comply with data protection laws in relation to the information we handle. If you do not agree with this Privacy Policy, you should not submit information to us.
After you install our App but before you start using the Services, please indicate your consent to our processing of your personal data as described in this Privacy Policy.
You can find out more about our responsibilities and about how and why we collect and use your personal information by reading this Privacy Policy. However, if anything is unclear or if you have any questions about this Privacy Policy, please contact us at support@salusoptima.com
Personal data, or personal information, means any information about a person from which they can be identified. We may collect, store, and use some or all of the following categories of personal information about you:
Identity Information
personal contact details such as name, title, gender, addresses, telephone numbers, and personal email addresses;
date of birth and place of residence;
next of kin and emergency contact information;
start date;
physical measurements, training statistics and dietary information;
photographs; and/or
information about your use of our information and communications systems (such as messages to personal trainers, goals and notes).
Subject to your explicit consent, we may also collect, store and use your health data. This is considered a special category of more sensitive data. Where we process health data, it will be treated confidentially and will never be used for direct marketing purposes.
System Information
When you log on to and interact with our App we automatically collect information about your use of the App including details of your visits such as pages viewed and the resources that you access. This information will include traffic data, location data, IP address, browser, operating system, referral source, length of visit, clickstream data and other communication data.
Identity Information
We collect Identity Information provided voluntarily by you. For example, when you register with or use our App (by entering training plan details, goals, or making a booking).
We also collect Identity Information when you fill out a form or questionnaire or contact us (by email or telephone) to ask a question or request information.
We also collect Identity Information through various other mobile applications (including the Apple Health app and Google Fit app) where you give us explicit consent to do so (detailed further below).
Location Data
We also use GPS technology, Bluetooth, crowd-sourced WIFI hotspots and other sensors (such as accelerometers) to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
In order to provide our Services to you, we may be required to process special category data, for example your health information. Where we process this special category data, data protection law requires that we satisfy certain additional conditions. We will only process special category data with your explicit consent to the processing.
In particular, we may ask you to grant us access to the Health app on your Apple device or the Google Fit app on your Android device, as well as other relevant 3rd party devices and services (e.g. Fitbit, Garmin, or others), and to share with us the health data which is collected, processed and stored as part of these products and services. You decide what information goes into the Health or Google Fit app and what information we can get from it. By allowing us access to that health data you are granting us explicit consent to process it in accordance with this Privacy Policy.
Providing our Services
As part of the provision of our Services, we may use the personal information that we collect from you to:
register you as a user of the App;
provide your details to our coaches, experts or other appropriate professionals;
share with our trainers and partners who are helping us improve and build the programmes offered via the App;
provide limited health monitoring, virtual fitness streaming and workout recordings;
notify you of renewal reminders and/or payment details, where applicable;
provide you with an appropriate address for support and enquiries relating to your use of the App; and/or
manage our relationship with you (for example by notifying you about changes to our terms or asking you to complete a survey).
Monitoring, administering and improving
We use your personal information to help us to monitor our performance, administer and improve our App by, for example:
tracking and analysing activity to identify patterns and help us improve our App;
troubleshooting, conducting data analysis, testing, system maintenance, support, reporting and hosting of data;
using data analytics to improve customer relationships and experiences;
analysing information so that we can prioritise features that are relevant and popular;
educating, training and developing our staff’s performance;
ensuring network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution;
preventing fraud; and/or
other business administration such as management and planning, including accounting and auditing.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Data protection law says we only have the right to use your personal information where we can identify a lawful basis for doing so. Please see below for details of the legal bases on which we rely to do so:
where we need to use the information to perform the contract we have entered into with you (including to provide you with the Services);
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or
where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
The Internet is not a secure medium. However, we have put in place various security procedures as set out in this Privacy Policy.
Please be aware that communications over the Internet, such as emails and online messages are not secure unless they have been encrypted. Your communications may route through a number of
countries before being delivered – this is the nature of the Internet. We cannot accept responsibility for any unauthorised access or loss of personal data that is beyond our control.
We believe that we have appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that personal data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
We will not share your personal information with or to third parties, except as otherwise provided for in this Privacy Policy and under the following limited circumstances when we want to or are compelled to share your personal information, including:
with our carefully selected trainers and partners who help us improve and build the programmes offered via the App;
with our coaches, experts and other appropriate professionals to allow them to provide you with the coaching services you request from them;
with third party service providers or suppliers to enable us to provide our Services (for example payment processors, webhosts, ID verification partners etc). Where we share data with service providers, we require them to sign a contract that obliges them amongst other things to have stringent security measures in place, comply with our instructions and help us to comply with data protection law;
to another legal entity on a temporary or permanent basis, in connection with a business deal, such as a merger, financing, acquisition, or sale of our business;
where we are required to do so by law; and/or
where you have provided your consent.
We may transfer the personal information we collect about you outside the country you are located in in order to perform our contract with you. Where this occurs we will ensure that your personal information receives an adequate level of protection and we will put in place appropriate measures to ensure that your personal information is treated in a way that is consistent with UK laws on data protection. If you require further information about these protective measures, you can request it by contacting us at support@salusoptima.com.
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. We also have 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.
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 information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your information, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal requirements.
Under certain circumstances, by law you have the right to:
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.
The App may include links to third-party sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party sites and are not responsible for the privacy policies and practices of other websites even if you accessed the third party website using links from our website. We recommend that you check the policy of each website you visit before deciding whether to proceed and contact the owner or operator of such website if you have concerns or questions.
We reserve the right to update this Privacy Policy at any time, and we will provide you with a new Privacy Policy 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.
English law governs this Privacy Policy, its subject matter and its formation. The courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.
This Privacy Policy (together with our Terms of Use) constitute the whole agreement between us and supersede all previous discussions, correspondence, negotiations, previous arrangement, understanding or agreement between us relating to the provision of Services via our App.
If any of the terms of this Privacy Policy are found by any competent authority to be invalid, unlawful or unenforceable to any extent, such term, condition or provision will to that extent be severed from the remaining terms, conditions and provisions which will continue to be valid to the fullest extent permitted by law.
If we delay in taking steps against you when you break this contract, that will not mean that you do not have to do what we ask in order to remedy your breach and it will not prevent us taking steps against you at a later date.
If you have any concerns about this Privacy Policy, please contact: support@salusoptima.com
Last updated: July 2023
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