This privacy policy should be read in conjunction with the BetterBe Services Agreement.
If you are a BetterBe account holder, just visiting the BetterBe website (www.Betterbegroup.com) (“the Website”), using the BetterBe On Track App (“the BetterBe App”), or using any other Services we provide, this privacy policy applies to you.
Any information that directly identifies you (such as your name), and any information that can be used to identify you (such as your IP address), is “personal information”. We are committed to protecting and respecting your privacy. This privacy policy tells you when we collect personal information from you, how we use it, and how we disclose it to third parties. This privacy policy does not apply to how third parties use your personal information.
- Who we are
- We are the BetterBe Group Limited, an Isle of Man company with registration number 136122C, having its registered offices at The Bungalow, Ballamanagh Road, Sulby, IM7 2HB, Isle of Man. In this policy, we refer to ourselves as “BetterBe”, “we”, “us”, or “our”.
- We are responsible for the Website and the BetterBe On Track Mobile Application (referred to as BetterBe App below).
- We are registered with the Isle of Man Information Commissioner under registration number R002805.
- Our data protection officer is Lisa Burri. You can reach her via email at support@betterbegroup.com.
- When and how we collect data
From the first moment you interact with us, we are collecting data. Sometimes you give us information directly (such as when you tell us your name when registering an account) and sometimes we collect data about you, either automatically (such as when we note your IP address) or from other sources, like publicly available websites or from a trusted data supplier like Google.
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- You give us information directly when you:
- register an account with us;
- download content;
- place an order on the Website or purchase any Services;
- participate in messaging or social media functions on the Website or the BetterBe App;
- share data regarding your health or activities (such as the number of steps you took or the distance you travelled);
- share emails with us;
- chat with us for customer support; or
- opt-in to marketing messages.
- We collect information about you automatically or from other sources when you:
- browse any page of the Website;
- use the Website or the BetterBe App;
- communicate with us in any way.
- You give us information directly when you:
- Types of data we collect
We strive to collect only the personal information that we need. We may collect (including but not limited to data collected through Google):
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- Personal details
Your name, address, telephone number, email address, date of birth, age, and your gender.
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- Your account details
Your username and password.
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- The relationship between individuals with the same account, for example, if you have a family account.
- Information relating to your health
Information that you share with us regarding your physical or mental health or condition. This may include information that can be used to make inferences about, or detect your health status.
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- Information relating to your fitness
The information you share with us regarding your fitness and exercise activities, such as the number of steps you took or the distance you travelled. The BetterBe App will not automatically collect your data, you will have the option to opt in. If you choose to have the BetterBe App integrate with Google Fit, the app will have access only to the health data types you opt-in to access. The data read from Google Fit is used solely for visualizing your data within the app. It is not collected or disclosed outside of your local installation of the app. In no case is your personal data ever transferred to a third party.
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- Journeys
If you opt in to participate in one of our journeys, you agree that your anonymous activity data is securely uploaded to our servers. You can always contact us on support@betterbegroup.com if you want all of your anonymous data to be removed from our servers completely.
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- Google Fit
We uphold a strict policy of non-disclosure regarding your Google Fit Data to third parties. Your data is securely stored locally and is expeditiously deleted upon the removal of the application.
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- Employment information
The name of your employer and your job title.
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- Financial information
Your bank account number, sort code, credit/debit card details.
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- Device information that identifies you
Your IP address, login information, browser type and version, time zone setting, browser plug-in types, geolocation information about where you might be, operating system and version, etc.
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- Data on how you use the Services
Your URL clickstreams (the path you take through the Website), products/services viewed, page response times, download errors, how long you stay on our pages, what you do on those pages, how often, and other actions.
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- Location data
We will request you to consent to the use of location services every time you use the BetterBe App. You may disable this functionality at any time.
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- If you choose to allow us to upload your data from Google Fit, it will enhance your Application experience by combining information from both sources. This permission enables the Application to seamlessly integrate with Google Fit, providing you with a comprehensive overview of your fitness progress. You have complete control over this integration and can disable the connection at any time to stop uploading of your personal information to your Google Fit account.
- Other information you provide us
Details such as the content of your communications with us, including customer support, social media, and information that you post on the BetterBe App or the Website.
The only situation we may get access to your personal identifiable information (PII) is when you personally decide to email us your feedback or to provide us with a bug report. The PII we may get from you in that situation are strictly limited to your name, email address and the contents of your response only. In above situation, we guarantee that your PII will only be used for contacting you and improving our services. We will never use such information (e.g. your name and email address) for any other purposes, such as to further market our products, or to disclose your personal information to a third party for commercial gains.
- How and why we use your data
We process your data (including but not limited to data collected through Google) to:
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- provide the Services to you and to improve them;
We use analytics services as described in this section that help us understand how the BetterBe App is being used. The processing of your personal data takes place in compliance with the General Data Protection Regulation (“GDPR”). We do not share any personal, Google Fit or Apple Health Kit data.
We collect information about your activity on our services, for instance how you use them (such as frequency, duration of usage, app crashes, features you’ve been using, advertising that you click on).
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- collect information from and about the device(s) you use to access our services, including:
hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, app version, app name, type of user (company admin/member), advertising IDs (such as Google’s Advertising ID, which is randomly generated number that you can reset by going into your device’s settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address).
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- create and manage your account with us;
- process any transactions concerning the Services;
- manage our relationship with you and to communicate with you regarding your account;
- notify you about changes to the Services or to our Services Agreement or policies;
- administer the Website and the BetterBe App, and for internal operations, including troubleshooting, testing, statistical and survey purposes;
- allow you to participate in interactive features of the Services;
- protect computers, devices, and the information they hold;
- detect, investigate, report and seek to prevent fraud and financial crime, managing risk for us and account holders;
- provide you with information about other goods and services we offer, or which third parties offer within the BetterBe App;
- make suggestions and recommendations to you and other users of the Services;
- respond to complaints and seek to resolve them;
- run our business in an efficient and proper way;
- exercise our rights as set out in agreements; and
- comply with the law.
- Cookies
We use cookies to distinguish you from other users of the Services. This helps us to provide you with a good experience when you browse the Website, to improve the Services, and to help us better understand user behaviour. If you prefer us not to use cookies, please disable cookies on your browser. If you use your browser settings to disable, reject, or block cookies (including essential cookies), certain parts of the Website or BetterBe App will not function fully. In some cases, they may not be accessible at all.
- How long we keep your personal information
If you are an account holder, we will keep your personal information for as long as your account is active, or until you ask us to delete your personal information. If you are not an account holder, we will keep your personal information only for so long as necessary to fulfil the purposes for which it was collected.
- Who we share your personal information with
We may share your personal information with companies affiliated to us, service providers who act on our behalf, our partners, or others if you direct us to or if you consent to us doing so. We do not share your personal information with third parties for their own marketing purposes. Third parties are required to protect your personal information. Entities we may share your personal information with include:
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- any member of the BetterBe Group, which means our subsidiaries, our ultimate holding company and its subsidiaries;
- service providers who perform tasks on our behalf, such as processing or storing data;
- business partners, including charities, with your consent, with whom we partner to provide services or other offerings to you;
- others, at your direction or with your consent. We will ask your permission prior to sharing your personal information with others; and
- third parties to whom we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of BetterBe, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- Your privacy choices
You may at any time exercise your rights by sending us an email at support@betterbegroup.com
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- Access to information
You can at any time request a copy of information we hold about you, as well as request details of why we have that information, who has access to that information and how we obtained that information. Once we have received your request we will respond within 30 days, unless doing so would adversely affect the rights and freedoms of others (e.g. another person’s confidentiality or intellectual property rights). We’ll tell you if we can’t meet your request for that reason. Any access request will be subject to a fee of £10 to meet our costs in providing you with these details.
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- Correcting inaccurate personal information
You can ask us to correct any personal information that you think is wrong, out of date or incomplete. If you do, we will take reasonable steps to check the accuracy of the information and correct it.
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- Objecting to profiling
You can object to us using your data for profiling you or making automated decisions about you.
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- Porting your personal information to another service provider.
We will give you a copy of your personal information in a commonly used, machine-readable format should you require us to do so.
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- Deleting your personal information
You can ask us to erase any personal information we hold about you, if it is no longer necessary for us to hold the information for purposes of your use of the Services. There may be legal reasons why we need to keep the information, and we’ll tell you if this is the case.
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- Withdrawing consent
You may at any time withdraw your consent to the processing of your personal information.
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- Complaints about the processing of your personal information
You have the right to lodge a complaint regarding our use of your data. Please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the Isle of Man Information Commissioner’s Office, either by calling their helpline or as directed on their website at www.inforights.im.
- Choosing not to give us personal information
You can choose not to provide us with personal information. If you choose to do this, you can continue to use the Website and browse its pages, but without personal information you will not be able to use the App, and we will not be able to process transactions, register an account for you or provide additional Services to you.
- Where we store your personal information
The personal data we collect is processed and stored either at our offices in the Isle of Man or in AWS servers in the UK.
- Transfer of personal information between countries
We will transfer your personal information outside of the UK only to follow instructions by you to do so, or to comply with a legal obligation to do so. If we transfer or store your information outside the UK, we will take steps required by law to ensure that your privacy rights continue to be protected as outlined in this privacy policy.
- Changes to this privacy policy
Any changes to this privacy policy will be posted on the Website or the BetterBe App. Where appropriate, we will notify you via e-mail of any changes.
- Disclosure
- BetterBe On Track’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.