BACK-TRACK PRIVACY POLICY (European Economic Area incl. UK). This policy is effective 1st August 2021.
BACK-TRACK Europe Ltd is committed to your privacy.
SCOPE
The Scope of this document relates to users of the BACK-TRACK mobile App
This policy explains the information we collect, how we use and share it and your rights in connection with our website and related mobile applications and services, the 'Services'.
Please also refer to our Terms of Service
BACK-TRACK Europe Ltd. is headquartered in the UK.
This policy is effective in the EEA & UK.
PERSONAL DATA
As an organisation, BACK-TRACK Europe Ltd. does not seek to collect personal data for BACK-TRACK device users. To ensure App users have secure access to their BACK-TRACK data, this can only be achieved by verifying the user's identity which is achieved by the use of an email confirmation. This is common practice as it provides a high level of security to the App user and allows BACK-TRACK Europe Ltd. to comply with our legal obligations to protect your data.
Your BACK-TRACK has been provided to you by your employer. In some cases, the email address used may be a company email address, in other cases, it will be a personal email address. In which ever instance, BACK-TRACK Europe Ltd will not contact you again and we will treat your email address as confidential.
We will address forgotten password issues via the secure email link process outlined above.
We do not seek to build a database of your personal data. We will not seek to know your name (although it may be apparent via the email address used).
BACK-TRACK device users are identified within their employer's organisation with a serial number - which may be an employee number or similar. The serial number is used as a pseudonym.
Some employers have an enhanced data protection requirement that requires a multi-factor authentication to verify the identity of anyone trying to access your data. In this instance, we will send you a text with a single use, time limited code that will enable only you to access your data. This will happen only once when you first attempt to log in to the App.
Your employer will ask you to provide an email address (and for those employers wanting to use 2-step authentication to verify identity) your mobile phone number. Your employer will enter these into the BACK-TRACK web interface and we will then use them to set-up and verify your identity when you register with the BACK-TRACK App.
The additional data we collect is;
- Your phone / devices IP address
- Posture related movement & activity data
- For some versions of the BACK-TRACK device which include a GPS chip, we may know Where a posture related event (ie BACK-TRACK movement activation) has occurred. The event location will be recorded to identify risk hot-spots so that these can be investigated.
We will also know;
Your employers name and your work location
The address of your employer
Your BACK-TRACK device's settings, eg the default setting or rehabilitation setting
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information (email address) to verify your identity and to address forgotten password issues - via an email. We may use your mobile phone number to provide an extra verification step when proving your identity. These steps are taken to ensure access to your BACK-TRACK data is secure. We do not need and will not use your personal information for any other purpose.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
The legal basis for processing your personal data is the responsibility of your employer, however, by agreeing to the terms of this App Privacy Policy, you are giving BACK-TRACK Europe Ltd consent to collect posture related movement and activity data, process it, collate it, profile it and provide it to you and to make it available to your employer.
If you do not Consent to BACK-TRACK Europe Ltd. processing your personal data, do not agree to this App Privacy Policy.
ACCESS & CONTROL OF DATA
This personal data detailed above will be transmitted between your phone (mobile device) and our server and is stored until you ask for your data to be deleted, your employer asks for it to be deleted or our contract with your employer comes to an end.
Within the Settings menu, you will be able to access the Delete My Data option. You will also be able to uninstall the App. Please note that uninstalling the BACK-TRACK App does not automatically delete your data. You can reinstall the APP at any time.
If you chose to delete your data, we will advise your employer that you have chosen to do this.
HOW DO WE SHARE YOUR DATA?
Data displayed on the APP will also be available to your employer via their own access to the BACK-TRACK web portal.
Data is not shared with any other parties and we will not request your consent to do so.
HOW LONG WILL WE RETAIN YOUR INFORMATION?
We retain your data until you ask for it to be deleted, your employer requests it is deleted or until our contract with your employer ends.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We will protect your data with a number of technical and security measures including firewalls, encryption and access authorisation controls.
YOUR RIGHTS
We are registered with the UK's Information Commissioner and you can access our certification at www.backtrack.co.uk/icocert
However, if you have a complaint about how we are managing or processing your personal data, you also have the right to complain to the Information Commissioner's Office at www.ico.org.uk/concerns
If you have any questions about this Privacy Policy, please contact us at:
BACK-TRACK Europe Ltd., 1 Emperor Way, Exeter, EX1 3QS
BACK-TRACK Europe Ltd. reserves the right to update this policy from time to time. Please review it regularly. If you object to any of the changes to this Privacy Policy, you should stop using our Services and delete your data. In this instance, we will delete all of the data we hold relating to you, however, will retain the date of deletion for our records. We will also notify your employer that the account has been deleted.