We are TakeTen Ltd, a private limited company incorporated in Northern Ireland with company address at 13 Maryville Park, Belfast, Antrim, BT9 6LN and company number: NI605634. Any reference in this policy to (“TakeTen”, “we”, “our”, or “us”) is a reference to us.

Our mission is to upskill a generation of children, young people, and adults, providing them with the strategies to manage stress, to allow them to thrive at school, at work or at home.

This policy document covers how we handle personal information (defined below) relating to our customers and personal data relating to end-users in connection with the use of the TakeTen Application (iPad and smartphone App) (“our App”). Our App is made available to end users which depending on the customer, may include students, employees, patients or other.

This policy will inform you what information we collect from our customers and end-users when they download and use our app and how we use it:

  1. “Personal information” (“PI”) – personally identifiable information that allows TakeTen Ltd to identify you directly or indirectly.
  • “Non-personal information” (“NPI”) – information that cannot be linked or associated with any individual’s identity. If a situation arises whereby NPI is combined with other information that in turn may identify an individual, this will be treated by Taketen as PI.

Personal Information collected by TakeTen. “Customer Data”

Customer Data is information we collect about contacts within our customers. We collect the following information about our customers:

Identity DataFirst name; last name.
Contact DataAddress; email address; telephone number;
Transaction DataDetails about transactions you have carried out
Marketing                  and Communications DataMarketing preferences; communication preferences.

We use this data primarily to negotiate and enter into a contract with you and provide you with our services. We may also use the data to ensure that the contract is being complied with; to enforce our legal rights. From time to time (to the extent legally permissible) we may also contact you for marketing purposes.

Where required at law, TakeTen will obtain your consent prior to sending you commercial electronic messages by email. You may unsubscribe from receiving marketing communications from us, such as announcements about new products, services or features.

“End-user Data”

End-user Data is information we collect about users of our App.

Technical DataWe collect technical data such as IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.

We use this data to ensure that our App is being used by end-users in accordance with the licence terms agreed with our customers and/or our terms of use. We may also use the technical data for statistical purposes.

All Personal Information (usernames or passwords), biometric data (heart rate variability sessions), usage, and performance data are stored entirely on the device which our App is downloaded onto (iPad or smartphone). No such end-user PI is collected or stored on the TakeTen server nor is it accessible by TakeTen. End-users can delete all stored information on their device by deleting the TakeTen App.

Third Party App Stores

If you wish to download and install our App from an app store (such as Google Play or the Apple AppStore), you must first register with the provider of the respective app store), for a user account and agree to that app store’s user agreement. We have no influence on the terms of such user agreement and are not a party to such user agreement.

Security

The TakeTen server facility is located in London, UK. PI is retained on the TakeTen server for the length of time that we hold an active contract with a customer, or as required by applicable laws, whichever is longer. For more information on the rights of data subjects, please see below.

Customer and end-user PI is protected using a secure log-in facility. The use of SSL encryption is not currently enforced.

Analytics Service Providers

We use Google Analytics to obtain analytics based on how end-users interact with our App. We use such analytics to provide reporting capabilities to customers if they request information on App usage specific to that customer licence. The information aggregated relates to the group of active users and provides information such as:

  • Users. The number of current users on a specific Licence
  • Sessions. The total number of user interactions conducted on the App.
  • Average session duration.
  • Percentage of new sessions.

You can find more information about Google Analytics here: (https://analytics.google.com/analytics/web) or visit Google’s privacy policy here ( Privacy Policy – Privacy & Terms – Google).

How We May Share Information

We do not sell, rent, or market customer or end user PI to other companies. Instances where we may share PI include:

  1. With customer permission, we may display a personal testimonial or endorsement about our products and services on our company website, and in internal team materials. We may include your name and organisation if you give us permission.
  • As Part of a Business Transition. In the event TakeTen Ltd goes through a business transition, such as a merger with, acquisition by, or sale of all or a portion of its assets to another company, or other corporate change, your personal information may be disclosed or transferred to the other company and other relevant parties as part of the process in accordance with applicable law. Any successor entity would be required to comply with applicable law in its handling of personal information.

We are committed to protecting the personal information we gather. Please note that even with safeguards, neither the Internet nor any data storage system can be guaranteed to be 100% secure. We keep your personal information for only as long as necessary for the purposes described in this Privacy Policy. We may also retain your personal information to comply with our tax, accounting and financial reporting obligations and as otherwise required by law.

Your Rights as a Data Subject

You have certain rights in relation to the personal data we hold about you. If you would like to exercise any of these rights, please contact us using the details set out above.

Your right of accessIf you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.
Your          right           to rectificationIf the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.
Your right to erasureYou can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have
 shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
Your right to restrict processingYou can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
Your     right     to     data portabilityYou have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.
Your right to objectYou can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.
Your rights in relation to automated decision- making and profilingYou have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Your right to withdraw consentIf we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your right to lodge a complaint with the supervisory authorityIf you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided above section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or
 the place of the alleged infringement. You can find a list of contact    details    for    all    EU    supervisory    authorities    at http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm. As we are incorporated in the United Kingdom, our regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk.

Changes to the Policy

This Policy may be modified from time-to-time following changes in App functionalities, or our use of personal information related to customers and/or end users. Any changes made in the Policy will be deemed effective on publishing of revised policy on the TakeTen website. Active customers will also be informed by email.