Paind Website Application Privacy Notice

Consent to usage

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in our Terms of Use Policy and it is important that you read that information.

How you can withdraw consent

You may change your mind and withdraw consent to us processing your personal data at any time by contacting us hello@paind.com, but that will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw consent, you may not be able to use all of the services Paind has to offer.

Consent to processing Location Data

YES I consent to the processing of my Location Data from the data that I choose to provide to the app so that location-enabled Services are activated. Examples of location-based services include showing you local community groups and pain-informed clinicians in your area. The app does not access your device’s GPS and we do not track your current location through the app.

NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.

Location Data

Oso Pain Management Ltd (we) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy (together with our website terms as set out in our terms and any additional terms of use incorporated by reference into the website's terms, together our Terms of Use) applies to your use of:

  • The Paind website hosted at paind.com (Website).
  • Any of the services accessible through the Website (Services) that are available on the Website. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This Website is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

IMPORTANT INFORMATION AND WHO WE ARE

Contact details

Our full details are:

Full name of legal entity: Oso Pain Management Ltd

Name or title of data privacy manager: Charles Balcombe

Email address: hello@paind.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 10/08/2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Web App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

The Web App and the App Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data.
  • Contact Data.
  • Financial Data.
  • Transaction Data.
  • Device Data.
  • Content Data.
  • Profile Data.
  • Usage Data.
  • Marketing and Communications Data.
  • Location Data.
  • Health Data.

We explain these categories of data here.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity...

We may also collect, store and use the following Special Categories of Personal Data:

  • Health Data

How is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial, Health and Marketing and Communications Data) you consent to giving us about you by filling in forms on the Web App or App Site, or by corresponding with us (for example, by email or chat)...
  • Information we collect about you and your device. Each time you use our Web App or visit our App Site we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies...
  • Location Data. We use the address (town/postcode and country name) that you optionally give us to determine and set your static location. Some of our location-enabled Services require your personal data for the feature to work...
  • Information we receive from other sources including third parties and publicly available sources...

Cookies

We use cookies to distinguish you from other users of the App Site and to remember your preferences. This helps us to provide you with a good experience when you use the Web App or the App Site and also allows us to improve the Web App and the App Site...

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform a contract we are about to enter or have entered with you.
  • 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...
  • Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us...

Purposes for which we will use your personal data

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:

  • External Third Parties as set out in the Glossary.
  • Specific third parties such as Amity and Mixpanel.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK...

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology...

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

Details of retention periods for different aspects of your personal data are available by contacting us...

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes...

In some circumstances, you can ask us to delete your data: see Your legal rights below for further information...

In the event that you do not use the Web App or App Site for a period of 24 months then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer or your personal data.
  • Right to withdraw consent.

Glossary

Lawful Basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose...

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience...

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract...

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

External Third Parties

  • Service providers acting as processors based in the UK and Europe who provide various administration services.
  • WeRDevs
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide banking, legal, insurance and accounting services.
  • HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the right to:

  • Request access to your personal data: This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of your personal data: This enables you to have any incomplete or inaccurate data we hold about you corrected.
  • Request erasure of your personal data: This enables you to ask us to delete or remove personal data under specific circumstances.
  • Object to processing of your personal data: This allows you to object to our processing of your personal data where we are relying on a legitimate interest or processing it for direct marketing purposes.
  • Request restriction of processing of your personal data: This enables you to ask us to suspend the processing of your personal data under certain conditions.
  • Request the transfer of your personal data: This allows you to receive your personal data in a structured, commonly used, machine-readable format.
  • Withdraw consent: You can withdraw your consent at any time where we rely on it as a lawful basis for processing your personal data.

Description of Categories of Personal Data

  • Identity Data: First name, last name, display name, date of birth, gender.
  • Contact Data: Billing address, delivery address, email address, telephone numbers.
  • Financial Data: Bank account and payment card details.
  • Health Data: Details about your general mental and physical health.
  • Transaction Data: Details about payments to and from you, in-Web App purchases.
  • Device Data: Type of mobile device, unique device identifier, mobile network information, mobile operating system, type of mobile browser, time zone setting.
  • Content Data: Information stored on your device, including posts, photos, videos, check-ins.
  • Profile Data: Display name, Web App purchase history, bio, preferences, feedback, survey responses.
  • Usage Data: Details of your visits to the Web App and the App Site, traffic data, communication data, resources accessed.
  • Marketing and Communications Data: Preferences in receiving marketing, communication preferences.
  • Location Data: Static location provided through the app.