Last updated June 2022.
The Diabetes Edit is operated by Younger Lives Limited.
Younger Lives Limited and its affiliates ("Younger Lives", "we" or "us") provide online services including but not limited to the Younger Lives website and associated computer programs, algorithms and mobile applications.
Younger Lives Limited takes privacy seriously. The following five principles underpin our approach to respecting your privacy:
1. We value the trust that you place in us by giving us your personal information. We will always use your personal information in a way that is fair and worthy of that trust.
2. We will provide clear information about how we use your personal information.
3. We shall always be transparent with you about what information we collect, what we do with it, with whom we share it and who you should contact if you have any concerns.
4. We will take all reasonable steps to protect your information from misuse and keep it secure.
5. We will will comply with all applicable data protection laws and regulations and we will co-operate with data protection authorities.
This Privacy Notice applies to personal information collected by Younger Lives in connection with the services offered. This includes information collected through our websites, applications and branded pages on third party platforms and applications accessed or used through such websites or third party platforms (“Younger Lives Sites”) and information collected when you engage us to provide coaching services (“Coaching Services”), together referred to as “Services”.
This Privacy Notice also applies to targeted content, including offers and advertisements for products and services, which we (or a service provider acting on our behalf) may send to you on third party websites, platforms and applications (“Third Party Sites”) based on your Usage Data (as defined below). These Third Party Sites may have their own privacy policies and terms and conditions. We encourage you to read them before using those Third Party Sites.
This Privacy Notice is hereby incorporated into and forms part of the terms and conditions of use of the applicable Services. For information about Younger Lives and who is responsible for protecting your personal information, see your privacy rights and who to contact below.
We respect your right to privacy and so we will only process personal information about you in line with applicable data protection laws. We comply with the retained EU law version of the General Data Protection Regulation (2016/679) and the Data Protection Act 2018. If any of these laws are replaced or superseded, we will comply with that too.
We are registered with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/), and our registration number is ZA169271. If you have any concerns about data protection, we would appreciate if you contacted us first so we can discuss these with you before you approach the ICO. You can reach us at email@example.com.
By using the Services, you are consenting to Younger Lives collecting, using and disclosing your personal information in accordance with this Privacy Notice. If you do not agree to the collection, use and disclosure of your personal information in this way, please do not use the Services or otherwise provide us with your personal information.
Younger Lives will only collect, use or disclose your personal information where it is fair and lawful to do so. In most cases, we will ask for your consent explicitly but, in some cases, we may infer consent from your actions and behaviour. We may ask you to provide additional consent if we need to use your personal information for purposes not covered by this Privacy Notice. You are not obliged to provide such consent but if you decide not to then your participation in certain activities may be restricted. If you provide additional consent, the terms of that consent shall prevail in the event of any conflict with the terms of this Privacy Notice.
Please note, however, that we may process your personal information without consent if we have a legitimate reason to do so, provided that such use will not have a prejudicial effect on your own rights, freedoms and interests. Any such use shall be in accordance with the Younger Lives Privacy Principles set out above.
In this Privacy Notice, your "personal information" means information or pieces of information that could allow you to be identified. The personal information we typically collect from you is your name and email address, but also information about your lifestyle or preferences, such as hobbies, interests, or different factors that may impact your health and wellbeing.
We may collect, use, store and transfer different kinds of personal information about you when you engage with us in the ways outlined in this Privacy Notice. Personal information falls under the following categories:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data includes information about how you use our website, products, and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Information you give us directly.
We may collect information from you directly when you provide us with personal information through your use of our Services, including the Diabetes Edit platform, or when you sign up to receive information from us, register for prize draws or competitions, fill out a survey, or make a comment or enquiry.
The types of information we may collect from you directly include your:
* Email address
* Your responses to questions we ask on Younger Lives services
* Any other personal information you voluntarily provide to us
Where you engage us to provide Coaching Service, we will collect the following information from you:
* Email address
* Your responses to questions we ask on Younger Lives services
* Any other personal information you voluntarily provide to us
The lawful basis for collection of this information is:
* To perform our contract with you so that we can provide you with the services our Younger Lives Sites provide, so we can provide you with our Coaching Services and to respond to any correspondence you send to us.
* It is in our legitimate interest to correspond with you, to provide you with the services our Younger Sites provides, to provide you with our Coaching Services and where you have signed up for our marketing, to present relevant products or services we think you will be interested in. The purpose in this instance is direct marketing
INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU USE YOUNGER LIVES SITES
The types of information collected automatically may include:
* Information about the type of browser you use
* Details of the web pages you have viewed
* Your IP address
* The hyperlinks you have clicked
* Your user name, profile picture, gender, networks and any other information you choose to share when using Third Party Sites (such as when you use the “Like” functionality on Facebook or the +1 functionality on Google+)
* The websites you visited before arriving at our website
We may share Usage Data with trusted third parties (e.g. advertisers, advertising agencies, advertising networks, data exchanges, etc.) in order to offer you tailored content, including more relevant advertising for products and services which may be of interest to you. These third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to help us deliver customised content and advertising to you when you visit a Younger Lives site. The lawful basis is it is in our legitimate interest so that we can present relevant products or services we think you will be interested in.
Depending on your location, there may be solutions to help you control your online behavioural advertising preferences (such as whether certain third parties may collect and use your Usage Data for targeted advertising purposes). For example, in Europe the website www.youronlinechoices.com allows you to choose which companies can deliver customised ads.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We use your personal information to:
* Improve your experience on the Younger Lives Sites
* To contact you regarding products and services which may be of interest to you, provided you have given us consent to do so or you have previously requested a product or service from us and the communication is relevant or related to that prior request and made within any timeframes established by applicable laws.
* To provide you with products or services that you request from us.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
Younger Lives believes in partnership to help people to change their health behaviours for the better. As part of that mission we may share your personal information with strategic partners and trusted third parties based outside the country in which you live so that they may process that data on our behalf.
* Agencies who help us deliver and analyse the effectiveness of our advertising campaigns and promotions
* Third parties required to deliver a product or service to you, such as where a client has engaged us to provide the Diabetes Edit platform to them, and their employees / customers
* Law enforcement or government authorities where they have followed due legal process to request us to disclose the information
* Third parties who wish to send you information about their products and services, but only if you have given us consent to do so
* Third party providers of services, such as data processing, to Younger Lives
* Web tool and web analytics providers, such as Google Analytics, Google Tag Manager, MailChimp and Wix
* If we want to sell our business, or our company, we can disclose it to the potential buyer
* We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006
If we do share your personal information with a strategic partner or with trusted third parties, we shall use our best efforts to ensure that they keep your information secure, take all reasonable steps to protect it from misuse and only use it in a manner consistent with our instructions, this Privacy Notice and applicable data protection laws and regulations.
We may also share your personal information with companies, organisations or individuals outside of Younger Lives if we believe that disclosure of the information is necessary for legal reasons.
We may share your personal information to:
* Conduct investigations into possible breaches of applicable laws
* Detect, prevent and protect against fraud and any technical or security vulnerabilities
* Comply with applicable laws and regulations, co-operate in any legal investigation and meet enforceable governmental requests
We store your personal information on our servers within the UK. Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected.
Specifically, we use Google Drive to host all personal data collected. Google’s cloud services employ industry standard security including encryption in transmit and at rest and ISO/IEC27001/27017/27018/27701, SOC 1/2/3, PCI DSS, and FedRAMP certifications. For more information, please refer to: https://cloud.google.com/security/. It is important to note that personal data is encrypted between your device and any external host storage we use.
We also use Amazon Web Services, hosted in Ireland. You can find information on their hosting services here: https://docs.aws.amazon.com/security/
Specifically, we store data in dynamodb, and more information on this can be found here: https://docs.aws.amazon.com/amazondynamodb/latest/developerguide/security.html
If you have any questions, comments or concerns about how we handle your personal information, then see Your privacy rights and who to contact below.
Younger Lives does not sell personal information, except to an entity to which we divest all or a portion of our business (for example, in connection with a sale), or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or a portion of our business.
TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer your personal information to servers located outside the United Kingdom or the European Economic Area (EEA) so it can be stored or processed and enable us to provide our services to you. If we do store or transfer data outside the UK or the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK or the EEA. This means that sometimes we may need to use legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements. We will still be responsible for protection of your personal data, even where we have transferred it outside the UK or the EEA.
By using a Younger Lives Site or otherwise providing Younger Lives with personal information, you agree to us doing so in accordance with the terms of this Privacy Notice and applicable data protection laws and regulations.
SAFEGUARDING YOUR PERSONAL INFORMATION
We take all reasonable precautions to keep your personal information secure and require any third parties that handle or process your personal information for us to do the same. Access to your personal information is restricted to prevent unauthorised access, modification or misuse and is only permitted among our employees and agents on a need-to-know basis.
YOUR PRIVACY RIGHTS AND WHO TO CONTACT
If you have any questions, comments or concerns about how we handle your personal information, then you may contact us by emailing us at firstname.lastname@example.org. Your request will be directed to the appropriate person.
You have the right to tell us if you:
* Don't want to be contacted in the future by us
* Would like a copy of the personal information which we hold about you
* Would like us to correct, update or delete your personal information in our records
* Wish to report any misuse of your personal information
To assist us in dealing with your request, please provide your full name and details.
CHANGES TO OUR PRIVACY NOTICE
OTHER YOUNGER LIVES PRIVACY NOTICES
In addition to this Privacy Notice, there may be specific campaigns or promotions, which will be governed by additional privacy terms or policies. We encourage you to read these additional terms or policies before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or policies will be made prominently available to you.
Access to and use of this Younger Lives Sites is subject to the following terms and conditions and the laws of England and Wales.
Copyright © Younger Lives Limited. All rights reserved. All copyright and other intellectual property rights in all text, images, sound, software and other materials on this site are owned by Younger Lives Limited.
AVAILABILITY OF PRODUCTS
Reference to any product or service on the Younger Lives Sites do not necessarily constitute an offer to sell or supply that product or service and does not mean that the product or service is available in all countries or that the name, description or specification of the product or service will be the same as that included on the Younger Lives Sites. Specific advice concerning the availability and suitability of any particular product or service should be sought from the distributor concerned.
The information on the Younger Lives Sites has been included in good faith but is for general informational purposes only. It should not be relied on for any specific purpose and no representation or warranty is given as regards its accuracy or completeness. Neither Younger Lives nor any affiliates nor their or their affiliates' officers, employees or agents shall be liable for any loss, damage or expense arising out of any access to or use of the Younger Lives Sites or any site linked to it including, without limitation, any loss of profit, indirect, incidental or consequential loss.
All comments, suggestions, graphics, ideas (including product and advertising ideas), and other information or materials you submit to Younger Lives through the Younger Lives Sites will become and remain the exclusive property of Younger Lives, including any future rights associated with such submissions, even if these terms and conditions are later modified or terminated.
This means that you disclaim any proprietary rights in such submissions, and you acknowledge our unrestricted right to use them (or materials or ideas similar to them) in any medium, now and in the future, without notice, compensation or other obligation to you or any other person. It also means Younger Lives has no obligation to keep your submissions confidential.
We reserve the right to make any changes and corrections to the Younger Lives Sites as and when we consider it appropriate and without notice.
At various points throughout the Younger Lives Sites you may be offered automatic links to other internet sites relevant to a particular aspect of the Younger Lives Sites. This does not indicate that Younger Lives or affiliates are necessarily associated with any of these other sites or their owners.
Whilst it is the intention of Younger Lives that you should find these other sites of interest, neither Younger Lives nor affiliates, nor their or their affiliates' officers, employees and agents shall have any responsibility or liability of any nature whatsoever for these other sites or any information contained in them, none of which have been verified or endorsed by Younger Lives or affiliates.
If at any time you find that you have accessed another site you may return to this site by clicking on the "backwards" arrow, or by keying in the domain address of the relevant Younger Lives Sites.
The Younger Lives Sites are fully accessible for users without CSS. Where images are used to show relevant textual content, a text-based alternative is provided.