Privacy Policy
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Activaite Limited (we, us), the publishers of Smorg (this app) value your privacy. The personal data you provide through this app will be held and used by us in accordance with this privacy policy (the Privacy Policy).
For the purposes of the General Data Protection Regulation (the GDPR), we are the controller of the personal data you provide. Full details of our company appear at the end of this Privacy Policy. Under the GDPR and related laws, we have a legal duty to tell you about how we process the personal data we collect from you, and to give it suitable protection.
As a controller we have registered with the Information Commissioner’s Office (the ICO) in the UK and our registration number is A8722431.
1. Personal data we may collect from you, and how we collect it
We may collect personal data from you through a variety of means, as described below (or end of page if not displayed):
If you decide not to give us your personal data when requested, we may not be able to provide you with the service you require.
2. How we use your personal data
We may use personal data we hold about you in one or more of the following ways (or see end of page if not displayed):
If we ask you or invite you to provide any special category personal data to us for any reason, for example allergies or other health based dietary requirements, we will process it on the basis of your consent. If we process your special category personal data, or any other personal data on the basis of consent, you can withdraw that consent at any time by emailing us at help@smorg.io.
An important part of the service we provide to you is our ability to recommend meal plans that suit you. We may use information you provide to us about your health and dietary requirements, or the preferences you show through the use of the app to recommend meal plans that match these requirements. These suggestions are aimed at helping you choose appropriate meal plans. The information that is collected to generate meal plans suggestions is not used for any other purposes.
3. How we share your personal data
We use other businesses to provide certain services to us, or to you on our behalf, such as reporting on the use of the app, the processing of credit card payments and the administration of the meal planning function of the app. These service providers will have access to your personal data, but only to the extent necessary to provide their services. We do not permit these service providers to make any use of any personal data they process except to provide their services, and they will not contact you unless we give them express permission to do so for the purposes of providing the services.
If you have given your consent to such sharing as part of the registration process or subsequently, we will share your personal data with the applicable group companies and/or third parties and (unless you give them further consent) they can only use it to send you the information that you have requested. Their use of your personal data will be otherwise subject to their own privacy policies. We are not responsible for the privacy policies or practices of any third party. You can stop receiving this information at any time by following the unsubscribe instructions on the emails that you receive, by amending your marketing preferences or by emailing help@smorg.io.
We may share aggregated data, through which you may not be personally identifiable, such as demographics and app usage statistics, with advertisers, sponsors and other organisations.
We do not currently transmit personal data outside the European Economic Area.
4. Retention and deletion of your personal data
We will not keep your personal data for any longer than required for the purposes for which it is collected, unless there is a legal obligation on us to keep it for a longer period.
When it is no longer required your personal data will be deleted.
We will retain your personal data for the following purposes and retention periods (or see end of page if not displayed below).
5. Your rights
You have the following rights under data protection legislation. If you have any questions about your rights, or you wish to exercise any of these rights, please email help@smorg.io.
Access: You have the right to access and receive a copy of the personal data we hold about you, including the details and purposes of the processing, the organisations to which your personal data is disclosed, and other information that we are obliged to give you about our processing. If you wish to access any of your personal data please contact us giving details of the information you require.
Accuracy: We have an obligation to keep the personal data we hold about you accurate and up to date, and you have the right to ensure that we do. Please notify us as soon as possible in the event of any change to your personal data.
Erasure: You have the right to ask that we erase your personal data (the ‘right to be forgotten’) in certain limited circumstances. We will let you know if any of those circumstances apply on request.
Restriction on processing: You have the right to restrict us from processing your personal information in certain limited circumstances. We will let you know if any of those circumstances apply on request.
Portability: You may have the right to require us to transfer the personal data we hold about you to a third party in machine-readable format. Please contact us to find out whether your right applies.
Right to object: If at any point we process your personal data on the basis of our legitimate interests, or on the basis that it is in the public interest to do so, you have the right to object to that processing. In any event, you have the absolute right to request that we do not use your personal data for any direct marketing purposes.
Automated decision-making: Finally, you have the right not to be subject to a decision based solely on automated decision-making that has significant prejudicial effect on you.
If you contact us by telephone, email or by any other remote means we may require proof of ID before acting.
If you contact us to exercise your rights we will respond as required under data protection legislation, but please note that not all rights are absolute. Sometimes they may not apply, or other legal obligations or third party rights will take precedence.
You can find out more about your rights on the ICO’s website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You have a right to raise a complaint with your national data protection supervisory authority. If you want to raise a complaint with the ICO, you can use the information provided at https://ico.org.uk/make-a-complaint/.
6. Use of cookies and similar technologies
We use cookies and similar technologies, including tokens on this app. A “cookie” is a small file of text which is downloaded onto your device when you access this app, and it allows us to recognise as a user, or returning user, of our app.
We will obtain your consent to use these tools except where the use of the tool is strictly necessary for the operation of our app.
The tools used on our app are either set by us or by our third party service providers, and fall into the following categories:
Necessary: Those that are necessary for the operation of the app, including allowing you to interact with our app and to recall selections as you move between pages and which enable core functionality such as security, credentials authentication, network management and accessibility.
Functional: Those that are used to provide services or to remember choices you make so we can personalise our content for you. We use this information to customise your experience of our app to meet your preferences e.g. to allow you to view meal plans that follow your preferences etc.
Analytics: Those that analyse the use of our app e.g. interface use, service monitoring and populating certain content on our app in line with usage.
We use a combination of tools that allow us to track current visit, how you navigate the app and enable our app to recognise you as a repeat visitor when you return.
7. A note for parents
We do not currently knowingly collect any personal data from children under the age of thirteen. The Internet offers children wonderful educational and entertainment resources.
The guidance and involvement of parents and guardians is essential to help ensure that children have a safe and rewarding online experience. We encourage you to visit https://www.google.com/safetycenter/ and the GetNetWise website to learn more about parental control tools.
8. Security
We take all reasonable steps to help prevent the loss or corruption of, or unauthorised access to, the information that you provide to us. Nonetheless, the transmission of data via the internet is not completely secure. We therefore cannot guarantee the security of the information you transmit to our app in the course of transmission. Any transmission of your information is therefore done at your own risk.
9. Notification of changes
We reserve the right to change or update this Privacy Policy at any time. Any changes will be effective when they are posted on this app. We will endeavour to notify you of any significant changes, such as those required by a change in the law. Please in any event review this Privacy Policy from time to time to make sure you’re aware of our current practices. Continued use of this app following the posting of changes will amount to acceptance of the revised Privacy Policy.
If you have any questions or complaints, or you wish to exercise any of your rights, please contact us at help@smorg.io.
Smorg and this app are owned by:
Activaite Ltd,
1st Floor WeWork Labs,
70 Wilson St,
EC2A 2DB
Activaite Ltd is registered in England & Wales with company number 9522467