TrackTogether Ltd (referred to as we, us, our etc. in this policy) is committed to protecting your personal data and respecting your privacy.
Introduction
This policy applies to your use of our website (the Site).
This policy sets out the basis on which any personal data we collect (or that you provide to us) will be processed by us.
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.
This policy is provided in a layered format so you can click through to the specific areas set out below.
The Data We Collect About You
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Age;
- Location Data;
- Symptom Data; and
- Unique ID
We explain these here.
As discussed below – where you have given us consent to do so – we may also create, use and share aggregated data (such as statistical or demographic data) for various purposes. In this case, the aggregated data will 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. For example, we may aggregate your personal data with the personal data of other users in order to calculate the proportion of users in specific areas of the country who likely have contracted COVID-19.
We do not collect any information about criminal convictions and offences.
How is Your Personal Data Collected?
We will collect and process the following data about you:
- Information you give us. This is:
- This is Age, Location Data and Symptom Data that you provide to us by filling in forms on the Site;
- Information we generate. This is the Unique ID, which we randomly generate in order to distinguish you and the device on which you access the Site (Device) from other users of the Site and of our app and which enables us to keep track of what information is provided by different users (i.e. to distinguish you from other users). We store a copy of the Unique ID on your Device and it will not expire until you clear your browser’s cookies.
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 takes place.
Click here. to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
| Purpose |
Type of data |
Lawful basis for processing |
| Creation of aggregated data |
- Age
- Location Data
- Symptom Data
|
Your consent |
| Sharing data with research institutions |
- Age
- Location Data
- Symptom Data
- Unique ID
|
Your consent |
Disclosures Of Your Personal Data
When you provide data to us via the Site, we will also ask you for your consent to share your personal data (as set out above) with the following research institutions:
- NHS England of Skipton House, 80 London Road, London, SE1 6LH, United Kingdom (the NHS);
- the Trustees of Columbia University in the City of New York (US institutional profile no. 1833202) of 110 Low Memorial Library, New York, NY 10027, United States of America (Columbia University).
Each of these institutions is a separate controller and has its own privacy policy setting out how they will use the personal data that we share with them.Links to their privacy policies are:
International Transfers
Some of the third parties with whom we share your data are based outside the EEA and – in this case – their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- the transfer of your personal data is to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy Decisions;
- we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Standard Contractual Clauses;
- where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US data transfers.
For each third party outside of the EEA, in the Glossary, we have provided details of the specific mechanism used by us when transferring your personal data out of the EEA.
Data Security
All of the information that you provide to us (or that we collect) is stored on our secure servers.
Once we have received your personal data, we will use strict procedures and industry-leading security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
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
Every six months, we assess whether your personal data (along with other individuals’ personal data) is of value to any current research conducted by the institutions with whom we share it (see Third Parties below). In the event that we decide that this is not the case, we will promptly erase your personal data.
In some circumstances, you can ask us to delete your personal data. See your legal rights [Insert as link.] below for further information about this.
As discussed above, in certain circumstances, we may create aggregated data using your personal data. We may use this aggregated data indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- 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 of your personal data
- right to withdraw consent
You can exercise any of these rights at any time by contacting us using the details provided above.
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. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by:
- 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. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Performance of contract means processing your personal 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
- Amazon Web Services EMEA SARL (incorporated and registered in Luxembourg under company no. B186284) of 38 avenue John F. Kennedy, L-1855 Luxembourg (AWS), which (acting as a processor) provides web hosting and other IT services. Although AWS is incorporated and registered in Luxembourg, the servers that we use are located in the United Kingdom.
- Nikita Chubatyuk (acting as a controller), our data protection officer, located in the United Kingdom.
- Research institutions (acting as controllers):
Your legal rights
You have the right to:
- request access to your personal data (commonly known as a ‘data subject access request’). 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 the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where
- you have successfully exercised your right to object to processing (see below);
- we may have processed your personal data unlawfully; or
- we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you (if applicable) at the time of your request;
N.B. You can request the erasure of your personal data at any time by contacting us.
- object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms;
- request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it;
- request the transfer of your personal data to you or to a third party. We will provide to you (or a third party you have chosen) your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
- withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
You can withdraw your consent at any time by:
Description of types/categories of personal data
- Age: your age.
- Location Data: your postcode and your GPS location history.
- Symptom Data: information about your COVID-19 symptoms (or lack of symptoms).
- Unique ID: an alphanumeric code, unique to your Device.
