Privacy Policy

Updated 13th August 2019

Your privacy is important to Ki Performance Lifestyle Ltd (Ki). We developed this Privacy Policy to provide you with information on how we process your personal data when using the KiActiv® websites and the KiActiv® Digital Behaviour Change Platform (including the web app, mobile apps and connected devices).

Other KiActiv® websites, apps and products that do not include a link to this Privacy Policy and include a link to a different KiActiv® privacy policy are governed by that privacy policy.

“Personal Data”: any information relating to an identifiable person who can be directly or indirectly identified.

“Sensitive Personal Data”: special categories of “Personal Data”, such as ethnicity and health data.

To jump to a specific section of this Privacy Policy, please click on a link below:

Categories of Personal Data Processed by KiActiv®

Personal data that is processed when you create a KiActiv® account:

When you create a KiActiv® account, we ask you to provide your email address and name. You can choose to provide a nickname instead of your full name if you wish.

PURPOSES AND LEGAL GROUNDS:

  1. Ki processes your email address because you use your email address and your password to sign in to your account. The legal ground for processing your email address for this purpose is based on Ki’s legitimate interest in protecting the security of your account.
  2. Ki also processes your email address for the purpose of sending you information about your KiActiv® products, apps or account, such as important safety information or material changes to this Privacy Policy. The name you provide is associated with your account profile and is displayed to your KiActiv® Mentor when they view your account information to deliver your personal, one-to-one sessions during your KiActiv® programme. The legal ground for processing your email address and name for these purposes is Ki’s legitimate interest in providing you important safety, research or other information about your KiActiv® products, apps, account, or material changes to this Privacy Policy, and in providing you a personalised service.
  3. If you provide your opt-in consent to receiving marketing information from Ki, Ki will also process your email address for the purpose of sending you marketing information about KiActiv® products and apps. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your KiActiv® account or through the unsubscribe link at the bottom of our marketing emails.
  4. Ki also processes your email address to associate it with your KiActiv® account when you interact with our customer support representatives. The legal ground for this processing is our legitimate interest in providing quality customer support.

Additional personal data that is processed if you choose to provide it when you create a KiActiv® account:

You can add additional information to your profile, such as your gender, date of birth, height, weight, handedness, normal bed and wake time, smoking status, telephone number, and postcode.

PURPOSES AND LEGAL GROUNDS:

This information is used to calculate the calories you burn during your everyday activities, to enable us to evaluate your everyday physical activity in the context of health and to provide you with personalised feedback. The legal ground for processing this information for these purposes is your consent. You can withdraw your consent at any time within your KiActiv® account.

Sensitive personal data that is processed if you choose to provide it when you create a KiActiv® account:

You can add additional information to your profile, such as race or ethnicity, and data relating to mental and physical health status.

PURPOSES AND LEGAL GROUNDS:

This information is used to calculate the calories you burn during your everyday activities, to enable us to evaluate your everyday physical activity in the context of health and to provide you with personalised feedback. The legal ground for processing this information for these purposes is your explicit consent. You can withdraw your consent at any time within your KiActiv® account.

Personal data that is processed when you choose to upload your activity data to KiActiv®:

You can choose to upload your activity data from your Band to your KiActiv® account. If you choose to upload your activity data to KiActiv®, you can control who sees this data. By default this will be viewable by your KiActiv® Mentor. Your activity data cannot be viewed by other KiActiv® users.

PURPOSES AND LEGAL GROUNDS:

  1. Ki processes your activity data, if you choose to upload it to KiActiv®, to enable you to see your everyday physical activity in the context of health, interact with your data (e.g. tag and plan), track your physical activity behaviour change, and, if you wish, share your activity data with others. The legal ground for this processing is your explicit consent, which you can withdraw at any time within your KiActiv® account.
  2. If you choose to participate in a KiActiv® programme and you choose to upload physical activity data from your compatible device to your KiActiv® account, then you will be provided with personalised support and guidance from an accredited KiActiv® Mentor. Your KiActiv® Mentor will view your account information to deliver your personal, one-to-one sessions during your KiActiv® programme. The legal ground for processing this data for this purpose is your explicit consent, which you can withdraw at any time within your KiActiv® account.

Personal data that is processed when you choose to tag your personal everyday physical activities in KiActiv®:

You can choose to tag your personal everyday physical activities in your KiActiv® account. If you choose to do this, you can control who sees this data. By default this will be viewable by your KiActiv® Mentor. Your activity data cannot be viewed by other KiActiv® users.

PURPOSES AND LEGAL GROUNDS:

Ki processes your personal everyday physical activities to provide you with enhanced insights into how your behaviours impact your health profile and to enable you to plan to optimise your physical activity using your own behaviours. The legal ground for this processing is your explicit consent, which you can withdraw at any time within your KiActiv® account.

Personal data that is processed when you sync your compatible device:

When you sync your device through the KiActiv® app, we log data about the transmission, such as the IP address used when syncing, the sync time and date, crash/diagnostic logs, information about your device, information about the network used to sync (e.g., WiFi or mobile) and device battery level.

PURPOSE AND LEGAL GROUNDS:

Ki process this information to help identify and resolve errors or syncing issues. The legal ground for processing this information for this purpose is Ki’s legitimate interest in resolving errors or syncing issues and providing quality product support.

Personal data that is processed when you communicate with Ki:

When you interact with our customer support or KiActiv® Mentors via email, telephone, or in person, we may collect personal data, such as your name, postal address, phone number, email address, and contact preferences; and information about the KiActiv® products you are using, such as the device size and type, the KiActiv® programme you are enrolled on and the name of your KiActiv® Mentor. We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue. To improve quality assurance we may also record and review conversations with customer support and KiActiv® Mentors, and analyse any feedback provided to us through this or voluntary customer surveys. With your consent, our customer support may sign in to your KiActiv® account, if appropriate, to help troubleshoot and resolve your issue.

PURPOSE AND LEGAL GROUNDS:

We use this information to provide you with customer and product support and to monitor the quality and types of customer and product support we provide to our customers. The legal ground for processing this information for these purposes is Ki’s legitimate interests in providing quality product support. The legal ground for signing in to your KiActiv® account, if appropriate, to help troubleshoot and resolve your issue is consent, which you may withdraw.

Categories of Recipients of Personal Data

KiActiv® Mentor:

You may be receiving the KiActiv® Digital Behaviour Change Programme from one of our partner organisations that you have a relationship with. In this instance your KiActiv® Mentor will be provided with access to your Personal Data in order to provide you with effective, empathetic and personalised support. This access remains subject to technical and organisational security measures.

Healthcare providers; other third parties:

From time to time, we share physical activity data in a de-identified and aggregated manner with agencies that provide healthcare services to you for the purpose of improving the quality of the service they provide, and with other third parties for scientific research, statistical or other purposes.

Other disclosures:

We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.

We may also transfer your personal data to an affiliate, a subsidiary or third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Ki’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that we transfer personal data to will not be permitted to process your personal data other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent.

Cookies and Similar technologies

KiActiv® Web Platform:

To help analyse how you and other visitors navigate the KiActiv® web platform, compile aggregate statistics about site usage and response rates, help diagnose any problems with Ki’s servers and administer the KiActiv® web platform, we, with assistance from third-party analytics service providers, collect certain information when you visit our site. This information includes IP address, browser type, browser language, date and time of your request, time(s) of your visit(s), page views and page elements (e.g., the activities you tag) that you click. We may use cookies or other similar tools on our site to assist us in collecting and analysing such information. We use this information to provide better, more relevant content on our site, to identify and fix problems, and to improve your overall experience on our site.

We are required to obtain your consent to use cookies on our sites, and as such you will have an opportunity to manage your cookie preferences on the sites; except that certain cookies are required to enable core site functionality, and you cannot choose to disable those cookies.

KiActiv® app:

We also collect data from users about their usage of the KiActiv® app. The types of analytical information that are collected include the date and time the app accesses our servers, app version, language setting, what information and files have been downloaded using the app, device information (e.g., serial number), hardware and operating system information, and information relating to how the app functions. Ki uses this data to improve the quality and functionality of the KiActiv® app; to develop and market products and other usability problems as quickly as possible.

The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our products, apps and websites so we can enhance the user experience and functionality of our products, apps and websites.

Here are examples of third-party providers of analytics and similar services we currently use:

ANALYTICS SERVICES:

  • Google: Google Analytics is used to track site statistics, user demographics, and behaviour on KiActiv®
  • Crashlytics (Fabric): Crashlytics is used to help us better understand usage of the KiActiv® app to improve user experience and to identify and resolve the root cause of app crashes.
  • Loggly: Loggly is used to help us better understand the behaviour of the KiActiv® app by analysing log files. This enables us to identify and troubleshoot issues.

Children

We request individuals under 12 not provide personal data to Ki Performance Lifestyle Ltd. without explicit consent from their parent or legal guardian. If we learn that we have collected the personal data from a child under 12 without explicit consent from their parent or legal guardian, we will take steps to delete the information as soon as possible.

Where an individual is under 12 and explicit consent is provided, this Privacy Policy applies to the individual’s personal data.

Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new products and apps, as we improve our current offerings and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last updated” legend at the top of this page. Any changes will become effective upon our posting of the revised Privacy Policy.

We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the KiActiv® websites and apps that link to this Privacy Policy.

Retention of Personal Data

We will retain your personal data as long as your KiActiv® account is considered to be active. In addition, see below under “Your Rights” for a description of your right of erasure.

Data Controller and Data Protection Officer

Ki Performance Lifestyle Ltd. is the data controller for KiActiv®, and is located at 58 Queen Anne Street, London, W1G 8HW, United Kingdom. The Data Protection Champion is Tommy Parker, located at the same address and can also be reached by email at privacy@kiactiv.com.

Your Rights

You have the right under the General Data Protection Regulation to request from Ki access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority.

If you wish to exercise any of your rights, or would like further information on our Data Security and Protection policies, please contact Ki’s Data Protection Champion by email at privacy@kiactiv.com.