Privacy Policy

Last updated September 2021

1. INTRODUCTION 

1.1 Important information and who we are 

Welcome to Simplify Operations Ltd’s Privacy and Data Protection Policy (“Privacy Policy”). 

Simplify Operations Ltd is a company registered in England and Wales with registered company number 13288825 and trading as "Habitude".

At Simplify Operations Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting  your privacy and Personal Data in compliance with the United Kingdom General Data  Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and  regulations of the United Kingdom. 

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you. 

The individuals from which we may gather and use data can include: 

Customers 

Business contacts 

Third parties connected to your customers 

and any other people that the organisation has a relationship with or may need to contact. 

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Who is Your Data Controller and Data Protection Officer 

Simplify Operations Ltd is your Data Controller and responsible for your Personal Data. 

We have appointed a data protection officer (“DPO”) who is responsible for overseeing  questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy,  including any requests to exercise your legal rights surrounding your Personal Data please  contact the DPO using the details set out below: 

Full name: Isolde Dorrian 

Email address: izzi@habitude.co 

Postal address: 23 Elmsdale Road, London, E17 6PN, United Kingdom 

You have the right to make a complaint at any time to the Information Commissioner’s Office  (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,  however, appreciate the chance to deal with your concerns before you approach the ICO so  please contact us in the first instance.

2. LEGAL BASIS FOR DATA COLLECTION 

2.1 Types of Data / Privacy Policy Scope 

Personal Data” means any information about an individual from which that person can be  identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store and transfer different kinds of Personal Data about you which we  have grouped together below. Not all of the following types of data will necessarily be  collected from you but this is the full scope of data that we collect and when we collect it from  you: 

Profile/Identity Data: This is data relating to your first name, last name, gender, date of  birth. 

Contact Data: This is data relating to your phone number, addresses, email addresses,  phone numbers. 

Marketing and Communications Data: This is your preferences in receiving marketing  information and other information from us. 

Financial Data: These are your banking details e.g. your account number and sort code. 

Transactional Data: This is information of details and records of all payments you have  made for our services or products. 

Workplace: Where the individual works 

Job Role: The role they undertake at their workplace 

We also collect use and share  Aggregated Data such as how often users complete their onboarding processes. 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. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy. 

We may also aggregate data to enable research or analysis so that we can better understand  and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not  identify you personally. We may share this type of anonymous data with others, including  service providers, our affiliates, agents and current and prospective business partners. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

2.2 The Legal Basis for Collecting That Data 

There are a number of justifiable reasons under the GDPR that allow collection and processing  of Personal Data. The main avenues we rely on are: 

Consent”: Certain situations allow us to collect your Personal Data, such as when you  tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to  a service. 

Contractual Obligations”: We may require certain information from you in order to  fulfil our contractual obligations and provide you with the promised service. 

Legal Compliance”: We’re required by law to collect and process certain types of data,  such as fraudulent activity or other illegal actions. 

Legitimate Interest”: We might need to collect certain information from you to be able  to meet our legitimate interests - this covers aspects that can be reasonably expected as  part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to  deliver something to, or your name, so that we have a record of who to contact moving  forwards. 

3. HOW WE USE YOUR PERSONAL DATA 

3.1 Our Uses 

We will only use your Personal Data when the law allows us to. Set out below is a table  containing the different types of Personal Data we collect and the lawful basis for processing  that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below. 

Examples provided in the list below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Data Protection Officer. 

a. When a profile is created for a customer

Type of data: Profile /Identity Data

Legal justification: Contractual Obligations

Lawful basis for processing data: Setting up profiles for users is a necessary part of
the functionality of the Habitude product which will have been purchased by their
employer organisations

b. When a profile is created for a customer

Type of data: Contact Data

Legal justification: Contractual Obligations

Lawful basis for processing data: Setting up profiles for users including email addresses is a necessary part of the functionality of the Habitude product which will have been purchased by their employer organisations

c. When creating habits e.g. Checklist function where certain documents are pushed out to staff members of a customer organisations via the platform for them to access and read

Type of data: Profile/ Identity Data

Legal justification: Contractual Obligations

Lawful basis for processing data: Being able to send information to customer's staff is
a key part of the function of the platform

d. When creating habits e.g. Checklist function where certain documents are pushed out to staff members of a customer organisations via the platform for them to access and read

Type of data: Contact Data

Legal justification: Contractual Obligations

Lawful basis for processing data: Being able to send information to customer's staff is a key part of the function of the platform

e. When a user requests and attending a live demo of our products/services or inquires into our services through a call with members of our sales/support team

Type of data: Profile/ Identity Data

Legal justification: Consent

Lawful basis for processing data: Certain company information will be taken at this time,
including names of staff members and users.

f. To administer and protect our business (the Site and Platform) including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

Type of data: Technical Data

Legal justification: Legitimate Interest

Lawful basis for processing data: For running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise

g. To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data: Usage Data

Legal justification: Legitimate Interest

Lawful basis for processing data: To define types of customers for our products and services, to keep our Site and Platform updated and relevant, to develop our business and to inform users about marketing strategy

4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US 

4.1 What Control Do I Have Over Simplify Operations Ltd’s Use Of My Personal Data?

Your account information will be protected by a password for your privacy and security.

You will need to contact us if you would like to delete your account. 

4.2 Opting Out Of Marketing Promotions 

You can ask us to stop  sending you marketing messages at any time by clicking 'Unsubscribe' in any emails sent or by emailing hello@habitude.co. 

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing  preferences. 

4.3 How to Request your Data and the Process for Obtaining it 

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request. 

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in  relation to your request to speed up our response. 

5. YOUR DATA AND THIRD PARTIES 

5.1 Will We Share Your Data With Third Parties? 

We may also share Personal Data with interested parties in the event that Simplify Operations Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology. 

If Simplify Operations Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that  transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in  accordance with this Privacy Policy (as amended from time to time). 

We may share your Personal Data at any time if required for legal reasons or in order to  enforce our terms or this Privacy Policy.

We may also share Personal Data with service providers providing IT services and data storage services as well.

6. HOW LONG WILL WE RETAIN YOUR DATA FOR? 

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a  complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

7. AGE LIMIT FOR OUR USERS 

You must not use Simplify Operations Ltd unless you are aged 16 or older. If you are under 16 and you access Simplify Operations Ltd by lying about your age, you must immediately stop using Simplify Operations Ltd. 

This website is not intended for children and we do not knowingly collect data relating to children.

8. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY 

We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 21 September 2021. Continued access or use of Simplify Operations Ltd will constitute your express acceptance of any modifications to this Privacy Policy.

9. INTERPRETATION 

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set  out in this policy may be used solely for the purpose for which they are stated to be provided, and  any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the  right to not respond to emails, even if they relate to a legitimate subject matter for which we have  provided an email address. As a matter of common sense, you are more likely to get a reply if your  request or question is polite, reasonable and there is no relatively obvious other way to deal with or  answer your concern or question (e.g. FAQs, other areas of our website etc.). 

Our staff are not authorised to contract on behalf of Simplify Operations Ltd, waive rights or make  representations (whether contractual or otherwise). If anything contained in an email from a Simplify  Operations Ltd address contradicts anything in this policy, our terms or any official public  announcement on our website, or is inconsistent with or amounts to a waiver of any Simplify Operations Ltd rights, the email content will be read down to grant precedence to the latter. The only  exception to this is genuine correspondence expressed to be from the Simplify Operations Ltd legal  department.