Salter Balance App Privacy Notice

Who We Are

Salter Balance mobile application is part of Ultimate Products UK Limited, which is a company under the group Ultimate Products PLC, ('we' or 'us' or 'our') and we gather and process your personal information in accordance with this privacy notice and in compliance with the relevant Data Protection law.

This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data with reference to this app. If you require wider information about how our business manages your personal data, please visit https://salter.com/privacy-policies/

Ultimate Products UK Limited’s registered office is at Manor Mill, Victoria Street, Manchester OL9 0DD and we are a company registered in England and Wales under company number 05432142. We are registered on the Information Commissioner's Office Register of Data Controllers under registration number ZA269152, and act as the data controller.

Our designated contact for data protection is our Compliance Department, and contact details are available at the foot of this notice.

If you have any concerns or outstanding questions after reviewing this statement, then we encourage you to contact us by:

Data Protection Principles

We will comply with UK GDPR. This says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

Information That We Collect

We process your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than specified in this notice. We may update this notice from time to time and the date it was last updated appears at the top of the page.

The personal data that we collect is:

• Username
• Email
• Date of birth
• Sex
• Connected app usernames (i.e. Apple health/Google fit)
• Profile Picture (optional)

Special Category Data (data related to Health):

• Height
• Pregnancy Status (if appropriate)
• Weight
• Blood Pressure
• Heart Rate
• Body Measurements (such as waist, chest, hip, thigh, calf, neck and upper arm)
• Scales Calculated health metrics (such as body water %, body fat %, Muscle Mass %, Bone Mass %, Body Mass Index (BMI), Basal Metabolic Rate (BMR), Relative Fat Mass (RFM), Lean Body Mass (LBM))

The app stores user data securely on EU Amazon servers rather than on your device. This ensures that when you log in with the same account on a new mobile phone, previously collected data will remain accessible through your account history. The app does not include any functionality for users to connect or communicate with one another, such as group or contact features.

We do not collect any data from public sources.

Children’s Data

We understand that children may use our products and services. However, children under the age of 13 are not allowed to register for the app unless they have obtained parental consent. Parents should register and manage their child’s account for them.

Parents who believe that their child has submitted their information to us without parental consent should contact us to have it deleted or to revoke parental consent at any time. We will action any requests for deletion within 30 days.

How We Collect Information

We collect information in the below ways:

• When you enter information as part of the product registration process
• When you use our connected products that send information to the mobile app
• When you connect to a device (i.e. scales)
• When you contact us
• Information received from any third-party apps, such as Apple Health or Google Fit, that you choose to link with the mobile app

How We Use Your Personal Data (Legal Basis for Processing)

We take your privacy very seriously and will never disclose, share or sell your data without your consent, unless required to do so by law or detailed herein as part a requirement to provide the services you have requested. We only retain your data for as long as is necessary and for the purposes specified in this notice.

Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw consent at any time.

• If you have chosen to allow us to use your email address or mobile phone number for marketing purposes, we rely on consent for this purpose.
• We use your information collected as part of the registration process to provide you with our services and for our legitimate interests to ensure that our services are secure, suitable and accurate. The information you provide us with allows you to maintain a profile on our mobile app. The information also allows us to continue to develop and improve our services and to communicate with you.
• Any special category data as detailed above is collected, and used, with your explicit consent prior to being collected. We will request your explicit consent via the app at the point that you link a device with the app. Special category data is collected to allow you to link a product with your account, record your results and view graphs, graphics and tables to help you to interpret your results and track your goals.

You are free to withdraw your consent at any time by contacting us. Please note that the device will no longer collect special category data and functionality will be limited.

Your Rights

You have the right to access any personal information that we process about you and to request information about:

• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to update/correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You may have the right to request erasure of your personal data or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use. Please note, we do not process your data using automated decisions for marketing purposes.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the relevant request; this is to ensure that your data is protected and kept secure. Any such requests will be responded to within one month, but if a request is particularly complex, we may need more time and will notify you of this if relevant.

Sharing and Disclosing Your Personal Information

We do not share or disclosure any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. We do not transfer your personal information outside of the UK or the European Economic Area.

We use third parties to provide the services and business functions below, however all processors acting on our behalf only process your data in accordance with contractually agreed instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.

We use partners to provide the following services:

• Undertake legally required accountancy services
• Developing the mobile app
• Hosting services
• Legal Services

Your personal information may also be shared:

• If we are required to do so by law or to comply with any applicable rules or regulations, or in response to a legitimate request from a law enforcement authority or other government official.
• If we sell or transfer all or a portion of our business or assets, in accordance with applicable law. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use data you have provided to us in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your data with any inquiries concerning the processing of that data.
• With our advisors and insurers require the personal information due to a claim, dispute or where otherwise necessary.
• With Ultimate Products PLC or any subsidiaries.

Social Media

We also use various social media channels to provide support and answers any questions you might have. We never add anyone’s personal data into any social media channel or use their audience or category advertising features; however, we act as joint controllers as they determine how your data is managed.

We also sometimes run competitions on these social media channels; however, we never take your personal data from these companies, except to send you prizes.

We advise you to consult the privacy policies of any external companies that may have access to your personal information. Doing so will help you understand how these organisations manage, process, and safeguard your data.

To find these privacy policies, please visit the websites of the relevant companies. There you will find comprehensive information about their data practices and details about your rights under their policies.

Safeguarding Measures

We take your privacy seriously and we take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:

• Firewall
• Encryption
• Strict Access Controls (physical and electronic)
• SSL certificates
• Full Privacy Governance structure

Consequences of Not Providing Your Data

You are not obligated to provide your personal information to us, however, as this information may be required for us to provide you with our services, this app will not work without it and the functionality of any connected devices such as smart scales may be limited.

How Long We Keep Your Data

We only ever retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations.

• We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
• Where you have consented to us using your details for direct marketing, we regularly review consent given and will keep such data until you notify us otherwise and/or withdraw your consent.
• If you delete your account, we will permanently delete it along with your personal information after 7 days. If you wish to recover your account, you can log into your account within this 7-day period. If you do not log in within this time, your account will be permanently deleted.
• Further to this, after a 12-month period of inactivity, we will contact you to query whether you would like to keep your account active. If you do not wish to keep your account active or if we do not receive a response in a reasonable timeframe, your account will be permanently deleted.

Lodging A Complaint

We only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority. We would be grateful if you would give us the opportunity to deal with any complaints in the first instance.

UK Data Protection Authority:

Contact Details

Notification of Changes to this Notice

If we decide to change our Privacy Notice, we will post these changes on this website so that you know exactly what information we collect and how we use it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will tell you and you will have a choice as to whether or not we use your information in this different manner.

Feedback

We want to make sure that we’re giving you the information that you want about privacy and security – let us know what you think. If you have any feedback, questions or concerns, please email us at data-protection@upplc.com or by post to the address above.

Links

Our website may contain links to let you visit other websites of interest with ease. Once you have used these links to leave our website, you should be aware that we do not have any control over that other website. As such, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting these websites, and they are not governed by this Privacy Notice.

We are not responsible for any products and/or services featured on any third-party websites; you should exercise caution and look at the Privacy Notice applicable to the website in question.

Ultimate Products UK Limited is a company under the group Ultimate Products PLC.