Privacy Policy

This privacy policy applies between you, the User of this Website and/or the App and Actegy Limited, the owner and provider of this Website and the App. Actegy Limited takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website and/or the App.

This privacy policy should be read alongside, and in addition to, our Licence Agreement Terms and Conditions, which can be found in the settings menu of the App.

Please read this privacy policy carefully. By agreeing to it, you consent to us collecting and processing your Data. If you change your mind you can withdraw your consent by contacting us at data.lead@actegy.com but that will not affect the lawfulness of any processing carried out before you withdrew your consent.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

2. In this privacy policy, unless the context requires a different interpretation:
   1. the singular includes the plural and vice versa;
   2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
   3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
   4. "including" is understood to mean "including without limitation";
   5. reference to any statutory provision includes any modification or amendment of it;
   6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of Actegy Limited and Users with respect to this Website or the App. It does not extend to any third-party websites that can be accessed from this Website or from the App including, but not limited to, any links we may provide to social media websites.
4. For purposes of the applicable Data Protection Laws, Actegy Limited is the "data controller". This means that Actegy Limited determines the purposes for which, and the manner in which, your Data is processed. The App is not intended to be used by any person under the age of 18.

Data collected

5. If you are using the App, we may collect the following Data (duly anonymised), which includes personal Data, from you:
   1. first name;
   2. year of birth;
   3. gender;
   4. height;
   5. weight;
   6. Heath symptoms and Conditions;
   7. Revitive usage data;
   8. contact information such as email addresses;
   9. IP address (automatically collected);
   10. mobile device information
   11. information related to the usage of the Revitive products;
   12. information relating to your medical conditions and symptoms associated with these;
   13. information related to the operating system (e.g Android or iOS)
   14. location data upon creating your App account, however we will not track your location thereafter.
6. If you are using the Website, we may collect the following Data, which includes personal Data, from you:
   1. first name;
   2. contact information such as email addresses;
   3. IP address (automatically collected);
   4. web browser type and version (automatically collected);
   5. operating system (automatically collected);
   6. For both App and Website, information we receive from other sources including third parties and publicly available sources, as set out below:
      • Device Data from the following parties:
        • analytics providers such as Google based outside the EU;

in each case, in accordance with this privacy policy

How we collect Data

7. We collect Data in the following ways:
   1. data is given to us by you, for example through your use of the Website or the App, or by corresponding with us; and
   2. data is collected automatically.

Data that is given to us by you

8. Actegy Limited will collect your Data in a number of ways, for example:
   1. when you contact us through the Website or App, or by telephone, post, e-mail or through any other means;
   2. when you register with us and set up an account to receive our products/services;
   3. when you make payments to us, through the Website or otherwise;
   4. when you elect to receive marketing communications from us;
   5. when you use the App with a Revitive.

in each case, in accordance with this privacy policy.

Data that is collected automatically

9. To the extent that you access the Website and on account creation for and usage of the App, we will collect your Data automatically, for example:
   1. we automatically collect some information about your visit to the Website or use of the App. This information helps us to make improvements to Website and App content and navigation and in the case of the App, to provide you with a record of your Revitive usage and achievements. The information we collect includes your IP address, the date, times and frequency with which you access the Website or App and the way you use and interact with its content.
   2. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".
   3. information about your installation and device, for example, your unique application number and the type of operating system, may be sent to us.

Our use of Data

10. Any or all of the above Data may be required by us in order to provide you with the best possible service and experience when using our Website or App. Specifically, Data may be used by us for the following reasons:
    1. internal record keeping;
    2. improvement of our products/services;
    3. provide the User of the App with guidance on the best use of Revitive ;
    4. provide the User of the App with a record of their usage of Revitive ;
    5. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website or App;
    6. to manage our relationship with you including notifying you of changes to the Website, App or any App services;
    7. register you as a new App user;
    8. to process in-App purchases;
    9. to administer and protect our business and this App including troubleshooting, data analysis and system testing;
    10. for Website Users, to deliver content and advertisements to you;
    11. for Website Users, to make recommendations to you about goods or services which may interest you;
    12. for Website Users, to measure and analyse the effectiveness of the advertising we serve you;
    13. to monitor trends so we can improve the Website and App;
    14. to provide you with information about your usage of your Revitive and your progress with your usage plan;

in each case, in accordance with this privacy policy.

11. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
12. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
13. For Website Users, if you have selected the relevant cookies we may use your Data to show you Actegy Limited adverts and other content on other websites. If you do not want us to use your data to show you Actegy Limited adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed "Cookies" below).

Who we share Data with

14. We may share your Data with the following groups of people for the following reasons:
    1. any of our group companies or affiliates - to ensure the proper management of the App and the Website;
    2. our employees, agents and/or professional advisors - to obtain advice and ensure the best quality of product is offered;
    3. third party payment providers who process in-App purchases and payments made over the Website. We do not process and have limited access to your financial information/Data. The third-party payment provider handles and secures such data in accordance with their privacy policy;
    4. relevant authorities - to facilitate the detection of crime or the collection of taxes or duties;

in each case, in accordance with this privacy policy.

15. Where personal Data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
    1. We will only transfer your personal Data to countries that have been deemed to provide adequate level of protection for personal Data by the European Commission;
    2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal Data the same protection it has in Europe;
    3. Where we use providers in the US, we may transfer your personal Data to them on the basis of specific contracts approved by the European Commission which give personal Data the same protection it has in Europe .

Keeping Data secure

16. We will use technical and organisational measures to safeguard your Data, for example:
    1. access to your account is controlled by a link sent to your email address that is unique to you;
    2. we store your Data on secure servers;
    3. payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology;
17. We are certified to PCI DSS. This family of standards helps us manage your Data and keep it secure.
18. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: info@actegy.com.
19. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by the UK Government and leading businesses in the UK.

Data retention

20. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.
21. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

22. You have the following rights in relation to your Data:
    1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
    3. Right to erase - the right to request that we delete or remove your Data from our systems.
    4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
    5. Right to data portability - the right to request that we move, copy or transfer your Data.
    6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
23. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@actegy.com.
24. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority.
25. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

26. This Website or the App may, from time to time, provide links to other third-party websites. We have no control over such third-party websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such third-party websites. You are advised to read the privacy policy or statement of such third-party websites prior to using them.

Changes of business ownership and control

27. Actegy Limited may, from time to time, expand or reduce its business and this may involve the sale and/or the transfer of control of all or part of Actegy Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
28. We may also disclose Data to a prospective purchaser of our business or any part of it.
29. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

30. This Website may place and access certain Cookies on your computer. Actegy Limited uses Cookies to improve your experience of using the Website and to improve our range of products, and to distinguish you from other users of the Website and to remember your preferences. Actegy Limited has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
31. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
32. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Actegy Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
33. This Website may place the following types of Cookies:

34. You can find a list of Cookies that we use in the Cookies Schedule.
35. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
36. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
37. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
38. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

39. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
40. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
41. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
42. Actegy Limited has appointed Revitive SAS as its EU Data Representative, if you need support you can contact our EU data representative by email and by post at the following address:

Revitive SAS

250 bis boulevard Saint Germain

75007 PARIS

Email : contact@revitive.fr

Phone : 0805 321 051 / +33 1 75 85 03 74

 

43. This Agreement is governed by, and construed in accordance with, the laws of England, and the parties submit to the non-exclusive jurisdiction of the courts of England. to the extent permitted by applicable law

 

Changes to this privacy policy

44. Actegy Limited reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. For the Website, any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. For the App these changes will be, where appropriate, notified to you when you next start the App or log on. The new policy may be viewed via a link and you may be required to read and accept the changes to continue your use of the App.

You may contact Actegy Limited by email at info@actegy.com.

 

 

Cookies

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.

Strictly necessary

We use the following strictly necessary cookies:

Analytical/performance

We use the following analytical/performance cookies:

Functionality

We use the following functionality cookies:

Targeting/Marketing

We use the following targeting cookies:

 

How we use your information to understand our customers wishes and shopping preferences

Our communications are designed to tell you about the benefits we can offer so that you have access to our best offers. We use the information we have about you to tailor the content and try to ensure that the offers are as relevant to you as possible. Under the Data Protection Legislation, this might qualify as profiling.

How we use your information to improve our service and our products

We may hold any feedback from individuals relating to customer service or product analysis (e.g. customer reviews) to help us to improve in these areas. Customer feedback may be used within our commercial advertising and/or on our websites.

Will Revitive Aerosure share my personal information with anyone else?

We may pass your personal data on to trusted service providers contracted to Revitive Aerosure in the course of our relationship. Any trusted providers that we may share your data with have been scrutinised by us to make sure they process data in accordance with the law and they are contractually bound to keep your details securely in accordance with data protection laws. Examples of trusted service providers include:

• HM Revenue & Customs, regulators and other authorities
• Logisitics/Order fulfilment companies
• Credit reference agencies
• Fraud prevention agencies
• Companies you ask us to share your data with
• Marketing agencies who are providing profiling, advertising and targeting services to us
• Market research companies
• IT systems providers

How can I change my marketing preferences?

Revitive Aerosure and our carefully selected and trusted retail partners will only send you relevant marketing communications, for instance, exclusive offers we feel are of interest to you or guidance tips on how to get the best out of your Revitive Aerosure device.

However, we respect and appreciate your right to privacy. If you would like to stop or amend the marketing communications you receive from Revitive Aerosure and/or our trusted retail partners then please fill out the marketing preferences form in its entirety using the below link:

Manage My Marketing Preferences Form

The form will then be submitted to our data lead who will immediately amend your details as requested and respond confirming your account has been updated. Alternatively, you can call our customer services team directly on 0800 014 6377 and they can update the system on your behalf.

How can I find out what information Revitive holds about me?

You can request a ‘subject access form’ directly from Revitive by emailing data.lead@actegy.com or alternatively, by post: Data Protection Lead, Revitive Aerosure Reflex, Cain Road, Bracknell, RG12 1HL. This service is offered free of charge unless your request is deemed excessive or unfounded. If this is the case, we will notify you of our intention to levy a reasonable cost and seek your agreement before undertaking the request.

How long do we keep your information?

Revitive Aerosure holds various categories of personal data for different periods of time. Wherever possible, we will endeavour to minimise the amount of personal data that we hold and the length of time for which it is held.

To find out the retention period for your personal information please email data.lead@actegy.com

How can I update, amend or stop the use of my information?

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’, ‘right to erasure’, or the ‘right to be forgotten’.

There may be legal or other reasons why we need to keep or use your data. But please tell us if you think that we should not be using it. We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

We understand that over time information about you may become inaccurate, for example, you change your address or contact information. It is our duty to keep your personal information up to date and therefore politely request that you notify us of any change using the details provided below.

If you would like to exercise your information rights as outlined above or if you think the information we are holding on you is incorrect or incomplete, please email data.lead@actegy.com or write to the Data Protection Lead, Revitive, Reflex, Cain Road, Bracknell, RG12 1HL. We will promptly respond and act upon your request.

Your right to complain

Please let us know if you are unhappy with how we have used your personal information by speaking directly to the Data Protection Lead at data.lead@actegy.com. You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.

Sending information outside of the EEA

On occasion Revitive Aerosure may need to send your information outside of the European Economic Area (‘EEA’). If we do transfer information outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA.

What cookies does Revitive Aerosure use?

You do not have to provide any information to us to use this website. However, certain sections of the site or facilities within the site may not be accessible if you choose not to share essential information with us. You can set your browser to reject cookies (see the ‘Help’ menu of your browser to find out how to do this), but please bear in mind that if you do this, certain personalised features of this website cannot be provided to you.

For more information on our cookie policy, a list of the main cookies, along with details of what each one is used for, then please visit our ‘cookies’ page.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, please send a detailed message to data.lead@actegy.com or write to our Data Protection Lead at Revitive, Reflex, Cain Road, Bracknell, RG12 1HL. We will be happy to resolve any concerns.