Last Modified: May 23, 2018
- Information We Collect
- How We Use Information We Collect
- How We Share Information We Collect
- International Transfer of Information
- Cookies and Similar Technologies
- How to Access & Control Your Personal Data
When You use our Portal, App and Visit our Websites
You are free to explore the Websites without providing any Personal Information about yourself. When you visit the App store, Play Store and Websites and register for using the Services, we request that you provide Personal Information about yourself, and we collect Navigational Information.
When You Use our Mobile Application
We use mobile analytics software to allow us to better understand the functionality of our Mobile Apps on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. In addition to information we collect on our Websites, when you use our Mobile Apps we may also collect your city location, device model and version, device identifier (or “UDID”), OS version, and your CyberLiver account credentials.
We send push notifications from time to time in the app as motivational messages, to update you about events or promotions. If you no longer wish to receive such communications, you may turn them off at the device level.
We may link information we store within the analytics software to Personal Information you submit within the Mobile App. We do this to improve services we offer you and improve our marketing, analytics and site functionality.
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, date of birth, gender, location, Height, Weight, Weekly drinking average, and other information about yourself. Personal Information can also include information about any transactions, both free and paid, that you enter into on the app, and information about you that is available on the internet, such as from Facebook, Google where you’ll use it for signing in to the app/portal.
Personal Information also includes your drinking data, sleep activity, drink location and time stamp of the activities in the app. Your payment information is stored in Google Play account, PayPal and iTunes account who are data processors and is secure. We don’t store any of your payment information in our databases and all the payments are carried out through secure 3rd party payment portal and are covered under their terms and privacy policies.
We may also collect information that your browser or App sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, mobile UDID, geo-localisation data, and other statistics. In order to process purchases made through the Websites we may pass this information to the third party service provider, PayPal. In addition, we may use third party services such as Google Analytics, Appsflyer and Flurry that collect, monitor and analyze this type of information in order to increase our Service’s functionality. These third party service providers have their own privacy policies addressing how they use such information.
Information we collect from third parties
We don’t collect any Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites.
Information About Children
The app and websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at privacy@CyberLiver.com, so that we may delete the information.
Alcohol Concern UK & Alcohol Research UK
In April 2017 Alcohol Concern merged with Alcohol Research UK, a charity registered in England and Wales (No. 1140287). Both charities share a clear mission to reduce the harm caused by alcohol. Alcohol Research UK has a long record of research excellence and impact, while Alcohol Concern brings a strong media and campaigning profile. Combined, the two charities are in a much stronger position to use robust evidence to campaign for, and support those working to achieve, a reduction in alcohol harms. Any data given to Alcohol Concern will be shared with Alcohol Research UK, who owns the trading name Alcohol Concern and Dry January. The newly formed charity sits under the registration of Alcohol Research.
We Never Sell Personal Information
We will never sell your Personal Information to any third party.
Use of Personal Information
- improve your browsing experience by personalizing the app and websites and to improve the Service;
- send information or CyberLiver content to you which we think may be of interest to you by push notification, email, or other means and send you marketing communications relating to our business;
- promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
- we share your personal information with our partners who have a legal contract with us to collect/use your data. In this case Alcohol Concern is our partner and we collect your personal data on behalf of them and share your personal information (Name, Email, Date of Birth, Gender, Location and preferences) for them to send appropriate emails during the Dry January campaign and thereafter. Our partners will get consent from you through email.
- meet legal requirements.
We do not transfer your Personal Information to any third party.
We use the information collected through our App and website Premium Subscription Service by our users for the following purposes:
- to provide the Premium Subscription Service (which may include the detection, prevention and resolution of security and technical issues);
- to respond to user support requests; and
- otherwise to fulfill the obligations under the CyberLiver Terms of Service.
Legal basis for processing Personal Information (EEA visitors only)
If you are a visitor/user located in the European Economic Area (“EEA”), CyberLiver Limited is the data controller of your personal information. CyberLiver’s Data Protection Officer can be contacted at privacy@CyberLiver.com.
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
User Testimonials and Comments
We post user testimonials and comments on our App pages, Websites, and portal which may contain Personal Information. We obtain each user’s consent via email prior to posting the user’s name and testimonial.
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
Social Media Features
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in “Opting Out and Unsubscribing” below.
Retention of Personal Information
How long we keep information we collect about you depends on the type of information. as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain Personal Information that you provide to us where we have an ongoing legitimate product/service/portal need to do so (for example, as long as is required in order to enable you to login to the app or portal or to access our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
When we have no ongoing product/service/portal need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in “To Unsubscribe from Our Communications” below.
If you provide information to our partners as part of their use of the app or portal or services, our partners decide how long to retain the personal information they collect from you. If an user requests to terminates the use of the app or portal or services, then we will provide user with access to all information stored in our database on request, including any Personal Information, for export according to our agreement with you. After termination, we may, unless legally prohibited, delete all user information, including your Personal Information, from our databases.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences until the end of that calendar year from the date you last expressed interest in our app, portal, content, products, or services, such as when you last opened the app, email from us or ceased using your CyberLiver account. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created.
- How we Share Information we Collect
CyberLiver Partners & Research
We, or Alcohol Research UK may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. We will only send you marketing information by email whilst you are opted in to our marketing database.
We may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide user support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information.
We work with experts with in our organisation and trusted partners who might use the data collected from you to do analysis, research, and release the results in public domain and we ensure you that whenever the research results are published the user identify is anonymised and are not shared with any third party. We might use the collected personal data for research purposes based on the consent received during the Dry January 2017/2018 campaign where users signed up from the website or app and may avoid restrictions on secondary processing and on processing sensitive categories of data (Article 6(4); Recital 50). We have implemented appropriate safeguards and may override a data subject’s right to object to processing and to seek the erasure of personal data (Article 89) in unavoidable circumstances.
We may contact you to get consent if you’re willing to be a part of future research and sign a separate privacy and research agreement at that time. As of now the terms and privacy that was available at the beginning of 2018 is in use and we are not making any changes to it in terms of how we collect and use your data until December 01, 2018.
Dry January Workplace
Organisations or Companies signing up for Dry January workplace will receive the licenses (redemption codes) in email after we realise the payment. Employees who redeem a code will be marked under an organisation to which the code is assigned. The personal information, activity in the app and other user information collected through the Dry January app or user dashboard is private and confidential. All this data will be anonymised and stored in our platform, CyberLiver will never share any individual information to the respective organisations. Local Data Protection Act and privacy laws will apply to ensure that employee information is safe and protected. Mail us at email@example.com if you have any questions about your participation in Workplace.
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by CyberLiver on the app, portal, websites and other services. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
International Transfers within CyberLiver’s Entities
To facilitate our global operations, we transfer information to India or United States and allow access to that information from countries in which the CyberLiver affiliated entities have operations for the purposes described in this policy.
International transfers to third parties
- Cookies and Similar Technologies
You can log in to our app or portal using a Single Sign-on (SSO) service using your email, Facebook or Google logins. This service will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.
We don’t partner with any third party to advertise in the app or portal or website based on your personal preferences and data. We don’t share or sell any personal information to any third party with respect to advertising or marketing.
Third Party Tracking Technologies
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
- You can request access, correction, updates or deletion of your personal information.
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)
To exercise any of these rights, please contact us at privacy@CyberLiver.com. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
To Unsubscribe From Our Communications
You may unsubscribe from our communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, updating your communication preferences, or by sending us email us at firstname.lastname@example.org or email@example.com. Users cannot opt out of receiving transactional emails related to their account with us or the Premium Service. To Unsubscribe from Our Partners Communications
Our partners are solely responsible for their emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our users’ marketing communications by clicking on the “unsubscribe” link located on the bottom of their emails, or by contacting them directly.
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