RevolutionEyes Me Ltd Privacy Statement

INTRODUCTION

RevolutionEyes Me Ltd (“RevolutionEyes Me” or “We” or “Us”) is committed to protecting and respecting your privacy in line with current legislation. This privacy statement is relevant to anyone who is using the RevolutionEyes Me service. It tells you what personal data is collected and what we do with that personal data.

The RevolutionEyes Me Ltd service uses your Health data (a combination of Personal Data and Sensitive Personal Data) collected manually from you and from any personal health tracking devices or mobile applications that you have linked to your account, for example the Apple Health app on your iPhone, in order to fulfill the RevolutionEyes Me service you have purchased. A full description of the RevolutionEyes Me service can be found in the Terms of Service on our website.

Please note that any health tracking devices or health apps that you integrate with the RevolutionEyes Me service are subject to their own terms and privacy policy and RevolutionEyes Me is not in any way affiliated with third party health tracking devices or health apps. You are under no obligation to use any devices and/or download any apps in order to use the RevolutionEyes Me service.

ABOUT REVOLUTIONEYES ME

RevolutionEyes Me Ltd (“RevolutionEyes Me” or “Us” or “We”) is a registered company in the United Kingdom (Company No. 09172894; Registered Office Address 18 Sulgrave Road, London W6 7RP)

DEFINITIONS

In the provision of the RevolutionEyes Me service, both Personal Data and Sensitive Personal Data will be collected and used.

Personal Data means data which relates to a living individual who can be identified from the data or from the data and any other information which is in the possession of, or likely to come into the possession of, the data controller.

Sensitive Personal Data means personal data consisting of racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.

We will also refer to the Data Protection Officer (DPO) and the Data Controller.

According to the GDPR legislation which comes into effect in May 2018, RevolutionEyes Me will be required to appoint a DPO as we carry out large scale systematic monitoring of individuals and carry out large scale processing of special categories of data. The purpose of the DPO is to inform and advise RevolutionEyes Me and our employees about obligations to comply with GDPR and other data protection laws; to monitor compliance with GDPR and data protection laws; and to be the first point of contact for supervisory authorities and for individuals whose data is processed.

The Data Controller means an organisation or person who determines the purposes for which and the manner in which any personal data are or are to be processed.

The Data Processor means any organisation or person who processes the data on behalf of the Data Controller.

WHAT DATA WE USE

Personal Data

We collect Personal Data at the point of contacting us via email, subscribing to any of our email lists, submitting a ‘contact’ form or purchasing the product/service.

Name, Age, Phone Number, Email

Sensitive Personal Data

We collect Sensitive Personal Data after you have purchased the product as part of fulfilling the product/service.

Gender; Physical/mental health information; Biometric information

Cookies

Cookies (small text files placed on your computer while using our site) may be used to assist with improving your site experience and to safeguard your privacy whilst browsing our site. For more information visit www.allaboutcookies.org

Strictly necessary cookies; Performance cookies; Functionality cookies; Targeting/Advertising cookies

Browser Event Data

Browser event data is collected during your visit to our website. This information is collected and processed to provide insights into user behaviour in order for us to continually improve our service.

Device IP address; Device screen resolution; Device type; Country location; Preferred language; Mouse events; Keypresses; Log data

Web Beacons

Webpages and HTML emails may also contain a small snippet of code called a web beacon. In their simplest form, web beacons allow a website to transfer or collect information through a graphic image request. RevolutionEyes Me may use web beacons as part of the site, but only for fraud detection.

 WHERE DO WE STORE YOUR DATA

All Data is stored within EEA Servers using Amazon Web Services. We conduct annual security testing to ensure our database is secure.

HOW DO WE PROVIDE THE REVOLUTIONEYES ME SERVICE WITH OTHERS

This section explains the purposes to which we put your Personal Data and Sensitive Personal Data and explains the legal basis and legitimate interests we rely upon when we do so.

‘Legitimate Interests’ refers to our interests in conducting and managing our business. The particular interest which we are relying on in each case is explained in more detail below. When we use your data in our legitimate interests, we make sure to balance any potential impact on you and your rights under data protection laws. Our interests do not automatically override your interests.

We will never share the Personal Data or Sensitive Personal Data with any other parties except for the purposes of fulfilling our service and aggregated data or research, in which case all data we use would not be identifiable.

  • To provide the RevolutionEyes Me service

What Data we use: Name, Email, Date of Birth, Address, Telephone Number, GP Information, Biometric Data, Dietary and exercise data

How We will use Data: We will use your Personal Data and Sensitive Personal Data to provide the service, including to manage our relationship with you, to verify your identity and eligibility to use our service and/or to contact you to provide and administer our service. Without this information, we cannot provide the RevolutionEyes Me service.

  • To improve the RevolutionEyes Me Service

What Data we use: Name, Email, Date of Birth, Address, Telephone Number

How we will use Data: We may use contact you for your feedback or use your information to improve the RevolutionEyes Me service by creating pseudonymised reports and by contacting you to receive feedback. We can use your data in this way because we have a legitimate interest in improving and tailoring our service and keeping our customers happy.

  • To conduct research and aggregated reports

What Data we use: Pseudonymised Personal Data and Sensitive Personal Data

How We will use Data: We may use this data to conduct research on the efficacy of our products and to identify where we can improve our product, or to provide aggregated anonymised reports to analyse the usage, uptake and efficacy of the products and services.

  • To do what we are required to do by law

What Data we use: Name, Email, Date of Birth, Telephone Number

How We will use Data: We may be required to retain or use your data if we have a legal duty or obligation to do so. This may be in the context of an employer and retaining certain employee data for a certain period of time, or it may be in the context of providing law enforcement agencies with data to aid with legal proceedings.

  • To assist you where you may be at risk

What Data we use: Name, Email, Address, Telephone Number, GP Information

How We will use Data: We may use your Data to assist where your health or life is in danger. We can use your data in this way because it protects your vital interests.

HOW LONG CAN WE KEEP YOUR PERSONAL DATA FOR

We may only keep your personal data for as long as it is required for one of the reasons detailed in the above section.

We have policies about how we keep/store your personal data. The periods differ depending on the period and the purpose for which we are using your personal data and the nature of the personal data.

How long we keep the data is determined by the period we need to keep it for in line with fulfilling the service and our legal obligations.

We typically retain personal data for approximately 7 years from the point the data is no longer used however in some cases, such as legal requirements, we may be required to keep it longer.

When data is no longer required for its purpose, we ensure data is securely and irrevocably deleted from our system.

WHEN CAN YOU ASK US TO STOP USING YOUR DATA

We rely on consent and lawful basis for processing in order to fulfill the products and services we offer and also so we can contact you directly about the status of your product/service.

You can ask us to stop using your Data at any time, however in doing so we will be unable to continue providing the service.

In order to request that we stop using your data, you can send us an email to hi@feeliom.com stating that you wish for us to stop using your data immediately.

WHAT HAPPENS IF YOU DON’T GIVE US SOME OF YOUR DATA

It is entirely optional to provide consent for us to collect and process your data, however where you do not provide the Data we need in order to provide the requested RevolutionEyes Me service or to fulfill a legal requirement, we will not be able to fulfill the service requested.

HOW TO CONTACT US ABOUT THIS PRIVACY STATEMENT

You may contact us at any time via email or post to query anything that may have come up from reading this statement.

Address: RevolutionEyes Me Ltd, Att: Operations, 18 Sulgrave Road, London W6 7RP United Kingdom

Email: hi@feeliom.com

YOUR RIGHTS

We can be contacted at the addresses above for one or more of the following reasons:

  1. To ask Us to fix Personal Data about You that is wrong or incomplete, or delete Personal Data about You.

  2. To tell Us that You no longer consent to Us using Personal Data about You and to ask Us to stop. This would not invalidate Our use of the Personal Data prior to the withdrawal of consent.

  3. To tell Us to stop using Your Personal Data for direct marketing purposes.

  4. To ask Us to send You the Personal Data We have about You. This is sometimes called a "subject access request".

 

On or after 25 May 2018, We can also be contacted at the address above for the following reasons:

  1. To ask Us to provide You with the Personal Data You have provided to Us. We will provide the Personal Data in a CSV formatted document so that another organisation's software can understand that Personal Data. This is sometimes called a "data portability" right.

  2. To ask Us not to use Personal Data about You in a way that allows Our computer systems to make decisions about You.

  3. To request that We restrict use of Your Personal Data or to object to its use (including objecting to data used in Our "legitimate interests").

Sometimes We will not be able to stop using Your Personal Data when You ask Us to (e.g. where We need to use it because the law requires Us to do so).

COMPLAINTS

You have the right to complain about how We treat Your Personal Data to the Information Commissioner's Office (the "ICO"). The ICO can be contacted at:

  • Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

  • Telephone: 0303 123 1113 (local rate) or 01625 545 745

  • Email: https://ico.org.uk/global/contact-us/email/

CHANGES TO THIS PRIVACY STATEMENT

We may update this Privacy Statement from time to time. We will notify You of the changes where required by law to do so.

Last modified on 21/06/2018

FEELIOM TERMS OF USE 2019

Information About Us

These Feeliom User Terms govern your order of the services we make available from  www.feeliom.com (the “Site”), a website operated by RevolutionEyes Me Limited (“we”/“us”/ “our”).  Our registered office address is: 18 Sulgrave Road, London, W6 7RP, UK.

Please read the following important terms and conditions before you sign up to the Feeliom service and confirm that they contain everything that you want and are willing to agree to.

If you do not agree to anything within these terms, our Privacy Policy or our User Terms, please refrain from accessing or using the Feeliom services.

 

How to Contact Us

You may contact us between the hours of 9:00am to 5:00pm on Monday to Friday by any the following methods:

Email: hi@feeliom.com

Phone Number: 07785 564 743

Post: RevolutionEyes Me Ltd, Att: 18 Sulgrave Road, London, W6 7RP, UK

Information about these Terms

These Feeliom User Terms apply to the exclusion of the Feeliom Website Terms but not our Privacy Statement.

 

These Terms together with our Privacy Statement and Website Terms form a legal contract between you, the ‘User’ and Us and apply between You and Us in relation to any use which you make of the Site.

 

You confirm that you request immediate performance of the Services contract and acknowledge that you will lose your right of withdrawal from the contract once the Services contract is fully performed.

 

We may revise these Feeliom User Terms from time to time in order to reflect (i) any changes in relevant laws or regulatory requirements (ii) any changes to the Site and/or the Services that are necessary to make as a result of changes to the way we receive services from our third party suppliers or (iii) any modified or additional Services we may cease to make available or make available and which you agree to receive.

 

If we have to revise these Feeliom User Terms we will give you at least 7 days notice of any changes to these Feeliom User Terms before they take effect. You can choose to cancel the Services contract by notifying us by email to hi@feeliom.com if such changes materially disadvantage you.  

 

Geographical Restrictions

Feeliom's Services available through the Site, are not available in locations outside the United Kingdom. Users access our Site and the Services on their own initiative and are responsible for compliance with local laws.

 

Becoming A User

When you register to the Feeliom service, you will be required to complete an online form and accept our Terms of Use, User Terms and Privacy Policy.

Once you have registered, you will receive an order confirmation email from us which will confirm your order and a welcome email from us which will confirm the process and your collection method. This email will also prompt you to login to your online account and complete your health profile.

As part of your becoming a User you will provide us with certain personal information when prompted to do so, in order to enable your account to be created. We will use that information in accordance with our Privacy Policy.

 

Information about the Services

Health Assessment

  • The Feeliom Health Assessment includes an in-app health survey.

  • Our Services are not a diagnosis tool. Your Account dashboard will provide a graphical representation of any outcomes obtained and enable you to access recommendations made. If further investigation is required the User will be guided to his/her general practitioner or existing healthcare provider(s). Our Services do not replace a User’s existing healthcare provider(s) but can be used as a supplement to them.

  • As a User, and provided you remain a User, you will be enabled via your account and its personal profile dashboard (“Account”) to engage with our online service. Our aim is to help a User be more proactive about his/her health by helping him/her to identify potential health risks. Our communication platform and guidance for Users are intended to promote our Users  making small proactive changes in their lives to help them minimise future risk.

Your Online Account

  • When you set up an Account, you are required to enter your name, email address, password (“Password”) and certain other information collected by us. We will send you an email link to enable your Account set-up.

  • You represent to us that you are at least 18 years old.

  • You are solely responsible for maintaining the confidentiality of your Account Information and you are fully responsible for all activities that occur under your Password or Account. You agree to immediately notify us upon your becoming aware of any unauthorised use of your Account Information or any other breach of security. You remain at all times solely responsible for any and all use of your Account, whether by you or by any other person obtaining access via your Account or using your Password.

  • Without limiting any rights which we may otherwise have, we reserve the right to take any and all action which we consider necessary or reasonable regarding the security of the Site and your Account, which may be for example, terminating your Account, changing your Password, or requesting additional information to authorise transactions on your Account. Notwithstanding these rights, we may rely on the authority of anyone accessing your Account or using your Password and in no event and under no circumstances will we be liable to you for any liabilities or damages resulting from or arising out of (i) any action or inaction under this provision, (ii) any compromise of the confidentiality of your Account or Password, and (iii) any unauthorised access to your Account or use of your Password. You may not use anyone else's Account at any time.

  • You promise that all information you provide to us is true, accurate, complete and current at the time you provide it to us; and you agree to maintain and promptly update such information to keep it true, accurate, current and complete. If we have reasonable grounds to suspect that such information is not true, accurate, current or complete, we may deny or terminate your access to the Site or Services (or any part thereof).

 

Submitting orders and Formation of contract

If you place an order through our site www.feeliom.com you will be required to make payment or provide a promotional code.

  • We will let you know the charges for the Products and Services before you place an order with us.

  • Payment is required up front and you will not be able to receive the Products or Services until we receive payment in full.  

  • Payment may be made by debit/credit card.

  • If you use the Site and/or Services to request further blood analysis re-tests, each such request constitutes a further order which we will notify as being accepted by us in accordance with these Feeliom User Terms. You appreciate that our Services will thus allow you to track your progress over time.

Cancellation

Your rights to cancel the products or services

The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 state that in most cases, you can cancel within 14 days. If you agree that a service will start within this time, you may be charged for what you have used.

The Consumer Rights Act 2015 states:

  • You can ask us to repeat or fix a service if it is not carried out with reasonable care and skill, or get some money back if we can’t fix it

  • If a price hasn’t been agreed upfront, what you’re asked to pay must be reasonable

  • If a time hasn’t been agreed upfront, any service we provide must be carried out within a reasonable time

For more detailed information on your key rights, please contact Citizens Advice www.citizensadvice.org.uk

 

How to cancel your products or services

  • You may delete your Account and end your ongoing User registration at any time, for any reason by sending an email to hi@feeliom.com

 

Our rights to cancel the products or services

  • If we find that you have breached the terms of this agreement, Feeliom may terminate your use of the Site, your Account and/or registration for any reason at any time without any liability to you.

 

Complaints and Disputes

If you are unhappy with the services, our service to you generally or any other matter, you may do so by emailing us at hi@feeliom.com.

  • We will try to resolve any disputes with you quickly and efficiently.

  • If you and we cannot resolve a dispute using our internal complaint handling procedure, we will let you know that we cannot settle the dispute with you and give you certain information required by law about the consumer ombudsman.

In the event of receiving a complaint, our process is to attempt to resolve the complaint directly with you. If we are unable to reach a resolution, we will escalate this to the relevant manager to investigate the issue further and discuss a resolution with you.

  • Nothing in these Terms affects your legal rights under the Consumer Rights Act 2015. You may also have other rights in law.

User Safety

We do not tolerate the sharing of content or displays of behaviour which are in any way harmful or abusive towards other users. To that effect, if you feel a user is behaving inappropriately towards you or someone else, you may refer them to us by emailing hi@feeliom.com.

Please quote their username, the date and time of your interaction to help us identify the misbehaviour and we shall take swift action to resolve this matter by:

  • Blocking them from connecting to your account.

  • Ejecting them from the platform.

We will act on objectionable content reports or misbehaviours by removing the content and ejecting the user who provided the offending content within 24 hours.

Your Acknowledgments

  • By placing your order, you promise and represent to us that you are legally capable of entering into this binding agreement between you and us; that you are at least 18 years old and you have completed an accurate request form identifying the blood sample as one taken from yourself.

  • By placing your order, you promise and represent to us that you are aware of the potential impacts and risks of taking your own blood sample, of blood analysis, and that you are proceeding on the basis that you accept full responsibility for any outcomes or consequences that may arise from these.

  • Although we make reasonable efforts to ensure that any information, including test results obtained and displayed by us within your Account dashboard are correct, we make no representations or promises of any kind in respect of the timeliness, accuracy or completeness of any of that information. You acknowledge that you are unable to rely on the content or information displayed in your Account dashboard (based on the results of the blood test and Health Assessment we provide as Services to you) alone to base your decisions about any personal and/or medical issues.

  • You acknowledge and agree that our Services are not a substitute for actual medical diagnosis, consultation with a doctor, any doctors’ recommendations, nor the advice and/or treatment to be derived from official health institutions regarding any aspect of your health, medicines, nutrition, lifestyle, treatment methods or related services. Our Services are intended to be used for information purposes only and for drawing attention to the importance of prevention for a longer and healthier life.

  • We recommend that you always consult an appropriate healthcare professional for advice on your specific circumstances and situation.

  • You acknowledge and agree that in rare cases, viable blood samples cannot always be taken from the blood sample actually provided.  Any final report/analysis will be deemed successfully completed if up to 14 specific analyses are absent, in which event no further tests will be carried out.

  • If you have any questions about the Services or results displayed via your Account dashboard, please email hi@feeliom.com and we will arrange a consultation with our expert team. Our Services do not include any telephone or in-person consultation with a doctor, however you may request this independently by sending us an email to  hi@feeliom.com.

Limitation of Liability

Due to the inherent nature of the internet, errors, interruptions and delays may occur at any time with your use of Feeliom. Accordingly, we cannot be held liable for any such errors, interruptions or delays.

 

  • Nothing in these Feeliom User Terms excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law.

  • If we fail to comply with these Feeliom User Terms, we are responsible for loss or damage you suffer that is a foreseeable result of our breach of these Feeliom User Terms or our negligence (but we are not responsible for any loss or damage that is not foreseeable). Loss or damage is foreseeable if they were an obvious consequence of our breach or if they were contemplated by you and Us at the time we entered into this User contract.

  • Please note that we only provide our Site and Services for domestic and private use. You agree not to use our Site and any Services provided for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

  • We take every care to ensure the services and suppliers we use are of good standing and are registered and accredited with the relevant governing bodies. You may be required to accept our suppliers terms and condition when booking appointments for clinic or nurse visits.

  • We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Site or to your downloading of any content on it, or on any website linked to it.

Changes to or Removal of User Information

  • Unless you have given us consent, we do not verify, modify or otherwise alter any of your User Information. We may at any time however correct any errors or modify any non-material information.

  • You may be allowed to update certain details of your Account-related information through your Account Dashboard (and you should in any event keep it updated at all times). If you are not able to update any information, you should request a modification by email directly to hi@feeliom.com.

  • You may request deletion of your User Information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).

  • When we delete User Information, it will be deleted from the active database, but may remain in our archives and we may also retain Anonymised Data about your use of our Service.

  • We employ reasonable technical, organisational and physical security methods to help protect against unauthorised access to User Information; However, you understand and agree that such steps do not guarantee that use of the Site is invulnerable to all security breaches, and that Feeliom makes no warranty, guarantee, or representation that use of any part of our Site is protected from viruses, security threats or other vulnerabilities.

  • Please report any breach of security of which you may become aware by email to hi@feeliom.com.

Law and Jurisdiction

If you are a consumer, please note that these Terms, its subject matter and its formation, are governed by English law. You and We both agree to that the courts of England and Wales will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland. If you are a business, these Terms, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

Updates

We may update our Terms from time to time. We will notify You of the changes where required by law to do so.

Last modified on 30/07/2018

Breaches

Please report any breaches of these Feeliom User Terms to hi@feeliom.com.

Contact

You may contact Us in writing by emailing us at hi@feeliom.com.