Privacy Policy

The Alpha Complex

 

The Alpha Complex’s mission is to find new ways for users to improve their overall wellbeing. Through various methods, including tracking your mental and emotional state and setting positive goals, we aim to provide services that are transparent about the data we collect. This data is collected to improve the service we provide our users.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

Who We Are

We are THE ALPHA COMPLEX LTD, registered in England and Wales, [trading as The Alpha Complex or The Zone Tracker App, or both]. We provide Internet and mobile app-based services through our app – The Alpha Complex – Zone Tracker and www.thealphacomplex.life (“the Services”).

As a part of our Services we collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our THE ALPHA COMPLEX
Personal information Any information relating to an identified or identifiable natural person, who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Special category personal information Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership.

Genetic and biometric data.

Data concerning health, sex life or sexual orientation.

Personal information we collect about you

We may collect and use the following personal information about you:

This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing these services to you.

How your personal information is collected

We collect most of this personal information directly from you—via our apps and website.

However, we may also collect information:

How and why we use your personal information

For the purposes of applicable data protection laws, we are the controller of the Personal Data you provide to us (“Data Controller”). As a Data Controller, we process the Personal information we maintain about you in accordance with this Privacy Policy. If you have any questions or concerns regarding the processing of your Personal information, or if you have questions regarding this Privacy Policy, please see below for our contact details.

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use and process your personal information for and our reasons for doing so:

What we use your personal information for Our reasons why we use your personal information
To provide OUR services to you For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you
To conduct checks to identify our customers and verify their identity To comply with our legal and regulatory obligations
To gather and to provide information required by or relating to audits, enquiries or investigations by regulatory bodies To comply with our legal and regulatory obligations
To ensure business policies are adhered to, e.g. policies covering security and internet use For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
For operational reasons, such as improving efficiency, training and quality control, and developing new services or products. For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price, and to be able to offer new services and products to you
To ensure the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

For statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
To prevent unauthorised access and modifications to systems For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

To update and enhance customer records For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

To ensure safe working practices, staff administration and assessments To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

For marketing our services to existing and former customers For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
For external audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate that we operate at the highest standards

To comply with our legal and regulatory obligations

To pass necessary information to healthcare providers For the performance of our contract with you to improve the quality of our services to you

For our legitimate interests or those of a third party, e.g. to understand triggers and trends in data, allowing us to offer a better service to users and create systems that may help users get the information they need, with regards to their health and wellbeing

To offer users commercial information, i.e. if a user states they are learning Russian, we can deliver/guide useful resources towards that customer. For the performance of our contract with you to improve the quality of our services to you

For our legitimate interests or those of a third party, e.g. if a user states they are learning Russian, we can deliver/guide useful resources towards that customer

Consent as a basis for processing

In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when (i) providing us with your Personal Data through our Services or a form (including enrolling in Promotions); or (ii) registering or creating an account with us.

Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our products AND services, including exclusive offers, promotions or new products AND services.

We have a legitimate interest in processing your personal information for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell OR share it with other organisations outside The Alpha Complex and other organisations listed below (see below: ‘Who we share your personal information with’) for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products AND services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with

We routinely share personal information with:

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party not already stated.

Where your personal information is held

Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

How long your personal information will be kept

We will keep your personal information while you have an account with us or we are providing products AND services to you. Thereafter, we will keep your personal information for as long as is necessary:

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Transferring your personal information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

These transfers are subject to special rules under European and UK data protection law. Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. If you would like further information, please contact us (see ‘How to contact us’ below).

We may transfer personal information only to those countries, which have been assessed by the European Commission as providing an adequate level of protection for personal information.

Your rights

You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal information (the right of access)
Rectification The right to require us to correct any mistakes in your personal information
To be forgotten The right to require us to delete your personal information—in certain situations
Restriction of processing The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:

—at any time to your personal information being processed for direct marketing (including profiling);

—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests

Not to be subject to automated individual decision-making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please view the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation online.

If you would like to exercise any of those rights, contact us at contact@thealphaxcomplex.life. Please include the following information with you request:

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on 28/10/18.

We may change this privacy notice from time to time—when we do we will inform you via contact@thealphacomplex.life.

How to contact us

Please contact us by email at contact@thealphacomplex.life.