Personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect personal data when you visit our website. We collect data when you use our services, as well as when you view our websites or our profiles on social media.

The personal data we collect about you depends on the particular activities carried out through our website and Maxity App. We may collect, use, store and transfer the following personal data about you:

• Identity Data including but not limited to your full name, title, gender, date of birth, home address, email address, telephone number and any other contact information or information required to check and verify your identity, company details (if applicable);
• Financial Data including but not limited to your account, payment details, data necessary to process your payment when you use our services on our website, such as your billing information, transaction and payment card or other payment method information;
• Profile Data including your username, password, transactions made by you;
• Usage Data including your activities on, and use of, our website;
• Marketing and Communications Data including information about the services we provide to you, your preferences in receiving marketing from us and our third parties and your communication preferences;
• Cookies (please see our Cookie Policy for more information);
• Technical Data including but not limited to internet protocol (IP) address used to connect your computer to the internet, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Generally, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We also collect information about your location and physical movements in order for the App to function properly and monitor and verify forms of eligible movement. We collect the movement data (Health kit / Google fit steps data), to verify your physical movement. You may turn location monitoring on and off from time to time using the settings of your operating system of your mobile device but, if you disable this functionality, we will not be able to collect information relating to your step-count and hence are not able to calculate the rewards for you.

If you fail to provide personal data

If you do not provide personal data we ask for where it is indicated to be 'required', it may delay or prevent us from replying to your enquiries and/or providing services to you.

We collect and use this personal data for the purposes described in the section 'How and why we use your personal data' below.

How your personal data is collected

We collect personal data from you:

• Directly when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, sign up to receive email alerts, purchase products or services via our website or complete customer surveys via our website, and;
• Indirectly such as your browsing activity while on our website; we will usually collect information indirectly using cookies and various tracking technologies.

We may also collect personal data about you from other sources such as public databases, marketing partners, as well as other third parties.

We use this information for the purposes that you provide it.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, for example:

• To provide services to you, for the performance of a contract with you or to take steps at your request before entering into a contract: we may use information to execute your transaction requests and trade orders;
• To comply with our legal and regulatory obligations: we are obliged to collect certain information about our Users to be authorized to act (Know Your Client and Anti-Money Laundering regulations);
• For our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests.

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. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use your personal data for and why.

Legal Basis for Processing Personal Data

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. 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. We state what we use your personal data for and our reasons as follows:

• Creating and managing your account with us - To provide products and services to you, to perform our contract with you or to take steps at your request before entering into a contract.
• Providing products and/or services to you - To perform our contract with you or to take steps at your request before entering into a contract.
• Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us - For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for you and/or us.
• Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website - Depending on the circumstances: your consent as gathered by cookies, log files and other tracking technology; where we are not required to obtain your consent and do not do so, 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 to you at the best price.
• Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes. This helps us to understand how people use our website so that we can make it more intuitive or to check our website is working as intended - Depending on the circumstances: your consent as gathered by cookies, log files and other tracking technology; where we are not required to obtain your consent and do not do so, for our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price.
• Protecting the security of systems and data - To comply with our legal and regulatory obligations. We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.
• Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures - For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service to you at the best price.
• Updating and enhancing customer records - Depending on the circumstances: to perform our contract with you or to take steps at your request before entering into a contract; to comply with our legal and regulatory obligations; where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products.
• Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant - To comply with our legal and regulatory obligations.
• Marketing our services to existing and former customers - For our legitimate interests or those of a third party, ie to promote our business to existing and former customers.

Who we share your personal data with

We routinely share personal data with:

• Third parties we use to help deliver our products and services to you, including payment service providers.
• Other third parties we use to help us run our business.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above may occasionally also need to share personal data with:

• External auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations.
• Professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations.
• Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations.

Block Technology LTD may transfer your personal data outside of the European Economic Area (“EEA”). Block Technology LTD has in place suitable technical, organizational and contractual safeguards, to ensure that such transfer is carried out in compliance with applicable data protection rules, except where the country to which the data is transferred has already been determined by the European Commission to provide an adequate level of protection.

If you would like more information about who we share our data with and why, please contact us. (see How to contact us)

Marketing

We may use your personal data 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 using your personal data for marketing purposes. This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.

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

• Contacting us at [email protected], or using the 'unsubscribe' link in emails.
• We may ask you to confirm or update your marketing preferences if you ask 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.
• We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes. (see Your rights)

How long your personal data will be kept

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Generally, we will retain your information for as long as your account is active, your information is needed to provide you services, or as required to fulfill our legal obligations.

• Access to a copy of your personal data The right to be provided with a copy of your personal data.

  A more detailed explanation of this right under UK law is available. here

• Correction (also known as rectification) The right to require us to correct any mistakes in your personal data.

  A more detailed explanation of this right under UK law is available. here

• Erasure (also known as the right to be forgotten) The right to require us to delete your personal data in certain situations.

  A more detailed explanation of this right under UK law is available. here

• Restriction of use The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.

  A more detailed explanation of this right under UK law is available. here

• Data portability The right to receive the personal data 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.

  A more detailed explanation of this right under UK law is available. here

• To object to use The right to object: at any time to your personal data being used for direct marketing (including profiling); in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.

  A more detailed explanation of this right under UK law is available. here

• Not to be subject to decisions without human involvement 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. We do not make any such decisions based on data collected by our website.

  A more detailed explanation of this right under UK law is available. here

• For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see How to contact us). You may also find it helpful to refer to the guidance from the UK's Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email us at [email protected]

When contacting us please:

• Provide enough information to identify yourself, including your full name, address and customer or matter reference number and any additional identity information we may reasonably request from you, and;
• Let us know which right(s) you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

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.

We have implemented the following technical and organisational measures for example:

How to complain

Please contact us if you have any queries or concerns about our use of your information (see below 'How to contact us'). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

• The Information Commissioner, and a relevant data protection supervisory authority in the EEA state of your habitual residence, place of work or of an alleged infringement of data protection laws in the EEA.
• The UK Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint

Changes to this privacy policy

We may change this privacy policy at any time, any such changes will be posted on this page with an updated revision date.