Hexis Privacy Policy

Last updated: Feb 2022    Responsible for policy: Michael Blakeley

Introduction

Thank you for using Hexis!
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At Hexis, we take the issue of your privacy very seriously, which is why we work hard to ensure we have policies and procedures in place that allows us to continue our mission of providing you with the framework and resources to improve your health and performance outcomes in a way which is respectful to your rights. The following privacy policy explains what personal data we collect from you, or that you provide to us, how we process it and what we do to keep it safe and as such we look to work in accordance with the Data Protection Act 2018.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Who we are and what we do

Hexis is a platform operated by Applied Behaviour Systems Limited. We empower athletes and coaches with personalised nutrition powered by AI. It is our belief that nutrition shouldn’t be confusing, which is why our platform is designed to remove the guesswork associated with nutrition and improve performance using bespoke fuel plans, live energy management, tailored energy and macronutrient recommendations, as well as intelligent coaching and carefully crafted recipes. We are registered at UK Companies House and our company number is 11280825, and ICO registration ZA752984 our office is based at 20-22 Wenlock Road, London, England, N1 7GU.

We collect personal data of the following types of people to allow us to undertake our business:

- You, our users or prospective users who we interact with.
- Our nutritionists, sports scientists, coaches and personal trainers who provide consultations for users of Hexis.
- Academic institutions that we partner with for PhD projects and research.
- B2B organisations, such as sports clubs, athletic teams, fitness groups, supplement suppliers and food manufacturers.
- Our own employees, technology partners and shareholders.

We collect information about you to carry out our core business and ancillary activities.

Information you give to us or we collect about you

This is information about you that you give us by registering on, and using, the platform or filling in forms on our site www.hexis.live, and corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use the platform, to enter our database, subscribe to our services or other social media functions, enter a competition, promotion or survey, and when you report a problem with our site or on our platform.

The information you give us or we collect about you may include your name, address, e-mail address, age, weight, height, sleep data, workout and nutrition data, dietary requirements, lifestyle activity & occupation.

Information we collect about you when you visit our website.

With regard to each of your visits to our site we will automatically collect the following information:

- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version, browser plug-in types and versions, operating system and platform;

- information about your visit, including the full Uniform Resource Locators (URL) and how you interact with our site.

Information we collect about you when you use our platform

Through your use of Hexis (such as uploading and updating your details and interacting with our services) and whether you sign into Hexis using your social media profile log in details or otherwise, we may collect and process the following information:

Name, age, gender, email address, training and nutrition data, weight, height, sleep patterns, workout and nutrition data, dietary requirements, lifestyle activity & occupation, information about your computer or mobile device,

Training and nutrition data includes data you provide related to your physical activity level, preferred sport and level of training, physical goals, workout details, meal patterns and timings.

Health Connect Data.

a. Collection and Usage of Health Data:
We value the privacy and security of our users. Our mobile application requests access to health-related permissions, specifically the ability to read steps and sleep information. This data is collected for the sole purpose of enhancing the user experience and providing features related to health and fitness.

b. Purpose of Health Data Access:
Our app utilizes health-related permissions to track daily steps, and sleep patterns. This data is processed locally on the user's device and is not shared with any third parties.

c. User Consent:
By using our app, you explicitly consent to the collection and usage of health-related data for the purposes outlined in this privacy policy. You have the option to grant or deny these permissions within the app settings.

d. Security Measures:
We implement robust security measures to protect the confidentiality and integrity of health-related data. This includes encryption and secure storage.

e. Data Retention:
We retain health-related data only for as long as necessary to fulfill the purposes outlined in this privacy policy. Users can request the deletion of their data by

f. Third-Party Services:
Our app does not share health-related data with any third-party services, advertisers, or external entities. We do not engage in the sale or exchange of user data.

Aggregated information

We may also convert your personal data into anonymous data and use for PhD research projects with our partnered academic institutions or for use in statistical analysis, platform improvements or efficiency gains.

Anonymised aggregated personal information does not personally identify you or any other user of Hexis and is therefore not personal data.‍

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information and services that you request from us or we think will be of interest to you because it is relevant to your individual training and nutrition plan.

To provide you with information about other services we offer that are similar to those that you already utilise, been provided with or enquired about.Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.

We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations.‍

Our Legitimate Business Interests

We have a number of lawful reasons that mean we can use your personal information, including your consent, where you give it. One lawful reason is something called ‘legitimate interests’. In general terms, “Legitimate Interests” means we can process your personal information if:

- We have a genuine and legitimate reason; and
- We are not harming any of your rights and interests.‍

Consent

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

Other Uses we will make of your data:

- Use of our platform;
- To notify you about changes to our service;
- To ensure that content from our site is presented in the most effective manner for you and for your computer; and
- To allow us to generate the best health, nutrition and performance plans and recommendations for our users via personalised fuel plans, live energy management, tailored energy and macronutrient recommendations, as well as intelligent coaching and carefully crafted recipes.

We will use this information:

- To administer our platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our platform to ensure that our service is provided in the most effective manner for you and for your phone;
- As part of our efforts to keep our platform safe and secure;
- To make sure the best and most accurate nutrition and training advice is given to you;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
- To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.‍

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie notice Cookies Policy.‍

Disclosure of your information inside and outside of the EEA

There are certain third parties we work with to help us deliver you the best service we can. In order to achieve this we will share your personal information with:

- Amazon Web Services, a secure cloud services platform. See https://aws.amazon.com/privacy/.
- Google Cloud, an online storage cloud where we store files and documents. See https://policies.google.com/privacy?hl=en-US.
- Point, a wearable data aggregator that allows us to integrate your wearable data. See https://www.areyouonpoint.co/privacy-cookies.
- Nutritics, a nutrition analysis software that allows us to analyse the nutritional information of foods and drinks. See https://www.nutritics.com/en/privacy-policy.
- Xero, accountancy software that allows us to manage our accounts and billing. See https://www.xero.com/uk/about/legal/privacy/.
- Stripe, an online payment processing platform that allows us to manage and process customer payments. See https://stripe.com/privacy.
- Zoho Creator, an automation tool that allows us to build databases. See https://www.zoho.com/privacy.html & https://www.zoho.com/gdpr.html.
- Slack, a developers and team collaboration tool. See https://slack.com/intl/en-gb/privacy-policy.
- Webflow, where our website is hosted and supported. See https://webflow.com/legal/privacy.
- Atlassian Jira, a planning and tracking tool for software development. See https://www.atlassian.com/legal/privacy-policy.
- Render, a secure cloud services platform. See https://render.com/privacy.
- Supabase, a hosted database platform and authentication service. See https://supabase.com/docs/company/privacy.
- PostgreSQL, a database system. See https://www.postgresql.org/about/policies/privacy/.
- Business partners, academic institutions & suppliers for the provision of Hexis' service to you.
- Analytics and search engine providers that assist us in the improvement and optimisation of our platform.

We will disclose your personal information to third parties:

- If we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
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- If Hexis, Applied Behaviour Systems Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
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- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of service, website terms of use and other agreements; or to protect the rights, property, or safety of Hexis, Applied Behaviour Systems Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store and process your personal data

The data that we collect from you is stored on Stripe and Supabase cloud servers within the European Economic Area (”EEA”). All information you provide to us is stored on these secure servers and any payment transactions are encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Data will be held in servers in Europe however may be accessed by remote staff working outside the EU, however such staff will be given appropriate training and only access to personal data as far as it is necessary to perform their roles.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

The GDPR provides you with the following rights. To:

- Request correction
of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

- Request erasure
of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

- Object to processing
of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

- Request the restriction of processing
of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

- Request the transfer
of your personal information to another party in certain formats, if practicable.

- Make a complaint
to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

Access to information

The Data Protection Act 2018 gives you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.

Your right of access can be exercised in accordance with the Act.

A subject access request should be submitted to our Data Protection Officer. No fee will apply as laid down by The Data Protection Act 2018.

Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

Contact

We hope that we have shared with you all the information you need, but in the event that we haven’t, or if you have any questions then please do not hesitate to contact our Data Protection Officer, Michael Blakeley on mike@pangolindpc.co.uk

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