Last updated: 26/7/24
We at Sarvas respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our services. Our services include the provision of website content (regardless of where you visit the website from), the ability to download and use the Sarvas app in conjunction with the Sarvas platform and the related analysis and content services that we provide via our software (the “Services”). This privacy policy tells you about your privacy rights and how the law protects you.
We comply with the principles relating to Processing of Personal Data set out in relevant data protection laws, which require Personal Data to be:
We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).
This privacy policy aims to give you information on how Sarvas Health Ltd collects and processes your personal data through your use of our Services, including any data you may provide through use of our Services.
Our Services are not intended for children (which we treat as individuals under the age of 18) and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Sarvas Health Ltd is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at sarvas.health@gmail.com.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our Services may include links to third-party sites, plug-ins and applications. This includes any third party payment processor when you input your financial data. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party sites and are not responsible for their privacy statements. When you leave our website or our Sarvas app, we encourage you to read the privacy policy of every other site or app you visit.
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).
When you use our Services we may collect, use, store and transfer different kinds of personal data about you. The personal data will depend upon which of our services you are using. This may include Special Categories of Personal Data. We have grouped the different types of personal data together as follows:
Currently we use Amazon Web Services (AWS) as our cloud hosting providers, using data centres within the European Economic Area. All your data stored in Amazon data centres is encrypted.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a Service you have with us but we will notify you via your email address if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before processing any Special Categories of Personal Data or sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent at any time by contacting us.
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
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To register you as a new user on the app and platform |
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To process and deliver the Services including:
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To manage our relationship with you which will include:
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To record your fitness test and feedback performance information to you |
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To enable you to partake in a prize draw, competition or complete a survey |
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To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
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To make suggestions and recommendations to you about goods or services that may be of interest to you |
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We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or Services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/Service purchase or other transaction.
We use cookies on this site. By using the site you are indicating that you are approving our use of cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. If you wish to know which cookies are used, please contact us directly via our customer service contact.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. With the exception of our third party card processor, we do not allow our third-party service providers to use your personal data for their own purposes. We only permit any third party processor to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the United Kingdom or the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach.
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.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us via email at sarvas.health@gmail.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Service providers acting as processors based in the EU who provide IT and system administration and payment services.
In rare circumstances, our professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the EU who provide professional services.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Controller: the person or organisation that determines when, why and how to Process Personal Data.
Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.
Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. A DPIA can be carried out and should be conducted for all major system or business change programmes involving the Processing of Personal Data.
DPA 2018: the Data Protection Act 2018.
Data Protection Officer (DPO): the person required to be appointed in specific circumstances under the GDPR. Where a mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the organisation’s data privacy team with responsibility for data protection compliance.
GDPR: the General Data Protection Regulation ((EU) 2016/679).
Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably possess. Personal Data includes Special Categories of Personal Data.
Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.