We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of personal data and other information we may collect from you or that you may provide (“Personal Information”) on the “Phaze” mobile application (“Mobile Application”), coach.phaze-app.com coaching hub (“Platform”), and any of their related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.
This Policy is a legally binding agreement between you (“User”, “you” or “your”) and Phaze Shift Ltd (doing business as “Phaze”, “we”, “us” or “our”). If you are entering into this Policy on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this Policy, in which case the terms “User”, “you” or “your” shall refer to such entity.
If you do not have such authority, or if you do not agree with the terms of this Policy, you must not accept this Policy and may not access and use the Services.
By accessing and using the Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
For the purposes of this Privacy Policy:
You can access and use the Services by providing certain Personal Information (for example, your name and email address) that can be used to contact or identify You. We receive and store any information you knowingly provide to us when you create an account, or fill any forms on the Services. When required, this information may include the following:
– Account details (such as user name, unique user ID, password)
– Contact information (email address)
– Basic personal information (such as name and date of birth).
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Services by or through a mobile device, We may collect certain information automatically and store it in log files. This may be information including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Services or when You access the Services by or through a mobile device.
Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Services. This statistical information is not otherwise aggregated in such a way that would identify any particular User of the system.
In order to provide features of the Application, while using the Application and with Your explicit consent we may collect Your sleep data using integrations with third-party applications.
Our Application has integrations with Apple Health Kit (HK) and Google Health Connect (HC) and uses the data in the following limited way:
Pictures and other information from your Device’s camera and photo library may also be collected with your prior Consent.
We use this information to provide features of our Services and to improve and customise our Services. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on Your device.
You can enable or disable access to this information at any time through Your Device settings.
We act as a data controller and a data processor when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information.
We act in the capacity of a data processor in situations when you submit Personal Information through the Services.
In order to make the Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services.
The Company may use any of the information we collect from you for the following purposes:
Processing your Personal Information depends on how you interact with the Services. We rely on the following legal bases upon which we collect and process your Personal Information:
We may also combine or aggregate some of your Personal Information in order to better serve you and to improve and update our Services.
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases above.
In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Services change. If you would like to delete your Trip Schedule data or permanently delete your account, you can do so from the Account Management section on the Application.
However, when you delete Personal Information, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our contract obligations to our partners, and for the purposes described below under Retention of Information.
Users of the Phaze Coaching Hub can close their account by emailing hello@phaze-app.com to request that we close their account. You have the right to request the deletion or removal of Your Personal Information or to restrict the processing of Your Personal Information where there is no compelling reason for its continued processing. When processing is restricted, Your Personal Information may be stored, but not further processed. Restriction could involve measures such as transferring data to a separate system, or limiting the access through the use of passwords and other access controls.
Where the complete deletion of Your Personal Information is not technically possible, we will ensure that we take adequate steps to secure and store Your Personal Information so that it is beyond use.
Depending on the requested Services or as necessary to complete any transaction or provide any Services you have requested, we may share your information with our contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information.
We will not share any information with unaffiliated third parties.
Service Providers are not authorised to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorise them to use or disclose any of the provided information for their own marketing or other purposes.
The Service Providers we use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Services in accordance with their Privacy Policies.
We use third-party Service providers to monitor and analyse the use of our App. We use the information obtained from these analytics tools to monitor the performance and improve our App. We do not use third-party analytics tools to track or to collect any personally identifiable information of our Users and we will not associate any information gathered from the statistical reports with any individual User.
Firebase is an analytics service provided by Google Inc. Google Analytics for Firebase uses device identifiers to collect and store information.
We use Firebase Analytics to collect anonymised, non-personal information about how our app is used, such as aggregated usage statistics (session numbers, device type, operating system, country, and app events). This data is not linked to any personally identifiable information, and we do not use it for profiling or individual tracking.
Currently, users cannot opt out of Firebase Analytics data collection via device or app settings; analytics collection is managed by the app and not by your device or operating system. If we introduce an opt-out option in the future, we will update this policy accordingly.
For more information on what type of information Firebase collects, visit the ‘How Google uses information from sites or apps that use our services’ webpage: https://policies.google.com/technologies/partner-sites.
We also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245
We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
All payments for our Direct-to-Consumer (D2C) services are processed securely via Stripe. We do not handle, store, transmit, or have access to your payment details at any time. By choosing to purchase our services, you are required to agree to Stripe’s own Terms & Conditions (https://stripe.com/legal/consumer) and Privacy Policy (https://stripe.com/privacy), which govern the handling of your payment information.
After payment via Stripe, you will receive a unique user ID and access to the selected service(s) for 12 months. At the end of the 12-month period, you may choose to purchase a new 12-month subscription. If you do not renew, your access to the service(s) will cease on the day after your subscription ends.
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, as long as your user account remains active, until the Services are fulfilled, to enforce our Policy, resolve disputes, and unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
You can find full details about our data retention and data deletion processes in the Phaze Data Retention Policy.
Depending on your location, data transfers may involve transferring and storing your Personal Information in a country other than your own, including the EU. Where required by applicable laws, we will ensure that such transfers are based on appropriate legal grounds, including obtaining your explicit consent or implementing necessary safeguards to protect your Personal Information.
You are entitled to learn about the legal basis of such transfers and the measures we take to ensure the security of your Personal Information.
If you would like more details, please refer to the relevant sections of this policy or contact us using the information provided. We are committed to protecting your Personal Information and complying with applicable data protection laws when processing personal information across different jurisdictions.
Out of respect for your privacy, we have implemented additional measures to comply with the obligations and rights associated with the collection of Personal Information as dictated by the laws governing the regions of our users.
Disclosures for residents of the UK and the EU/EEA
If you are a resident of the United Kingdom (“UK”) or European Union (“EU”), the European Economic Area (“EEA”), you have certain rights in relation to your Personal Information based on the UK Data Protection Act 2018 and UK General Data Protection Regulation (GDPR) that we comply with as part of our commitment to your privacy. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in the UK GDPR.
(a) Right to withdraw consent: You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
(b) Right to access: You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.
(c) Right to rectification: You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.
(d) Right to object to the processing: You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.
(e) Right to restrict processing: You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether our legitimate grounds override your legitimate grounds.
Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or defense of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest.
(f) Right to delete: You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed.
However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or defense of legal claims.
(g) Right to data portability: You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.
(h) Right to complaint: You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority.
For more information, please contact your local data protection authority in the UK, EU or the EEA. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.
Other countries and general privacy rights
If you reside in a country not specifically mentioned in this policy, we are committed to protecting your personal data in accordance with internationally recognised privacy principles. Users from these regions may have rights similar to those outlined above and other data protection laws. These rights include:
– The right to access, correct, or delete your personal data.
– The right to restrict or object to certain types of processing.
– The right to withdraw consent for data processing.
– The right to data portability, where applicable.
– The right to opt out of targeted advertising and data sales, where required by law.
– The right to file a grievance with a relevant data protection authority.
– The right to nominate a representative to exercise your privacy rights on your behalf, if permitted by applicable regulations.
Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorised representative of such person.
If we receive your request from an authorised representative, we may request evidence that you have provided such an authorised representative with power of attorney or that the authorised representative otherwise has valid written authority to submit requests on your behalf.
You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Services, please contact us to request that we delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
Cookies are small text files that websites place on your computer or device to store information about Your visit. They help websites remember your preferences, enhance functionality, and provide a more seamless user experience.
The Phaze Coaching Hub website uses cookies to improve Your browsing experience and remember Your cookie preferences. By using our website, You consent to our use of cookies in accordance with this policy.
Both the PHPSESSID and coach_token cookies are categorised as Necessary cookies. These cookies are essential for the operation of the Coaching Hub website and enable core functionality such as security, authentication, and session management. For this reason, they cannot be rejected or disabled by users through the cookie preferences panel.
Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from users who use or visit a website or online service as they move across different websites over time.
How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information. For a description of Do Not Track protocols for browsers and mobile devices or to learn more about the choices available to you, visit internetcookies.com
We offer push notifications to which you may voluntarily subscribe at any time. To make sure push notifications reach the correct devices, we rely on a device token unique to your device which is issued by the operating system of your device. While it is possible to access a list of device tokens, they will not reveal your identity, your unique device ID, or your contact information to us. We will maintain the information sent in accordance with applicable laws and regulations.
If, at any time, you wish to stop receiving push notifications, simply adjust your device settings accordingly.
The Services may contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Services and to read the privacy statements of each and every resource that may collect Personal Information.
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorised access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that
(a) there are security and privacy limitations of the Internet which are beyond our control;
(b) the security, integrity, and privacy of any and all information and data exchanged between you and the Services cannot be guaranteed; and
(c) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.
In the event we become aware that the security of the Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities.
In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will send you an email. In jurisdictions where required, we may also report the breach to relevant authorities in accordance with applicable data protection regulations.
Our Services are governed by the laws of England and Wales. The Courts of England and Wales will have jurisdiction to settle any disputes which may arise out of or in connection with this Privacy Policy.
We reserve the right to modify this Policy or its terms related to the Services at any time at our discretion. When we do, we will revise the updated date at the top of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorised to access or use the Services.
If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:
Phaze Shift Ltd,
9a Denmark Terrace
Brighton
England
BN1 3AN
https://phaze-app.com/contact-us
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.
If you believe your concerns have not been adequately addressed, you can also complain to the Information Commissioner’s Office (ICO).
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113