AlcoChange® Privacy Policy – Version 1.6
Updated date: 24 Apr 2023
At CyberLiver® Ltd, we value your privacy and take the protection of your personal data seriously. As the owner, controller, and operator of AlcoChange® (iOS & Android) (the App), we are dedicated to safeguarding your personal data. This Privacy Policy is intended to inform you about how we handle and protect your personal data when you use the App.
If a user registers for CyberLiver®’s products and services, CyberLiver® will act as the data controller for any personal data collected using these products and services.
You can view the Terms of Use for AlcoChange® here https://alcochange.cyberliver.com/dtx-terms-and-conditions
This Privacy Policy aims to provide details on how CyberLiver® collects and processes your personal data when you interact with us, including through the App.
In addition, this policy outlines your legal rights concerning the use, access, and correction of your personal data. If you disagree with the data practices outlined in this Privacy Policy, we advise you to refrain from using the App. By using the App, you are presumed to have accepted and agreed to the terms outlined in this Privacy Policy.
Controller and contact details
CyberLiver® Limited (company number: 8052630) is the data controller responsible for your personal data (collectively referred to as CyberLiver®, we or our in this Privacy Policy).
To address any inquiries you may have about this Privacy Policy or how we handle your information, we have designated a Data Protection Officer (DPO). You can contact our DPO by emailing [email protected] or sending a letter to CyberLiver®, Attn: Privacy, First Floor, Burnells, 5 Garland Road, Stanmore, Middlesex, HA71NR, UK.
Changes to the Privacy Policy
We keep this Privacy Policy under regular review. We will post any changes to this Privacy Policy on this page. If the changes are significant, we will provide more prominent notice by sending you a notification in the App, and you may be required to read and accept the changes to continue your use of the App.
While we notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically. Historic versions can be obtained by contacting us.
The personal data that we hold about you must be accurate and current. Please keep us informed if your personal details change during our relationship.
Information About Children
The App is not intended for or targeted at children under 18; we do not knowingly or intentionally collect information about children under 18. If you believe we have collected information about a child under 18, please get in touch with us at [email protected] so we may delete the information.
Third-Party Links
The App may include links to third-party websites, plug-ins and applications. Clicking or enabling those links may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the App, we encourage you to read every website’s privacy policy.
Third-Party Devices
The app might be connected to third-party devices and sensors.
Users can Sign up for CyberLiver® from our apps or add a clinical user from a dashboard. When you visit the App Store or Play Store and signup to use the App, we will request that you provide personal data about yourself (including first name, last name, date of birth, email address, weight, height and gender) and you will also be asked to create a unique password.
You may upload a profile photo to your account within the App either when you sign up to the App or at any time when you use the App. You do not have to upload a profile photo, and you can remove your profile photo at any time.
When You Use the App
You will be asked to supply personal and special category data when using the App. We will use this information to enable the use of our services.
Personal Data
This refers to any information that you voluntarily submit to us when you signup and Use the App, and that identifies you personally, including contact information, such as your first and last name, e-mail address, date of birth, gender, location (including postcode and country) height, weight, weekly drinking average, and other information about yourself which you’ve provided.
Special Category Data
Special category data also includes your digital biomarker data and health-related data measured through sensors and services through the AlcoChange® app including your abstinence, alcohol consumption, nutrition (food, fluid etc.,), sleep activity, physical activity, drink location, coping strategies, triggers, personal interests (ex., music, sports, etc.,) and time stamp of the activities in the App.
Optional access to Name and contact number of supportive friends or family from phone contacts or phonebook.
Permission to turn on notifications, Bluetooth (to connect breathalyser or wearable devices), and turn off battery optimisation to run the app in the background.
CyberLiver® Support bot
When using the CyberLiver® support bot inside the app, you will be asked to provide your name and email address for any technical support, and this information will be stored in our database. We will use this information to contact you to provide any technical support.
Log Files and Analytics Services
We may also collect information your browser, or App sends whenever you visit the App ( Log Data). This Log Data may include information such as your devices Internet Protocol ( IP ) address, device model, IMEI number, battery percentage, permissions, browser type, browser version, the pages of our Website or App that you visit, the time and date of your visit, and the time spent on those pages, mobile UDID, geo-localisation data, and other statistics. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
In addition, we use third-party services such as Google Analytics to collect, monitor and analyse this information to improve our App functionality and make your experience more enjoyable.
We may link the information stored within the analytics software to personal data you submit within the App. We do this to improve your services and our marketing, analytics and site functionality.
Information we collect from third parties
In addition, when you use the App, we may collect your city location, precise and approximate location(optional), phone model and version, device identifier (or UDID ), OS version, and CyberLiver® account credentials.
We don’t collect your personal data from publicly available sources such as social media websites unless you specifically request support by posting your personal information on our social media handles and managed communities. We might use this information provided by you on social media and managed communities to help improve your services.
Location Data: We also use GPS technology to determine your current location. Some of our location-enabled services within the App require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to the use of your personal data. You can withdraw your consent anytime by disabling Location Data in your settings.
Legal Basis for Processing Personal Data
Our legal basis for collecting and using the personal data described above will depend on the personal data and the specific context in which we collect it. However, we will generally collect personal data from you only where we have your consent to do so, where we need the personal data 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. Sometimes, we may also legally be obligated to collect your personal data.
When you install the App, please register as a user and subsequently use the App and its features. You consent to us processing the personal data you have provided us under this Privacy Policy.
If we ask you to provide personal data to comply with a legal requirement, we will make this clear at the relevant time and advise you whether providing your personal data is mandatory (as well as the possible consequences if you do not provide your personal data).
We will rely on your consent to process any Special Categories of Personal Data you voluntarily disclose. You do not have to tell any Special Categories of Personal Data to use the App. By voluntarily providing Special Categories of Personal Data to us, we will proceed on the basis that you have given your consent to the processing of the Special Categories of Data disclosed to us.
If we collect and/or use your personal data in reliance on our legitimate interests (or those of any third party), this interest will usually be to operate our business and communicate with you as necessary to provide our services to you or for our legitimate commercial interest including, but not limited to
to deliver content to you;
reminders and digital behaviour change interventions;
improving your user experience by personalising the App;
responding to your user support requests and any queries that you raise with us or with any of our business partners;
registering you as a user;
managing our relationship with you, including notifying you via push notifications about changes to the App, to the terms of the App or this Privacy Policy;
improving our platform, products and services;
supporting our business operations and the App;
unless you tell us otherwise, undertaking marketing of any or all of the services that we provide (either directly or through our authorised third parties) and which we consider may be of interest to you and which we will notify you via push notifications in the App;
To monitor trends so that we can improve the App;
to detect or prevent illegal activities or where we need to comply with a legal obligation, or where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We send push notifications from time to time in the App as motivational messages to update you about your progress, events or promotions. You may turn them off at the device level if you no longer wish to receive such communications.
We will get your consent before sending direct marketing communications to you via email or text message. You can withdraw consent to marketing at any time by contacting us.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data. Please get in touch with us if you need details about the specific legal ground we rely on to process your personal data.
User Testimonials and Comments
We post user testimonials and comments on our App pages, Play Store, App Store, Social media promotions, websites, and portal, which may contain personal data. We obtain each user’s consent via email before posting the user’s name and testimonial.
Security of your Personal Data
We use various security technologies and procedures to help protect your personal data from unauthorised access, use or disclosure. We secure the personal data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All personal data is protected using appropriate physical, technical and organizational measures.
Social Media Features
The App might include Social Media Features, such as the Facebook/ Google Login and Facebook Like buttons and Widgets, such as the Share This button or interactive mini-programs that run in the App. These features may collect your IP address and which page you visit on our apps and set a cookie to enable the feature to function correctly. Social Media Features and Widgets are hosted by a third party or hosted directly on the App. This Privacy Policy does not apply to these features. The companies’ privacy and other policies govern your interactions with these features.
External Websites
The App may provide links to other websites. We do not control and are not responsible for the content or practices of these other websites. Providing such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.
Public Forums
Our App provides public message boards, blogs, and community forums that are accessible to all. Any information you disclose directly on these platforms may be collected and used by third parties. If you wish to have any posted information corrected or removed, please refer to the “Opting Out and Unsubscribing” section below for instructions on how to do so.
We Never Sell Personal Data
We will never sell your personal data to a third party.
Disclosing Personal Data
Per the terms and conditions agreed in the collaboration agreement between the collaborators of AlcoChange® real-world RCT, you agree that we may disclose your personal data to the collaborators.
Regulatory compliance
We might use your anonymised data to apply for regulatory compliance with our products in the future.
Service Providers
We may disclose your personal data to service providers who provide data processing services to us or whose services are integral to the delivery of our services to you (for example, to the provision of services to you according to a contract that you have entered into with us or to support the delivery of, provide functionality on, or help to enhance the security of the App), or who otherwise process personal data for purposes that are described in this Privacy Policy or notified to you when we collect your personal data.
Advisers
We may disclose your personal data to professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services. HMRC
We may disclose your personal data to HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who may require reporting of processing activities in certain circumstances. CyberLiver® Partners & Research
We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may interest you. We will only send you marketing information by email whilst you have opted into our marketing database.
We may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide user support. We work with experts within our organisation and trusted partners who might use the personal data collected from you to do analysis, research, and release the results in the public domain. We ensure the user identity is anonymised whenever the research results are published and not shared with any third party. We might use the collected personal data for research based on the consent received during sign-up.
We may contact you for consent if you want to participate in future research and sign a separate privacy and research agreement.
Corporate Events
We may share your personal data with third parties to whom we may sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your data like this Privacy Policy.
Compelled Disclosure
We reserve the right to use or disclose your personal data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
All third parties to which we disclose your personal data are prohibited from using your personal data except for the purposes for which that data has been disclosed to them, and they are required to maintain the confidentiality of your information.
International Transfers to third parties
Certain of our third-party suppliers are based outside the European Economic Area ( EEA ); therefore, their processing of your personal data will involve a transfer of data outside of the EEA. When we transfer your personal data from the EEA, we use the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal 1`mechanisms to safeguard the transfer.
Cookies
If you access your account in the App, we will use tracking technology to retain your login session. Otherwise, we do not use cookies or similar technologies when you use the App.
Advertising
We don’t partner with any third party to advertise in the App based on your personal preferences and data.
We don’t share or sell personal data to any third party for advertising or marketing.
Third-Party Tracking Technologies
We use third parties such as Google Analytics to track the user behaviour on the App. Those third parties may also use cookies, over which we have no control.
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed unauthorised, 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 are subject to a duty of confidentiality.
We have established procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data?
We will only retain your personal data as per the NHS (National Health Service) data retention policy to fulfil the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a more extended period in case of a complaint or if we reasonably believe there is a prospect of litigation in 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.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, or where it is not possible to delete your personal data, in which case we may use this information indefinitely without further notice to you.
We retain information derived from cookies and other tracking technologies under our cookies policy.
Reviewing, Correcting and Removing Your Personal Data
You have the following data protection rights:
You can request access, correction, updates or deletion of the personal data that we hold about you. You can ask us to delete or remove personal data where there is no good reason for us to continue 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). 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.
You can object to the 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 to 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 overrides your rights and freedoms.
You can ask us to restrict the processing of your personal data in the following circumstances:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful, but you do not want us to erase it.
You need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims.
You have objected to using your data, but we need to verify whether we have overridden legitimate grounds to use it.
You can request your personal data transfer to you or a third party. We will provide 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 you initially provided consent for us to use or where we used the information to perform a contract with you.
If we have collected and processed your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent.
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 or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.
To exercise any of these rights, please get in touch with us at [email protected]. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of our actions.
To Unsubscribe From Our Communications
You may unsubscribe from our communications by clicking on the “unsubscribe” link at the bottom of our e-mails, updating your communication preferences, or emailing us at [email protected]. Users cannot opt out of receiving transactional emails related to their accounts.
Visit us at https://cyberliver.com/ or write to us at
CyberLiver® Limited,
First Floor, Burnells, 5 Garland Road,
Stanmore, Middlesex, HA71NR, UK
If you have any questions about how we use your personal data or want to exercise your rights over your information, you can email our DPO at [email protected]
This policy was last updated on 24 Apr 2023. We may update it at any time.
Please refer to this page for the latest Privacy policy for AlcoChange®.
Please find the previous versions of the Privacy policy below.
Privacy Policy version 1.5 – 24 August 2022
Privacy Policy version 1.4 – 14 November 2021
Privacy Policy version 1.3 – 20 April 2021