Information we may collect from you
We may collect and process the following data about you:
- Information you give us (Submitted information): You may give us information about you by filling in forms when you register to download or register to use COVI-PASS and/or the APP and/or use the Services or by corresponding with us (for example, by e-mail). The information you give us may include your name, address, e-mail address and phone number, mobile phone number, age, username, password and other registration information, demographic information, personal description and photograph.
- Information we collect about you and your device. Each time you visit COVI-PASS or use the App we may automatically collect the following information:
- technical information, including the type of mobile device you use (“Device”), a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting (“Device Information”);
- information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content, checkins (Content Information);
- details of your use of any of the App or your visits to COVI-PASS including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access, including the nature of the content that is viewed, related transfer rates, length of viewing, which pages are viewed and other similar data (Log Information).
- Information we receive from other sources (Third Party Information). We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
- Unique application numbers: When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us
Uses made of the information
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and Services that you request from us;
- if you have previously agreed, to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you with information about third party goods or services we feel may be of interest to you. We will only contact you by electronic means (i.e. via the APP, e-mail, SMS or via the VPortal) if you have consented to this at the time that you register to use the APP. If you do not want us to use your data in this way, you can withdraw your consent at any time however this may mean that you can no longer access some or all of the Services;
- to notify you about changes to our Services;
- to ensure that content from the Website and the App is presented in the most effective manner for you and for your computer or Device.
Information we collect about you.
We will use this information:
- to maintain, administer and monitor the Services in order to analyze trends, improve the overall quality of the Services, tailor the Services to your needs and respond to your inquiries. Such analysis and information is aggregated across users, does not identify you as an individual and does not link to any personally identifiable information;
- to administer the Website and the App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve the Website and the App to ensure that content is presented in the most effective manner for you and for your computer;
- as part of our efforts to keep the Services safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of the Website and the App about goods or services that may interest you or them.
Information we receive from other sources.
We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may share your information with selected third parties including:
- business partners, suppliers and sub-contractors who provide Services on our behalf; and
- affiliate brands, advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our affiliate brands and/or advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have scanned their VCode on any given day). We may also use such aggregate information to help our affiliate brands and/or advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our affiliate brands’ and/or advertisers’ wishes by displaying their offers, rewards and/or other advertisements to you (if you are part of their target audience.
We may also disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if EMBT 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;
- if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; or
- in order to:
- enforce or apply the App Terms and Conditions and other agreements or to investigate potential breaches; or
- protect the rights, property or safety of EMBT, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Protection of Minors.
EMBT does not permit anyone under the age of 16 to register to use the Website, App or Services or use any of its functionality for which registration is required. If you are under 16 please do not register to use the Website, App or Services. If you do register and we find out that you are under 16 your account will be deleted. If you are between the age of 16 and 18 your registration must be with the permission of your parent or guardian. If you do not have such permission please do not register. If the event that we find out that you are between the age of 16 to 18 and you do not have such permission your account will be deleted. The above relates to direct registration with EMBT or through any third party social media site.
NOTE TO PARENTS AND GUARDIANS. If you become aware that your child has provided us with personal information without your consent, please contact us at [email protected]. EMBT do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take all reasonable steps to remove such information and terminate the child’s account.
Cookies and Log Information.
EMBT may use your username and email address to provide you with email newsletters, announcements, EMBT news about products and/or services and information about your user account. If you did “opt in” at registration and no longer wish to receive these kinds of marketing communications, you may “opt out” by unchecking the email newsletters and announcements within your user profile.
Linking to third party websites
COVI-PASS and/or the APP may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
Where we store your personal data
International data transfers
All information you provide to us is stored on our secure servers.
On subscribing to use the Services you will able to make purchases of various goods and services. All transactions at this present time are serviced exclusively through our chosen third-party provider of payment processing services using encrypted software. We do not collect or store any of your credit or debit card information.
Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the APP or certain Services, 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 or via the any websites, COVI-PASS and/or the APP; 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.
Your Rights under applicable data protection laws.
Your rights under the applicable data protection law as at 1 June 2018 are as follows:
- The right to be informed about the processing of your personal data;
- The right to have your personal data corrected or completed if it is inaccurate or incomplete;
- The Right to object to the processing of your personal data;
- The Right to restrict the processing of your personal data;
- The Right to have your personal data erased;
- The right to request access to your personal data and information about how it is processed;
- The Right to move, copy and or transfer your personal data;
- The Right to object to automated decision making including profiling.
We will seek to deal with any request or complaint with regard to Our dealings with your personal data within 28 days of formal notification from you.
You have the right at any time to complain to the Information Commissioners Office at ico.org
EM Bio-Tech Kilronan House, Church Road, Malahide, Dublin, K18 RW36, Ireland