Privacy Policy

Last update: 07 December 2022

IMPORTANT INFORMATION AND WHO WE ARE

Introduction

Sense-IT Limited is a private limited liability company registered in terms of the laws of Jersey, with registration number 129850, and registered office at No. 2, The Forum, Grenville Street, St Helier, JE1 4HH, Jersey.

Sense-IT currently trades as Parent Sense / Parent Sense app.

Sense-IT provides information and guidance through a mobile application to assist expecting mothers through their pregnancy and first year of caring for their baby. This Privacy Policy applies to your access to the Parent Sense mobile application (the “app”) and our website(s), the website currently located at www.parentsense.app, as well as any other media form, media channel, mobile website, mobile application or other website related, linked, or otherwise connected thereto (collectively, the “Site”).

We respect your privacy and are committed to protecting your personal data. This Privacy Notice sets out how we receive, collect, use, disclose, store, process, transfer and delete your personal data (including personal data in respect of individuals who are members, subscribers, visitors, service providers and suppliers, intermediaries or other third parties, or any individual connected to these parties) in terms of the applicable data privacy laws including the Data Protection (Jersey) Law 2018 (“DPJL”), the General Data Protection Regulation (2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”) or the UK Data Protection Act, 2018, applying and supplementing the UK GDPR (where applicable). This Privacy Policy also sets out your privacy rights and explains how the law protects you.

Should you have any questions on the content of this Privacy Notice or how we use your data, please contact us by email on [email protected].

About us

As mentioned above, Sense-IT Limited is a private company trading as Parent Sense. This Privacy Notice is issued on behalf of Sense-IT and so when we mention “Sense-IT”, “Parent Sense”, “we”, “us” or “our” in the Privacy Notice, we are referring to Sense-IT Limited.

Changes to the Privacy Notice

This version of our Privacy Notice was updated on the date reflected above. Historic versions can be obtained by contacting us. We may update our Privacy Notice from time to time, and we will alert you thereto by reflecting the date of the most recent update. It is your responsibility to periodically review this Privacy Notice.

Your duty to inform us of changes

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.

Contact us or your local data protection authority

If you have any queries, require further information or wish to exercise any the rights set out in this Privacy Notice, please contact us at

We are registered as a Controller under the Data Protection (Jersey) Law 2018.

The Jersey Data Protection Authority, the Jersey Office of the Information Commissioner (the ‘JOIC’), can be contacted as follows:

Telephone: +44 (0)1534 716530

Physical Address: 2^nd Floor, 5 Castle Street, St Helier, Jersey, JE2 3BT

Website address: www.jerseyoic.org

Email: [email protected]

You have the right to make a complaint at any time to the JOIC or the authorities listed below, where applicable.

If you live or are based in the UK, you may submit your complaint to:

The Information Commissioner’s Office (“ICO”)

Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113

ICO website: https://www.ico.org.uk

If you live or are based in the European Economic Area (“EEA”), please refer your complaint to your local supervisory authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

We would, however, appreciate the opportunity to deal with your concerns before you approach any relevant authority, so please contact us in the first instance.

THE DATA WE COLLECT ABOUT YOU

The data we collect

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).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, age, gender and geographical location.

Contact Data includes postal address, email address, and telephone numbers.

Special Categories of Personal Data includes –

Pregnancy Data: due date, your photo, your uploaded pictures, diary entries and memories, doctor’s visits, weight, blood pressure, fetal heart rate, time and date of appointments, name and profession of health care provider, your breastfeeding data, and similar data.

Your baby’s data: gestational age, date of birth, age, name, weight, photo, developmental milestones, growth data, sleep habits, feed method, eating habits, behaviour, number of diapers, medication data, vaccination data, doctors’ visits and similar appointments, and similar data.

Health data including your baby’s vaccination status, weight and teething status.

Other data: your relationship to the baby.

Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details or services we have provided to you.

Marketing and Communication Data includes your preference in receiving marketing from us and our third parties and your communication preferences.

Browser Data includes your public IP address, your browsing behaviour and history (including cookies).

If you create an account (membership or subscription) and provide us your explicit consent, we will securely store your data. That way we can ensure you are securely backed up.

Other sensitive data

We ask that you do not send us or disclose to us other sensitive personal data, such as social security numbers, identity numbers, information related to racial or ethnic original, political opinions, religion or other beliefs, or any information regarding your or the baby’s health, biometrics or genetic characteristics which we do not ask for.

Cookies policy

“Cookies” are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow it) that enables the Site or service provider’s systems to recognize your browser and capture and remember certain information.

For instance, we use cookies to –

help us remember and process the items in your shopping cart;

help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services; help us compile aggregate data about Site traffic and Site interaction so that we can offer better Site experiences; and keep track of advertisements. Refer to the below mentioned Google Adwords and Remarketing section.

We may also use trusted third-party services that track this information on our behalf. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser’s (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies. If you turn cookies off, some features will be disabled and some of our services may not function properly.

If you fail to provide personal data

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 the data when requested, we may not be able to perform the contract we have or are trying to enter into with you, and in this case, we may be unable to provide you with the services or to provide you access to our Site. Should you decide not to provide certain optional data to us, we may not be able to optimise our services to you and you may not be able to make full use or draw full advantage of our services.

HOW AND WHEN WE COLLECT YOUR DATA

We collect Identity Data, Contact Data and Marketing and Communication Data when you register for our newsletter, create an account on our website as a member, or download or subscribe to our app, as well as when you update any of the mentioned data manually. When you subscribe to our app or purchase any products through our Site, we may also collect the Special Category of Personal Data, Financial Data and Transaction Data. These data categories are manually provided by yourself and collected by us through our systems.

When you access our Site, we may collect the Browser Data through cookies and other similar devices.

We may also collect information from you directly via personal meetings, email correspondence, telephone calls or other communications, where you choose to contact us via these means, and such correspondences may be shared amongst our staff.

Job Applications

In respect of any potential job applicants, information may be collected from a number of sources and may include CVs, education and employment history, references and background checks. We will use this information to assess your suitability for any vacancy and to determine how to progress your application. This information will typically be retained on our systems for up to six months after which time it shall be destroyed unless we have a legitimate reason for retaining your information for a longer period.

HOW WE USE YOUR DATA

We will always process your personal data lawfully for any of the following purposes:

To provide our services to you;
For processing payment transactions for services or products supplied to or by us;
For reporting personal data, app and course uptake and usage data to our corporate clients where you have made use of any app benefit provided to you by any of them;
Where is it necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; Where we need to comply with a legal or regulatory obligation;
Where the processing is necessary for legal proceedings, for obtaining legal advice or establishing, exercising or defending legal rights.

Generally, we do not rely on consent as a legal basis for processing your personal data save in respect of matters where we collect data relating to the Special Category of Personal Data, or other than in relation to sending third party direct marketing communications to you via email or text message. We will only

send this type of communication to you if you have provided us with your express consent. You have the right to withdraw consent to marketing at any time by contacting us.

The lawful basis for using your information and the purpose for which we use the information

The Identity Data and Contact Data are collected to create and manage your account, be it registration to our newsletter, registration on our website, or registration on our app. You can use your account to securely log into the Site. If you create an account with us, we will send you a welcoming email, communicate with you in response to your enquiries, and send you strictly service-related announcements or direct marketing communication if you have provided your consent thereto. Through our app we may send you in-app correspondence and push notifications. We comply with the CAN-SPAM Act.

You can upload the Special Categories of Personal Data to the app. The data is used to give you insight into and guidance on your pregnancy, your well-being, your baby’s development and health, and your parenting skills. We also use the data to provide you with personalised content, messages and tips. We do this by personalising the content you see on the app and to personalise the product offerings displayed to you, as well as by sending you emails, push notifications and in-app messaging.

The Financial Data and Transaction Data are collected in order to facilitate payment of subscription fees and any other purchases through our Site, and to keep record of the payments we have received from you.

The Marketing and Communication Data are collected to ensure that we know which information and communication you would like us to send to you, and that we communicate to you through your preferred methods. As mentioned, we will send you a welcoming email, communicate with you in response to your enquiries, and send you strictly service-related announcements or direct marketing communication if you have provided your consent thereto. Through our app we may send you in-app correspondence and push notifications.

We explain how we use the Browser Data when we explain how we use cookies.

We also use the data collected through our Site to manage and improve our services and content, and we may use the data collected for analysis, research, statistical and survey purposes. We may also monitor our advertising and marketing effectiveness through the analysis of the data we collect.

Change of purpose

We will only use the data we collected 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.

Disclosure of your personal data

We may have to share your personal data with the parties set out below for the purposes set out above:

Third parties acting as processors of data who may be based outside the EEA;
Professional advisers acting as processors including lawyers, auditors and insurers who may be based outside the EEA, who provide consultancy, legal, insurance or accounting services;
Financial, taxation, regulatory or judicial authorities, state agencies or public bodies, on request and to the extent that may be required by law;
our corporate clients with whom you have taken up the app benefit; and
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same manner as set out herein.

We require all third parties to respect the security of your personal data and to treat it in accordance with the applicable data protection law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

To protect your privacy, we do not sell, trade, or otherwise transfer to outside parties your personally identifiable information, but we do share your digital footprint with such parties.

International transfers

Our Site is available for use, and is supported by teams physically situated, in different jurisdictions.

When we share your personal data within our company and between the different teams or support staff, this may involve transferring your data outside the EEA. We ensure your personal data is protected by requiring all persons involved to follow the same rules when processing your personal data to ensure a similar degree of protection is afforded to your data at all times.

In certain circumstances we may also transfer your data to third party service providers that support the operation of our business (such as providers of software and cloud computing services) and who may be located outside the EEA. In relation to jurisdictions in which the European Commission has recognised an adequate level of protection, we will rely on this finding. If no such recognition

has been provided then we would seek to ensure that your data is adequately protected, for example where the European Commissions Standard Contractual Clauses can be used, the entity is Privacy Shield certified, or we can rely on an appropriate derogation which may include the provision of legal advice.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

OUR MARKETING POLICY

Google Analytics

We use all features of Google Analytics for Display Advertisers (‘banner advertising’, i.e., the advertisements displayed on websites), to display content specific advertisements (“ads”) to visitors that have previously visited our Site when those visitors go to other websites that have the Google Display Network implemented.

Parent Sense and other third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitor’s past visits to our Site.

This entails obtaining specific visitor cookie data, such as the source, medium and keyword used to visit our Site. Google Analytics does not store any personally identifiable information and we will not use personally identifiable information in any way related to Google Analytics, Google Adwords, and Remarketing.

We take your privacy very seriously. We feel that certain data should always be kept private, so we’ve developed restrictions around the types of ads where we don’t allow remarketing. When creating remarketing lists based on non- personally identifiable criteria, we won’t use any sensitive information about users. This includes information such as their financial status, sexual orientation, and other sensitive categories.

Where you have chosen to enable Google to associate your web and app browsing history with your Google account, and to use information from your Google account to personalize ads, Google will use data from its signed-in users together with the Google Analytics data to build audience lists for cross-device remarketing. Google Analytics will collect Google-authenticated identifiers associated with users’ Google Accounts (and therefore, personal information). Google Analytics will temporarily join these identifiers to the Google Analytics data in order to support specific audiences. This means that, if you visited a website using a mobile device and became a part of a remarketing campaign, you would see personalised ads with any type of device associated with your Google account.

As AdWords advertisers, we are restricted from and will not perform the following actions:

Running ads that collect personally identifiable information, including, but not limited to, email addresses, telephone numbers, and credit card numbers; and

Creating a remarketing list or creating ad text that specifically targets users in ways that are outlined as “prohibited”.

You can opt out of Google Analytics for Display Advertisers and opt out of customized Google Display Network ads, by visiting the Ads Preferences Manager in your browser.

Internet-based advertising

We make use of Google Adwords Remarketing to advertise our Site across the internet, in particular on the Google Display Network. This means we use Google Adwords Remarketing to advertise on third party websites to you after you visited our Site. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Site.

Adwords remarketing will therefore display ads to you based on what parts of our Site you have viewed, by placing a cookie on your web browser. These cookies allow third parties to identify what you find popular, allowing a more personalised and relevant selection of advertisements to be displayed when you browse the internet. They normally won’t just be from us, but build an overall, but anonymous, picture of your preferences based on how you have browsed the internet, in order to deliver more relevant advertising. You may see internet- based advertising on our Site, but also on third party websites which uses information collected about your browsing activity on our Site.

You can opt-out of Google Adwords Remarketing by visiting Google’s Ads Settings page. You can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page. If you need any guidance on doing this, please do not hesitate to contact us.

DoubleClick Remarketing

We make use of the online marketing tool called DoubleClick by Google. DoubleClick uses cookies in order to activate ads relevant to you, improve advertising campaign performance reports, and prevents you from seeing the same ads more than once.

DoubleClick collects the time and date you saw an ad, your IP address, the unique identity of the ad, the website on which you saw the ad, and the part of the website on which you saw the ad.

If you click on an ad a cookie will be set on your browser. This is designed so that the company that advertised will know if you then, after seeing an advert, went on to buy the product.

On its own, this data can tell DoubleClick how many times you have seen an ad and, for example, which country’s version of the ad you need to see. The information collected forms a set of data about the IP address to provide more relevant ads to you according to your browsing and clicking history.

We do not have any influence on the scope and further use of the data collected by Google through DoubleClick and therefore inform you according to our level of knowledge, and you can view their policies on the support.google.com website under Google Ad Manager.

To check what data DoubleClick has collected on you, you can go to Google’s ad references manager (you don’t have to be signed in to Google). If you don’t want to be tracked by DoubleClick you can visit the activity controls section of your account page on Google, unticking the box marked “Include Chrome browsing history and activity from websites and apps that use Google services”, or follow any of these options:

set your browser software accordingly, in particular the suppression of third party cookies means that you will not receive any ads from third party providers;

disable cookies for conversion tracking by setting your browser to block cookies at adssettings.google.com, which will be deleted when you delete your cookies;

disable the interest-based advertisements from providers that are part of the “About Ads” self-regulation campaign via the link https://www.aboutads.info/choices, whereby this setting is deleted if you delete your cookies;

permanently deactivate cookies in your browsers Firefox, Internet Explorer or Google Chrome via the link https://www.google.com/settings/ads/plugin. Please note that in this case you may not be able to use all functions of our Site in full.

DATA SECURITY

We have put in place appropriate security measures, such as encryption, 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 where we are legally required to do so.

Should you become aware of any actual or suspected breach in the security of your personal data, you are requested to immediately notify us in writing by sending us an email to [email protected].

Third-party links

Our Site may include links to third-party websites, plug-ins and applications. 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 websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the Privacy Notice of every website you visit.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we will 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 requirements.

Our policy is to retain personal data in relation to a person who is a member only until such person terminates his or her account, and in relation to a person who is a subscriber, only until such a person terminates his or her subscription, or for so long as may be required by data protection laws and other regulatory requirements (in the local jurisdiction where services were provided), whichever is the later.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for analysis, research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Requesting access to your personal data (commonly known as a “data subject access request”) enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

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 may refuse to comply with your request in certain 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 four weeks. Occasionally it may take us longer than four weeks 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.

Requesting 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.

Requesting 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.

Objecting 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.

Requesting 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:

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;
where 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; or
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Requesting 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.

Withdrawing consent 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. You can withdraw your consent under the account settings function on our app, or by sending us an emailing withdrawing your consent.

GLOSSARY

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We may use your data in pursuing our legitimate interests in carrying on the business of a pregnancy and infant guidance and information service. 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 overruled 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.

“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.