Privacy Policy
Introduction
Welcome to Wittosis’s privacy policy.
MMK Tech Labs W.L.L (we, us and our) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website and/or mobile application (our Platform) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This policy (together with our terms of use and cookie policy) applies to your use of our website www.wittosis.com (Site) and our mobile application software (App), known as Wittosis which is made available via the Google Play store and the iTunes store, once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?]
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR RIGHTS
10. GLOSSARY
1. Important information and who we are
MMK Tech Labs WLL is a private limited company, registered in Bahrain under registration number 165719 - 1, and its registered office address is at Unit 53, Building 2415 Road 2831, Block 428 Seef District Kingdom of Bahrain.
Wittosis aims to provide a forum for people facing similar mental health challenges to meet with each other, share their experiences, recommendations, insights and understanding for such issues and generally support each other. We do this by enabling people to share their thoughts, feelings, personal health experiences and information with people with similar health conditions online using our Platform.
It is therefore important that you understand how we use and share your information through the use of our Platform.
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and processes your personal data through your use of our Platform.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Age Requirements. Our Platform is not available to individuals below the age of 18. We do not knowingly collect information from children under the age of 18 and if you are under this age you must not use our Platform. Please take your privacy seriously and do not provide false information regarding your age when you register. If we become aware that you are under 18 and using our Platform, we will terminate your user account and issue bans to your device.
Controller
MMK Tech Labs WLL is the controller and responsible for your personal data.
If you have any questions about this privacy policy, including any requests to exercise your rights, please contact us at info@wittosis.com.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name: MMK Tech Labs W.L.L
Email address: info@wittosis.com
You have the right to make a complaint at any time to the Personal Data Protection Authority of your residency (PDPA).
PDPAs and their contact details in the EEA (EU, Iceland, Liechtenstein, Norway):
https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
PDPA and its contact details in the UK:
https://ico.org.uk/about-the-ico/
PDPA and its contact details in Bahrain:
http://www.pdp.gov.bh/en/index.html
We would, however, appreciate the chance to deal with your concerns before you approach the PDPA so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our Platform 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 or plant cookies or other trackers on your device. We do not control these third-party websites, or applications and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every website or app you visit.
2. The data we collect about you
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 together as follows:
· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, nationality.
· Contact Data includes email address and telephone numbers.
· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform, including cookie data.
· Device Data includes the type of mobile device you use, 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.
· Profile Data includes your username and password, your interests, preferences, feedback and survey responses, photo image.
· Usage Data includes information about how you use our Platform.
· Communications Data includes your communication preferences and other communications data such as calls with our support centre.
· Data you provide to us includes the content, communications and other information you provide when you use our Platform, including when you sign up for an account, create or share content (i.e. make a post or create forum), your messages and communications with us and other users of our Platform. This can also include information in or about the content you provide, such as the location of a photo or the date a file was created.
· Networks and Connections includes the people, accounts, groups and pages you are connected to and how you interact with them.
· Data from other users or third parties includes content, communications and information that other people provide when they use our Platform. Anything we receive from third parties may be combined with information we already hold.
· We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
· We may collect Special Categories of Personal Data about you when you choose to add this information to your profile and when you use the Platform to make a post, comment or enter into private discussions with other users (this includes details about your health or mental health race, or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data). You have the option to share this information with other users of our Platform. You may remove this information from your profile or contributions at any time. We will obtain your consent in collecting this data.
We do not knowingly collect any information about criminal convictions and offences.
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 that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us, suspend your access to our Platform, or remove your account registered on our Platform, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
· Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by email. This includes personal data you provide when you:
· create an account on our Platform;
· subscribe to our service or publications;
· give us feedback or contact us.
· Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
4. How we use your personal data
We will only use your personal data when the law allows us to and where you have consented to the processing. Most commonly, we will use your personal data in the following circumstances:
· Where you have consented to it.
· Where we need to perform the contract we are about to enter into or have entered into with you.
· 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.
· Where we need to comply with a legal obligation.
Click here [LINK TO GLOSSARY, LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Research
We may also disclose data obtained from our Platform to academic institutions and research bodies for research purposes specifically related to mental health support. Any such data is anonymised before it is shared with any third parties and we assure you that any recipients of this data adhere to adequate standards of data security, ethical review, and privacy.
Cookies
We may use cookies and/or other tracking technologies to distinguish you from other users of our Platform, or the distribution platform (Appstore) and to remember your preferences. This would help us to provide you with a good experience when you use the Platform and also allows us to improve the Platform. For more information about the cookies we use, please see our cookie policy.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
1. Disclosures of your personal data
Our Platform allows you to connect and share your content, posts, comments, reviews and information publicly or with other users of our Platform. Please be mindful of your own privacy needs and the privacy needs of others as you choose who to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others.
We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
· External Third Parties as set out in the Glossary.
· 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 way as set out in this privacy policy.
When you submit a post or comment to our Platform, visitors to and users of our Platform will be able to see the content of your posts and comments, the username associated with your posts or comments, and the date and time you originally submitted the post or comment. Although some parts of the Platform may be private or quarantined, they may become public (e.g., if content you have shared in a one-to-one conversation is shared by another member without your consent) and you should take that into consideration before posting to our Platform.
When users view your profile they will be able to see information about your activities on our Platform, such as your username, prior posts and comments, any other information you link to your profile, and how long you have been a member of our Platform.
Please note that, even when you delete your account, the posts, comments and messages you submit through our Platform may still be viewable or available on our servers.
We require all third parties to respect the security of your personal data and to treat it in accordance with the 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.
There may be exceptional circumstances where we are required by law to make a disclosure of your personal data to certain internal third parties or authorities (for example, where information is provided that suggests an ongoing or potential threat against a child or vulnerable person). We may seek to notify you first where such a disclosure of your personal data is going to be made unless we are legally prohibited from doing so.
2. International transfers
Our partner in storing data for our services is Amazon Web Services. We are applying Standard Contractual Clauses with them to ensure that we comply with data privacy regulations regarding data transfers.
Many of our external third parties are based outside the country in which you reside or where we operate, therefore, their processing of your personal data will involve a transfer of data. Whenever data transfer occurs, we ensure a similar degree of protection is afforded to it by applying data transfer mechanisms, such as Standard Contractual Clauses.
You can find the location of our partners in the Glossary under External Third Parties.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.
3. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Your username, posts, comments and activity on our Platform will be publicly available and accessible to visitors and other members of our Platform. Please choose a non-identifiable username and do not share any data on our Platform which you do not want to become publicly available.
Information you share on our Platform from your profile or contributions, including special categories of data such as health data, that allows or enables you to be identified, could be identified as your data. This may also happen if you upload a photo of yourself, or a likeness of yourself, as a profile picture. Prior to posting any photo or likeness of you, choosing a username that may identify you, and/or posting other information that may identify you, you should carefully consider whether you:
1. wish to be identifiable on our Platform; and
2. want to post information that may be capable of being linked to you.
When you do, and you also make available special categories of data about yourself you will be deemed as having made that data manifestly public.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
You agree to notify us immediately of any unauthorised use of your account or any other breach of security. We will not be liable for any loss or damage that you may incur as a result of someone else using your password or account, either with or without your knowledge. However, you could be held liable for loss or damage incurred by us or another party due to someone else using your account or password. You may not use anyone else’s account at any time, without the express permission of the account holder.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with this or our Acceptable Use Policy.
If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us at info@wittosis.com. Notwithstanding any other terms pertaining to our right to disable or block access to your account, we reserve the right to disable or block your account at any time where it is suspected that unauthorised access has been made.
We may collect and store personal data on your device using application data caches and browser web storage (including HTML5) and other technology.
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.
Our service is hosted on third party servers. We have contracts in place with our third-party service providers which require them to implement security measures to protect the data they hold and the current security provisions in place are described above.
4. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. In such cases we retain the data as long as the issue is resolved through our complaint channels or before the relevant authorities or courts.
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.
If you wish to receive details of retention periods for different aspects of your personal data please contact us. Generally, once an account has been closed, we will process your data only for six months after closing your account.
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, in which case we may use this information indefinitely without further notice to you.
5. Account de-activation and deletion
When you delete your account, we may delete some of the information you have provided to us and you will not be able to recover that. Information that others have shared about you, is not part of your account and will not be deleted. If you do not want to delete your account but want to temporarily stop using it, you can deactivate your account instead.
6. Your rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
· Request access to your personal data.
· Request correction of your personal data.
· Request erasure of your personal data.
· Object to processing of your personal data.
· Request restriction of processing your personal data.
· Request transfer of your personal data.
· Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
7. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Consent means any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to you.
THIRD PARTIES
External Third Parties
· Service providers acting as processors who provide generally support to our business including but not limited to IT and system administration services, technical infrastructure services, analysis of how our services are used, customer service support services, based in Bahrain or abroad.
· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in England, Bahrain or abroad, who provide consultancy, banking, legal, insurance and accounting services.
· Regulators and other authorities based in Bahrain or abroad who require reporting of processing activities in certain circumstances.
YOUR RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
· 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.
· You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
