NECapture Privacy Policy

Last updated: 22nd October 2019

This privacy policy applies to all information collected when using our app, NECapture (the "App").

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

Information we collect

In Short: We collect device sensor data for researching context recognition. Some of this is collected automatically, and some is collected with your explicit consent.

Some data is automatically collected for the purpose of research and development for human activity recognition, and for security reasons. Other information may be provided by you explicitly when using the app.

This information is non-sensitive, but may contain your location, your name (if given), and a device identifier which could be used to identify you.

Below are some examples of what we may collect:​

  • Identifiers: a unique, pseudonymous identifier for the device running the App.

  • Device sensor data: acceleration, rate of rotation, external magnetic field, ambient light, barometric pressure, humidity, screen lock status, and location.

  • Derived usage information: user motion, device position, physical place category, overall user situation, local weather, habitual behaviours.

  • Device statistics: Wi-Fi/cellular connection statistics.

How we use collected information

 

In Short: Information is sent via a secure connection to us for analysis.

We use information collected via the App for a variety of business purposes described below.

We process your information for these purposes in reliance on our legitimate business interests ("Legitimate Interests"), in order to enter into or fulfill a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons").

 

We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To record device sensor data for later analysis. This is with Consent.

  • To show you live context recognition data. This is for Legitimate Interests.

  • To improve our technology. Anonymous data may be used to improve our methodologies for context recognition. This is for Legitmate Interests.

  • To enforce our terms, conditions and policies. This is for Legal Reasons.

How your information is shared

 

In Short: We only share information with your consent, to comply with laws, or to fulfill business obligations.

Reasons we may share your data:

  • Consent: We may share your data if you have given us explicit consent to use it for a particular purpose.

  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

  • Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

How long we keep information

 

In Short: Information within the App is discarded after 1 month, and information sent to us from the App is kept until consent to use it for research is revoked.

Information that is processed within the App is either discarded after a few seconds, or stored inside the App for up to 1 month. Due to technological limitations, old information cannot be deleted until the App is opened, uninstalled, or its data is cleared.

Information sent to us for the purposes of research and development is kept until consent is revoked.

We will only keep information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

 

When we have no ongoing legitimate business need to process personal information, we will either delete or fully anonymise it by removing all identifiers and location data.

How we keep your information safe

 

In Short: We use technological and organisational measures to prevent unauthorized access to your information.

Information is either short-lived, or stored using appropriate technological measures to ensure that only our App may access the information.

All sensor data sent to us is protected by appropriate technical and organisational measures to limit access to only those who are authorized.

Do we collect information from minors?

 

In Short: Not knowingly.

We do not knowingly solicit data from or market to children under 13 years of age. By using the App, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the App. If we learn that personal information from users less than 16 years of age has been collected, we will deactivate the device and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 13, please contact us at hi@numbereight.me.

Your privacy rights

 

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

Your privacy rights

If you would at any time like to review or change the information we hold about you, you can:

  • Uninstall the App, or clear its data.

  • Contact us using the contact information provided. You may need to provide further information about your device.

Upon a request to erase any information, we will deactivate or delete any related information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our terms and conditions and/or comply with legal requirements.

Specific rights for California residents

 

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

 

If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

Updates to this policy

 

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

Contact information

 

If you have questions or comments about this policy, you may email us at hi@numbereight.me or by post to:

NumberEight Technologies Ltd.
1-15 Clere Street
London
EC2A 4UY
United Kingdom

©2019 NumberEight Technologies Ltd, trading as NumberEight.
Registered and incorporated in England and Wales (No. 10502650).

Privacy Policy

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