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Breathe Remote Monitor (RM) – App Privacy Policy

6th February 2025

 

Magic Bullet Ltd (“us”, “we”, or “our”) (registered at 350 Wokingham Road, Earley, Reading, Berkshire RG6 7DE with company number 04886771) operates the Breathe Remote Monitor (RM) mobile application (the “App”).

This Privacy Policy informs the user of our App (“you”) of our procedures regarding the collection, use, and disclosure of personal data when you use our App. We are the controller of any personal data collected and processed in relation to the App, and we are committed to protecting and respecting your privacy at all times.

 

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using the App, you agree to the collection and use of your information in accordance with this Privacy Policy.

 

What personal data do we collect:

While using our App, we will ask you to provide certain personal data including but not limited to: Spirometry, Oximetry, Heart Rate, Activity, Sleep, Weight, Temperature, and self-reported measures of Wellness and Coughing (“Health Details”). If you are taking part in a clinical evaluation, you will only need to provide us with an anonymised email address created specifically for the purpose of the evaluation. If you are not taking part in a clinical evaluation, you may need to provide certain personal data to enable your clinical team to identify you, including your full name, email address, hospital number, NHS number, and date of birth. When you access the App by or through a mobile device, we may also collect certain information automatically, including the make and model of your mobile device and analytics on how you use the app.

 

How we use your personal data:

We use the personal data collected from you for various purposes, as follows:

  • To provide and maintain the App.

  • To analyse your use of the App so that we can make improvements.

  • To share your personal data with your clinical team where you have provided your explicit consent for us to do so.

  • To share your personal data with researchers, but only where you have explicitly consented to us sharing this information for research purposes.

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Research and the National Data Opt-out Policy:

We may use your personal data to support medical research, but only where you have explicitly consented to this. You have the right to withdraw this consent at any time. Additionally, if you do not wish for your data to be used for any future research or planning purposes beyond your direct care, you can exercise your right under the National Data Opt-out policy by contacting us or visiting the relevant NHS Digital portal. If you withdraw consent or exercise your right to opt out, we will cease sharing your personal data with researchers or clinical teams for those purposes.

 

Your rights:

You have the following rights in relation to our processing of your personal data through the App:

  • The right to access personal data we hold about you: You can contact us to request a copy of the personal data we hold about you, as well as why we process that personal data, who has access to it, and where we obtained it.

  • The right to correct and update the personal data we hold about you: If the personal data we hold about you is out of date, incomplete, or incorrect, please let us know, and we will ensure that it is updated.

  • The right to have your personal data erased: If you no longer wish to use the App, you have the right to request the deletion of your account and associated personal data. To do so, please follow the steps outlined in the ‘How to Delete Your Account’ section below. Once your account is deleted, all associated data will be permanently removed unless we are required to retain certain information for legal or regulatory purposes. Please note that account deletion requests may take up to 30 days to process.

  • The right to object to the processing of your personal data: You have the right to request that we stop processing your personal data. Upon receiving the request, we will contact you to inform you if we are able to comply or if we have lawful grounds to continue, for example, if the personal data is required to allow us to provide you access to the App. If personal data is no longer processed, we may continue to hold your personal data to comply with your other rights.

  • The right to data portability: You have the right to request that we transfer your personal data to another controller. Once we have received your request, we will comply where it is feasible to do so.

  • The right to lodge a complaint: You can make a complaint to us by contacting us using the contact details set out below. Alternatively, you can also make a complaint to the data protection supervisory authority. In the UK, this is the Information Commissioner’s Office, and contact details can be found at https://ico.org.uk.

 

How to Delete Your Account:

If you would like to delete your Breathe RM account and permanently remove your personal data, please follow these steps:

  1. Submit a Request – Send an email to support@breatherm.com with the subject line: Request to Delete Account.

  2. Verification – For security purposes, we may ask you to verify your identity before proceeding with account deletion.

  3. Processing Time – Your account and associated data will be permanently deleted within 30 days of confirmation, unless we are required to retain certain data for legal or regulatory reasons.

  4. Impact of Deletion – Once your account is deleted, you will no longer be able to access your data, including any health metrics stored within the App. This action cannot be undone.

 

If you have any questions regarding account deletion, please contact us at support@breatherm.com.

 

Security of your personal data:

We recommend all app users familiarise themselves with the National Cyber Security Centre guidance on keeping your smartphones safe. If you choose to share your Health Details with us you will be required to log into the Breathe account section of the App. Once you have signed into your Breathe account, the App will automatically sync all of your personal data with us, including your Health Details. We use a combination of technical, administrative, and physical controls to maintain the security of your personal data once it has synced with the Breathe account. In particular, Microsoft Azure implements the transmission integrity and confidentiality control by ensuring that cryptography is implemented through a hybrid model. Our cloud infrastructure (which includes all hardware, software, networks, and the physical data centres that house it all) is located within the UK.

 

Contact us:

If you have any questions about this Privacy Policy or need assistance with deleting your account, please contact us at:

Alternatively, you can reach us via our contact form at https://magicbullet.co.uk/contact.

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