Privacy Policy for Mami by CupArise CIO

Dated 9th  November 2022

Introduction

CupArise CIO (“we”) are committed to protecting your personal data and respecting your privacy. We strive to respect your privacy as well as the privacy of all users of our application, Mami app (the “App”).  This Privacy Policy describes how we collect, use, or disclose personal information we receive through our App (either by you or from third parties on your behalf). This policy also describes your choices about the collection and use of your information. A separate policy for our website can be found here and terms and conditions in this link.

Please read the Privacy Policy carefully before you start to use our App. By downloading and using our App, you agree to be bound and abide by our posted Terms of Use (“Terms”) and this Privacy Policy. If you do not agree to both our Terms and Privacy Policy, or if you violate them in any way, your right to access or use shall be terminated.

This policy is outlined in the following sections:

  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 Legal Rights

Important information and who we are

CupArise is a CIO registered with the UK Charities Commission with charity number 1200402 and is the controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this policy).

What is Mami?

Mami is a mobile app and SMS service that helps women living in Nigeria identify breast cancer symptoms and then connect with care. It is developed by CupArise CIO, a registered charity in England and Wales (Registration number 1200402).

Who can use Mami?

Adults aged 18 years old and above.

Medical Disclaimer

Mami is a software developed by CupArise CIO. CupArise CIO is an organisation focused on improving the breast health awareness of the public. We are not a healthcare or medical device provider, nor should CupArise CIO, our programmes and information provided on our website or platform such as Mami, or social media handles, podcasts be deemed as medical advice.

This is not a medical or diagnostic test. Any medical information referred to in or through either our mobile application, page or website is given as information only and is NOT intended:

We strongly recommend that you consult a healthcare professional for specific advice about your situation.

The content, resources, and recommendations on our websites, Mami app and social media platforms, are meant for information purposes only and are not a substitute for professional medical advice. We make no representations and claims that our services and website provide a therapeutic or health-related benefit, and we make no representations or warranties about the suitability, accuracy and completeness of the services and website. You agree to assume full responsibility for your actions and decisions, and we are neither responsible nor liable for any consequences having read this.  Before going forward, make sure to read the rest of our Terms and Conditions.

If you have any questions about this privacy policy, please contact us  using the details set out below.

Contact details

Our full details are:

Postal address: CUPARISE 4th Floor, 18 St. Cross Street, London, EC1N 8UN.

We will keep our privacy policy under regular review.

This version was last updated on the date at the top of this policy. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you. The new policy may be displayed on-screen, and you may be required to read and accept the changes to continue your use of the App or the Services.

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 our relationship with you.

Third party links

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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.

The data we collect about you

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

We also 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 App 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.

How is your personal data collected?

We will collect and process the following data about you:

analytics providers such as Google and Apple based outside the EU;

search information providers such as Google based inside and outside the EU.

Unique application and device numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates or when you agree to receive push notifications, that number and information about your installation, for example, the type of operating system, may be sent to us and used to send push notifications to your device.

Cookies

We do not use cookies on our App. Our website uses cookies to distinguish you from other users of our website and to remember your preferences. This helps us to provide you with a good experience when you use our website and allows us to improve our website. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy here.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activityType of dataLawful basis for processing
To install the App and register you as a new App user and to help verify your identityIdentity Contact Device Location DataYour consent Performance of a contract with you
To manage our relationship with you including your use of the App, notifying you of changes to the App or any Services and to enable us to send you push notifications, and location services.Identity Contact Profile Marketing and Communications Log Data Device Data Content Data Usage Data Location Data MessagesYour consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how stakeholders use our products/ Services, to manage the Services and App, to notify you of security concerns and issues and deal with complaints from others) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a surveyIdentity Contact Device Profile Marketing and CommunicationsYour consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our Services and to develop and improve them and the App) We will use survey information for the purposes described when we collect the data (although we may use anonymised data from the survey in order to undertake research and trends) If you have consented to us contacting you in relation to a survey, we may do so. For prizes and competitions, we may contact you in connection with the administration of those competitions.
To administer and protect our organisation and this App including troubleshooting, data analysis and system testingAll categories of dataNecessary for our legitimate interests (for running our organisation, provision of administration and IT services, network and app security) and to safeguard our users, to test and upgrade our App, Services and processes Your consent where this is required by law
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve youIdentity Contact Device Content Profile Usage Marketing and Communications LocationYour consent for marketing activities
To enable our staff to provide helpline services and other support To provide customer servicesIdentity Contact Device Content Profile Usage Marketing and Communications Location MessagesYour consent Necessary for our legitimate interests (to develop our Services and App and grow our organisation)
For research and analytical purposes to help improve our App and ServicesAll categories of dataNecessary for our legitimate interests (to develop our Services and App and grow our organisation) Consent for Location Data and other data where your consent is required to process this data for this purpose.
Fundraising and Donations and to transact with you whether paid or unpaidIdentity Contact Transaction FinancialConsent Our legitimate interest (in raising funds for our organisation) Contract


Disclosures of your personal data

We may disclose your personal data to third parties 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, if you have consented to this, to protect our rights and property and the rights, safety and property of others (provided we comply with data protection law).

We may also transfer your personal data to a third party we have appointed to provide services to us on our instructions which we refer to as External Third Parties as set out in the [Glossary].

We may transfer your data in connection with a potential transfer of part or all of our organisation. In such circumstances we may share information with prospective purchasers (for example as part of a controlled due diligence exercise). Alternatively, we may seek to acquire another organisation or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy policy.

If we reorganise our business as we may need to transfer information about you to another member of our group so that we can continue to provide the Service to you.

Data security

All information you provide to us is stored on secure cloud servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 will 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 when we are legally required to do so.

Data retention

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.

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In most cases, we will keep your information for three years after our relationship with you ends but where we have a contract with you, we will keep it for at least 6 years. It will vary depending on what data we hold, why we hold it and what we are obliged to do by law. Further details of our data retention policies can be obtained by writing to the address above.

In most cases, we will keep your information for three years after our relationship with you ends but where we have a contract with you, we will keep it for at least 6 years. It will vary depending on what data we hold, why we hold it and what we are obliged to do by law. Further details of our data retention policies can be obtained by writing to the address above. We are implementing end to end encryption for our messaging service and once this is enabled we will delete any of your user to user messages that we process so as to improve privacy of your messages.

We will not keep your personal information longer than is reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and in order to comply or demonstrate compliance with our legal and regulatory obligations. Where we can, and it is appropriate, we will minimise personal data or de-personalise data to use for statistical or analytical purposes.

In some cases, such as if there is a dispute or a legal action affecting the information we may need or be required to keep personal information for longer.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data for at least 6 years.

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.

In the event that you do not use the App for a period of time then we may treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances you have the following rights under GDPR (prior to 31 December 2020 and the Data Protection Act 2018 from 1 January 2021) in relation to your personal data.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at hellomami@cuparise.org.

Postal address: CUPARISE, 4th Floor 18 St. Cross Street, London, EC1N 8UN.

©CupArise 2022. All rights reserved. Registered Charity in England and Wales (1200402).