Privacy Policy

Introduction

This Privacy Policy (together with our terms and conditions and any other documents referred to in it) describes the type of information that we, the data controller, collect from you ("you/your") through our website at www.strolll.co ("Website") or the strolllhub (“Website”), how that information may be used or disclosed by us and the safeguards we use to protect it. In some situations, when we process personal information about your health and medical conditions, our Appropriate Policy Document relating to special categories of personal information will apply and before we process any such information we will obtain your express consent.

Who we are

Here are our details:

Our Website address is www.strolll.co
Our company name is Strolll Limited
Our registered address is Office 3 Trent Business Park, Eastern Avenue, Lichfield, England, WS13 6RN
Our nominated representative is Jorgen Ellis
Contact details: privacy@strolll.co

We respect your right to privacy and will only process personal information about you or provided by you in accordance with the Data Protection Legislation which for the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.

Acceptance of this Privacy Policy

Please check back regularly to keep informed of updates to this Privacy Policy. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.

What personal data we may collect & how we may use it

What type of personal data are we collecting?	Purpose of processing	What lawful basis do we rely on to use your personal data?
Your name, email address, telephone number and any other personal data you supply to us	To provide you with updates on our activities, services and products, to record your marketing preferences and any feedback or responses for the purposes of improving our products or services.	With your consent
Information about your health conditions and medical treatment. Device and website data including calibration measurements, room scans, user identifiers, session history (distance, type, performance, adherence, active time, scores), SOAP notes	To share your information with clinicians to enable them to manage patients and prescribe exercises including augmented reality games devised by us to provide physical therapy software as a service to patients suffering from neurodegenerative conditions and monitor performance over time	With your explicit consent, and subject to our Appropriate Policy Document a copy of which will be provided to you before we process any of this category of information
Any personal data we collect as part of your Cookies settings, namely online identifiers (such as your cookie identifier, IP address, browser type and version, time zone settings and location)	To allow us to operate our Website and ensure that its operation runs as smoothly as possible	With your consent
Name, job role, gender, email address, billing address, shipping address, payment information, phone numbers, order history, utilisation, device types, device serial	To allow us to collect order and user account information when you purchase our goods or services. To keep you informed, responding to your enquiries, or processing your orders. To troubleshoot if support is required.	Contract
De-identified health data.	For research and development purposes. Analysis of the clinical benefits whilst using our products and services. The data will assist us with medical device product innovation, science, publications, and technological development, acting in the public interest to strive to attain societal impact.	Legitimate interest. The legal basis of processing special category data is archiving, research, and statistics

How we may collect your personal data

We may collect your personal data from the following sources:

Through cookies or similar tracking technologies that we have set on our Website; and/or
When you provide us with personal information through our contact form or at events; this information may be stored in our customer management tool (CRM) and/or
When you submit medical, health, and other information through the portal on our “Website” or by other means (which will be subject to the Appropriate Policy Document a copy of which will be provided to you before we collect such information, which we will only do with your express consent); and/or
When we enter a contract to provide products or services

For more information on our use of cookies and/or similar tracking technologies, see the “Cookies” section below.

How long we may keep your personal data

We will not keep your personal data any longer than we think is necessary. When deciding how long to keep your personal data, we consider factors such as:

Our contractual rights and obligations in relation to the personal data involved;
Legal obligations under applicable law to retain data for a certain period of time;
Whether we relied on your consent to use the personal data, but you have since withdrawn your consent;
Statute of limitation under applicable law(s);
Our legitimate interests;
Fraud and risk management;
Potential disputes; and
Guidelines issued by relevant data protection authorities.

Cookies

When you browse our Website, we automatically receive your computer’s internet protocol (IP) address. We may collect data about how you interact with our Website through the use of Cookies, or other similar tracking technologies (collectively referred to as “Cookies”). A cookie is a small file of text that is stored on your browser or the hard drive of your computer.

We use Cookies to distinguish you from other users of our Website. It helps us to remember your preferences. When you visit our Website Cookies allow us to keep track of how many times you’ve visited us, how long you’ve visited us for and what you’ve done whilst you’ve been on our Website.

None of the Cookies we use are used to identify you as an individual. They typically collect anonymous identifiers associated with your device, browser, referring site URLs, time or usage information.

We use the following types of cookies:

Strictly necessary Cookies that are required for the operation of our Site, Tools and/or Services. These include Cookies that tell us if you’ve consented to the placement of functionality or analytical /performance Cookies, let you log into secure areas of our website, let us authenticate you when you sign-on to use any of our Services, and help us distinguish you from other users of our Site, Tools and/or Services. The functionality of our Services would be affected if these cookies are disabled.
Functionality or preference Cookies, that are used to recognise you when you return to our website so we can personalise our content for you (such as your country or language preferences).
Analytical or performance Cookies, that enable us to count the number of unique visitors to our Site and/or Tools and to see how users interact with our Site, Tools and/or Services by collecting information such as network requests, console logs, text entered and mouse movements. We use this information to help improve our Site Tools and/or Services and your experience. For example, we can use these Cookies to understand what areas of our website are not being used by users and make improvements.

International transfers of personal data

Any personal data that you provide will not generally be transferred to, or outside of the UK. We will take reasonable steps to ensure that your personal data is handled securely and in accordance with our Privacy Policy. If we do need to transfer outside of the UK, we will only do so if:

It is to a country that has been deemed to provide an adequate level of protections for personal data by the ICO; or
We have entered into a standard contractual clause approved by the ICO, which gives the personal data the same protection it has in the UK, with the recipient of the data.

Sharing your personal data

We may be required to share your personal data in the following circumstances:

If we reasonably consider that we are under a duty to disclose or share your personal data to comply with any legal obligation;
We need to enforce or apply or terms and conditions and/or other agreements with you; and/or
With third parties to whom we may sell, transfer or merge parts of our business or assets. If a change like this happens to our business, the new owners may use your personal data in the same way as set out in this privacy policy.

Behavioural advertising

We may use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Links to other sites

Please note that our Privacy Policy will not apply to other websites that you get to via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Changes

We will carry out a Data Protection Impact Assessment (DPIA) to systematically identify and minimise the data protection risks when undertaking any new project or plan that involves processing personal data.

If we change our Privacy Policy, we will post the changes on this page so please check this page for our current policy. Your continued use of our Website will be interpreted as your express acceptance of any changes to our Privacy Policy.

Right of access

You have the right to ask us to provide any personal data we have collected about you. Should you wish to do so, please email us at privacy@strolll.co to make a subject access request.

Other rights

You have the following additional rights under UK data protection law:

request access to, deletion of or correction of your personal data held by us at no cost to you;
request that your personal data be transferred to another person (data portability);
be informed of what data processing is taking place;
restrict processing;
to object to processing of your personal data; and
complain to a supervisory authority.

Making a complaint to a supervisory authority

Should you be dissatisfied with the service we provide, you have the right to file a formal complaint to the Information Commissioner's Office at www.ico.org.uk, or to the relevant data protection supervisory authority in your country of residence.

Contact Us

Should you have any questions about GDPR compliance or want to exercise any of your data subject rights, for now just drop us an email at privacy@strolll.co and keep an eye out for platform improvements that make it even easier to manage your data with us.