Kuradocs Limited (“we”, “us”, “our”) is committed to protecting and respecting your privacy and those of our Users.
This policy (together with our Terms and Conditions as set out here  (“Terms”) and any additional terms incorporated by reference into them) applies to your use of the Portal and Account (“Liferaft”) and sets out the basis on which we shall process any personal data that is inputted into the Portal and Account or otherwise provided to us. Please read the Policy carefully and if you do not agree with this Policy please do not use the Portal or Account.

In this Policy the following words have the following meanings:
“Account Holder” an individual with an Account which is accessed via the portal.

“Account” a MyLiferaft account which is accessed via the portal.

“Data Owner” an Account Holder who manages their own Account or a Managed Account. All Data Owners must at least 16 years of age.

“Managed Account” an Account where the Data Owner differs from the Account Holder.

“Portal” the portal used to access the Account.

“Shared-With Account” an Account that has been shared by the Data Owner/Account Holder with another person. The number of people who can be invited to become Shared-With Users depends on the subscription plan of the Data Owner/Account Holder

“Shared-With User” an Account Holder who has accepted an invitation to interact with another user’s Account. The invitation is sent by the Data Owner or Account Holder of the Account being shared. Sharing Permissions govern how the Shared-With User interacts with the Shared-With Account. There are no limitations on the number of Accounts a Shared-With User can access.

“Sharing Permissions” the permissions granted by the Data Owner/Account Holder to a Shared-With User or permissions granted by the Data Owner to the Account Holder of a Managed Account. Sharing Permissions govern the items of data that can be seen and the interactions that the Shared-With User, or Account Holder for a Managed Account, has.

“Subject” the Account Holder of the Account that is currently being accessed.

“User” An individual accessing an Account as either an Account Holder, the Data Owner or a Shared-With User.

For the purpose of the Data Protection Act 2018, the data controller will be the Data Owner and we will be processing the personal data on the behalf of the data controller as a data processor only. However, we will also use the personal data inputted to the Portal and Account in order to provide you with updates and in that case we will also be a data controller.

DATA WE MAY COLLECT FROM OR ABOUT YOU:

We may collect and process the following data about you and/or any accounts you manage:

• Data that you submit to MyLiferaft when registering or using the Account, this may include “sensitive personal data” such as details about your health and details about third party Subjects;
• Data about your use of MyLiferaft and any related services;
• A record of any correspondence between you and us; and
• Details of your subscription for the Account and payment details.

If you are inputting personal data to the Account that relates to a Subject other than yourself or are sharing such personal data with any third party you warrant that you have all relevant consents and authorities to do so and for the processing of that data in accordance with this policy. If you do not have the relevant consents from the Subject you must not submit such data to the Account or share it with any third party.

IP ADDRESSES / TECHNICAL DETAILS

We may collect data about the computer and/or mobile device from which you access the Portal and Account. This is statistical data about your browsing actions and patterns, and does not identify any individual. We use this data for system administration and may report aggregate data to our advertisers.

COOKIES

The Portal and Account use cookies to distinguish you from other users. A cookie is a small file of letters and numbers that we store on the hard disc or permanent memory of your computer or mobile device. Cookies contain data that is transferred back to is from your device’s memory on request.
Cookies help us to provide you with a good experience when you use the Portal and Account and also allow us to improve the Portal and Account.

The Portal and Account use cookies listed on https://www.myliferaft.com/cookies/

Please note that our advertisers may also use cookies, over which we have no control.

You can block cookies in the browser settings of your computer and the settings and preferences sections of your mobile device that allows you to refuse all or some cookies. However, if you block all cookies (including essential cookies) then you may not be able to access all or parts of the Portal and Account. Unless you have adjusted the browser setting of your computer or your mobile device’s preferences so that it will refuse cookies, our system will issue cookies as soon you use the Portal and Account.

Third Party Data Connections

As new connections are added this policy will be updated to reflect any specific details.
Third Party Specific details:

Google

If a data owner chooses to link their account to a google account the following describes what information is accessed by MyLIferaft.

MyLiferaft will store the account identifier and associated authorisation token. This information is only used for the purpose of providing linked account features, and the details are removed either when a user unlinks their account, or when the MyLiferaft account is closed.

Calendar: To enable users to have Liferaft appointments and reminders on a mobile, MyLiferaft will create and populate Google Calendar appointments and reminders generated from data within the MyLiferaft portal calendar. Users can sync the Google calendar to a mobile device, enabling mobile access to MyLiferaft appointments and reminders.

Contacts: Contact details can be imported from Google to prevent the need for the data owner to re-type existing contacts. Firstname, Lastname, Known As, Email, Telephone and Address information may be retrieved.

Twitter

No information is pulled from Twitter. MyLiferaft may use the Twitter account associate to push journal posts to the user’s Twitter account.

A user can revoke access to third-party accounts at any time.

Uses made of the Data

We may use data held about you in the following ways:
 To ensure that content from the Portal and Account is presented in the most effective manner for you and your computer or mobile device;

• To provide you with data, products or services that you request via the Portal or Account or which we feel may interest you, where you have consented to be contacted for such purposes;
• To carry out our obligations arising from any contracts entered into between you and us;
• To allow you to participate in interactive features of the Portal or Account, when you choose to do so;
• To notify you about changes to the Portal or Account.
• When subscribing to a fee-based Account you will be asked for payment information. Subscription payments are handled via Braintree (Paypal) or such other third-party payment processor as we may select. The payment processor will hold your payment details. We do not have access to this information but are notified whether your payment is up to date only.
• The Data Owner may not use data that you submit for the purpose of running or facilitating any business, club or organisation.
• Shared-With Users may use the data that you submit, in accordance with the access and use rights granted to them by you and/or the Data Owner (but not for the purpose of running or facilitating any business, club or organisation).

We will also process the data that we hold about Subjects as instructed by the Data Owner. This may include the processing of sensitive personal data about the Subject’s health. We will not use Subject’s sensitive personal data for marketing purposes or disclose it to any third party except the Shared-With Users as instructed and in accordance with their access and use rights as selected by the Data Owner/Account Holder.

If you are a Data Owner and/or Account holder we will also process the data that we hold about you to manage your subscription for the Account.

Users are not permitted to share any data with anyone other than authorised Shared-With Users in accordance with the rights granted to them by the Data Owner. By using the Portal and Account Users accept this restriction and agree to abide by it.

We do not disclose data that identifies individuals to our advertisers or other third parties, but we may provide third parties such as support groups or charities with aggregate data about our users to help them to plan the services that they provide to address the needs of their users and target users.

DISCLOSURE OF YOUR DATA

If you are a Data Owner, you acknowledge and accept that Shared-With Users will be able to view the data that you have submitted to the Account/Managed Account in accordance with the permissions that you have set for them. You warrant that the data in your Account relates to you or where it relates to a third party Subject, that you have all necessary and appropriate rights and consents to use it and share it in the way that you have chosen.

If you are a Shared-With User, you acknowledge and accept that the Data Owner will be able to view all of the data that you submit to the Account except for your password and by submitting data you acknowledge and accept this disclosure. Other Shared-With Users will also be able to access and view certain data that you submit to the Account – this will not include your password but may include any other data in line with the access rights that the Data Owner has granted to such person and by submitting data you acknowledge and accept this disclosure. If you do not wish the Data Owner or other Shared-With Users to view any data about you please do not submit it to the Account or check the access rights of other Shared-With Users first.

Account holders acknowledge and accept that Data Owners will be able to submit and enter information on their behalf and share that information accordingly.

We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We may disclose your personal data to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If our company, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation,
• In order to enforce or apply the Terms and Conditions and other agreements or to investigate potential breaches.
• In order to protect the rights, property or safety of Kuradocs Limited, our customers, or others. This includes exchanging data with other companies and organisations for the purposes of fraud protection and credit risk reduction.

WHERE WE STORE YOUR PERSONAL DATA

All data you provide to us is stored on our secure servers which are located in the UK. We will not transfer your personal data outside of the European Economic Area unless you have instructed us to do so. Where you access the portal via https any data transferred between your web browser and our servers will be encrypted using a minimum of 256-bit SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Portal and Account, you are responsible for keeping this password confidential. You must not share a password with anyone. We will never ask you for your password if you contact us. If you are asked for your password at any time on the Website then you should check your browser to ensure the padlock symbol is showing and that the URL links back to the Website. If it does not this could be a third-party fishing activity.

Unfortunately, the transmission of data via the internet is not completely secure. Although we will try to protect your personal data, we cannot guarantee the security of your data transmitted to the Account and any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your data to any third party for such purposes. You can exercise your right to prevent such processing by checking/unchecking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at our registered office address: Kuradocs Limited, Cowes Business Centre, 232 Newport Road, PO31 8PE or by email: info@myliferaft.com

If you follow any links from the Portal or Account to any third party website, please note that such websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

ACCESS TO INFORMATION

You have the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Act 1998. If you make an access request you may be charged a fee of £10 (at the time of writing this policy) to cover administrative costs in providing you with details of the information we hold about you. If you are a, shared with user or Subject then we will contact the Data Owner if you make an access request.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and you should check back to this page from time to time. If we make any significant changes we will notify you of them next time you log into the Account. Your continued use of the Portal and Account will demonstrate your continued acceptance of the current privacy policy.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to us at our registered office address: Kuradocs Limited, Cowes Business Centre, 232 Newport Road, PO31 8PE or by email: info@myliferaft.com