PRIVACY NOTICE

This privacy notice describes how we might collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018, the Health and Safety Regulations 2005 & 2015; together with any other national implementing laws, regulations, secondary legislation and Health and Safety Laws as amended or updated from time to time in the UK, EU, Russia, USA and the rest of the world.

Please read the following carefully to understand our practices regarding your personal data and how we process it.

Wearable Technologies Ltd (“WTL”) is a company that supplies data gathering garments. It is registered in England and Wales as a limited company under number 08814318, with the registered office at 12 Warren Park Way, Enderby, Leicester, LE19 4SA, England

For the purposes of EU & UK Data Protection Legislation we are a ‘Data Controller’. This means we are responsible for deciding how we process personal information about you. For Russian citizens – we are a ‘Data Operator’.

Our Chief Data Protection Officer (CDPO) is responsible for helping with all enquiries relating to our management of your personal data. If you wish to contact our CDPO please use the email address below.

 

Data Collection

WTL obtains personal data about you, for example, when:

– you request a proposal from us in respect of the products or services we provide; or

– you, your employer or our clients engage us to provide products or services; or

– you contact us via email, telephone, post, our website contact form; or

– we obtain your information from third parties and/or publicly available sources; from your employer; from Companies House; or

– you wear one of our Health and Safety garments for protection and enhanced security.

These garments collect different types of data that we use to protect and defend your health, safety & security at work. Importantly, most of the data is collected and processed in real time, so that if something happens to you, help can be sent as quickly as possible – even if you are incapacitated.

 

The personal data our garments collect

Our breakthrough technology is housed within a high-viz jacket, and has been carefully designed to keep workers safer, more secure, and to protect their health from many types of everyday harm. To achieve this, we gather the following personal information/data.

* Your whole body suddenly accelerating. e.g. falling (still in development).

* Your exposure to dangerous gases (Co2, CO), Oxygen levels & Volatile Organic Compounds (VOCs).

* Any hand and arm vibration when using power tools.

* Your heart rate, breathing levels, heat stress and any resulting physiological strain.

* Harmful or damaging sounds in the environment around you. This helps to protect your hearing in both the short and longer term. We do not, and cannot, collect your voice data (speech).

* Your proximity to (dangerous) moving machinery or vehicles (Proximity Warning System – PWS).

* Your location so that if an incident occurs help can be sent quickly – even if you are incapacitated; or, help can be provided in the shortest possible time when you send an SOS alert to your supervisor, requesting assistance.

* Personal Protective Equipment (PPE) – our software sends reminders to ensure your preventative equipment is being utilised for your on-going safety and protection.

* When working on your own, two way regular ‘click’ communication with a supervisor can be set up so that if an event occurs which incapacitates you, the supervisor can send help.

 

Harmful Incident Reporting – If you, or any of the data above trigger a critical alert, your jacket will immediately light up in red (so any ‘in-sight’ colleagues can assist), while our system automatically sends a warning with your location to a supervisor’s phone, requesting assistance.

And crucially, your name is not held by the system.

Our system records every jacket wearer by number – not by name (e.g. Worker 1234). The system is carefully designed to protect your privacy. In data protection law, using a unique number, instead of a person’s name, is called pseudonymisation and is considered a valuable ‘’privacy treatment’’ that protects personal data

 

Personal information that collected by WTL’s website, phone (or other medium)

Should you decide to contact us, we may hold the following personal data about you:

– your personal details such as your name, address, phone number, mobile phone number, job title with any other information you have freely given/presented to us;

– any previous details we hold about you in relation to the provision, or the proposed provision, of our products, advice, services or guidance;

– our correspondence and communications with you;

– information about any complaints and enquiries you make to us;

– Information we receive from other sources (publicly available information), or information provided by your employer, our clients, our suppliers,

-or information from our associated network of firms and organisations.

We may process your personal data if it’s necessary for the performance of our contract with you or your employer or our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or a customer of a WTL client.

We may process your personal data to perform our legitimate interests, provided our interests do not override any of your own interests, rights or freedoms. This includes processing for marketing, business development, statistical and management purposes; and we may process your personal data for certain additional purposes with your consent. Where your consent is required for the processing of your personal data you have the right to withdraw your consent to processing for a specified purpose.

Please note that we may process your personal data for more than one lawful basis depending on the purpose for which we are processing your data.

 

Situations in which we will use your personal data

We may use your personal data in order to:

– carry out our obligations arising from any agreements entered into between you, your employer, our suppliers or our clients and us, which will usually be for the provision of our products or services;

– carry out our obligations arising from any agreements entered into between our suppliers, clients and us; usually for the provision of our products or services where you may be a client, an employee of our client, subcontractor, supplier or customer.

– provide health and safety assistance to you where the processing is necessary to protect your vital interests if you are physically incapable of giving consent;

– provide you with information related to our products, services and our events or activities that you request or which we feel may interest you, provided you have consented to be contacted for those purposes;

– seek your thoughts and opinions on the products and services we provide; and notify you about any changes to our products and services.

 

Legal obligations

Please understand that in accordance with this notice we may also process your personal data without your knowledge or consent, only where we are required to do so by law.

 

Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected and in line with our legal obligations.

When assessing what retention period is appropriate for your personal data, we take into account: the requirements of our business for the products and services provided; any statutory or legal obligations; the purposes for which we originally collected the personal data; the lawful basis for our processing; the types of personal data we have collected; the amount and categories of your personal data and whether the purpose of the processing could reasonably be fulfilled by other means.

Where or when we need to use your personal data for a different purpose to the one for which it was collected, we will only use your personal data where that reason is compatible with the original purpose. However, should it be necessary to use your personal data for a new purpose we will notify you first of the legal basis before commencing with any new processing.

Please know that we will only share your personal data with third parties when we are required by law or where it is necessary to administer the relationship or contract between us, or where we have another legitimate interest.

We use Third parties to process your data. These may also be regarded as ‘Sub-processors’.

“Third parties” means any third-party service providers (or other entities within our company).

The following activities are carried out by third-party service providers:

Information Technology (IT) and cloud services; professional or advisory services; administration services; health monitoring where we have your consent; payment services and Tax administration (which is a legal obligation).

All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes in accordance with our instructions.

We may share your personal data with other third parties, for example in the possible sale or restructuring of the business. We may also share your personal data with a regulator or to comply with the law.

We will not transfer any personal data we collect about you outside of the EEA without first obtaining your consent.

Should you require further information about these protective measures please contact us using the email address below.

 

Security of your Data

We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, altered or disclosed, used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality and similar standards of compliance.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

It is important that the personal data we hold about you is accurate and up to date. Should your personal information change, please notify us of any changes by contacting at the email address below.

 

Your data privacy rights

Please know that under certain circumstances, such as within the context of GDPR, you have the right to:

 

– Request access to your personal data. This enables you to receive details of the personal data we hold about you, to check that it is accurate and that we are processing it lawfully.

– Request correction of the personal data that we hold about you.

– Request erasure of your personal data. This enables you to ask us to delete or remove your personal data where there is no longer a legal reason for WTL continuing to process it. You also have the right to ask us to delete or remove your personal data if you have exercised your right to object to processing.

– Object to processing of your personal data where we are relying on a legitimate interest or those of a third party and there is something about your particular situation which makes you want to object to WTL processing your data. You also have the right to object where we are processing your personal information for direct marketing purposes.

– Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

– Request the transfer of your personal data to you or to another data controller if the processing is based on consent or contract and this is technically feasible and reasonable.

If you want to exercise any of the above rights, please email our Chief Data Privacy Officer at the point of contact below.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information, or to exercise any of your other rights. This is an appropriate security measure to ensure that your personal information is not disclosed to a person who does not have the right to receive it.

Where you have only provided to us your consent for the collection, processing and transfer of your personal data for a specific purpose (for example in relation to health and safety monitoring), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent simply email our data protection point of contact below.

Once we have received notification that you have withdrawn your consent, we will erase your data and no longer process your personal information (personal data) for the purpose(s) you originally agreed to unless we have a legal obligation to do so.

 

This privacy notice was last updated on 9^th July 2019.

 

CONTACT WTL

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Chief Data Privacy Officer at the email address below.

We are sorry to lose you and if you chose to opt out we will refrain from sending you any further marketing material, though we may keep a record of your information as part of our legal obligation or where it is necessary for the purposes of our legitimate interests and those interests are not overridden by your privacy rights. Additionally, if you wish to withdraw your consent for receiving information, please send an email to the Chief Data Privacy Officer at:

Email: CDPO@wearable.technology

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone – 0303 123 1113 (local rate) or 01625 545 745

Website – https://ico.org.uk/concerns