RUBY - Privacy Notice

The RUBY App (RUBY) and the SeeMe Web Service (SeeMe) is operated by Glassmoon Strategies Ltd and Glassmoon Digital Ltd respectively and are both part of the Glassmoon group of companies. Glassmoon Digital Ltd and Glassmoon Strategies Ltd (“we” or “us”) are the data controller in respect of your personal information.

Our contact details:

You can contact us at the below contact details:

Address: 6th Floor, King's House, 9-10 Haymarket, London, SW1Y 4BP

E-mail: dataprivacy@glassmoon.co.uk

Introduction

The purpose of RUBY and SeeMe are to help people see their personal and professional identities and their emotional states to create a self-defined picture of themselves, using their own data to support them to navigate their career, work and life.

SeeMe is a tool to help individuals to understand themselves better and to understand all aspects of themselves which make up their identity and their intersecting areas of identity.

RUBY builds on the SeeMe platform for individual users to track their thoughts, feelings, wellbeing and structured Pathways of Life. Research suggests that undertaking activities like this contributes to a more positive sense of wellbeing and self-identity.

SeeMe comprises 26 questions across 13 areas of identity. Once you have answered the questions, you can view your SeeMe profile. Once you submit this, your answers are anonymised.

Our intention is not to sell your personal data to 3rd parties for marketing and / or personal advertising. We can give you an assurance that we will never do this. We value your privacy.

This privacy notice

This privacy notice sets out the basis on which any of your personal information we collect from you or third parties, or that you provide to us, will be processed by us.

Please read the following carefully to understand our practices regarding your personal information and how it will be treated.

The type of personal information we collect

For your SeeMe profile, we take great care that the data we collect is anonymised, to ensure your data is not linked to you as an individual. We ask that you choose a profile name instead of a personal email when you are completing your SeeMe profile. We do not need to know your name.

We, and our third-party providers and business partners who enable us to operate the RUBY app, may collect and process the following personal information about you:

Submitted information

We may collect and process the following personal information about you which you provide:

• Contact details (name, email address etc. to create your personal app security profile and account registration);
• Demographic information
  • Age
  • Sex, Gender & Sexual Orientation
  • Nationality, Race & Ethnicity
  • Relationship Status
  • Religious & Spiritual Beliefs
  • Socio-Economic Background
  • Physical, Mental Health & Non-neurotypical
  • Caring Responsibilities
  • Position & Working Arrangements
  • Earnings & Income

• information on your views, values & work/life needs and non-work passions (including engagement and enjoyment in respect of your job);
• password and other authentication information; and
• responses to any customer satisfaction surveys or market research (unless these are provided anonymously).

Additional information

If you contact us with a complaint or query, we may keep a record of any email correspondence with us. We may also record your levels of satisfaction with the services we have provided.

When you use the RUBY app, we may also collect information from you automatically, for example using similar technologies to cookies. A cookie is a small file of letters and numbers that we may set on your device. Cookies generally only work with web browsers, but there are similar technologies that are used by apps, like the RUBY app.

This type of information may include the following:

• information about your device (including a unique device identifier or device ID);
• your login information; and
• information about your use of the RUBY app, for example to distinguish you from other users of our app, and to remember your preferences to help us to provide you with a good experience when you use our app and allows us to improve the app.

How and when we collect personal information

We collect and process personal information when you:

• use the RUBY app (including when registering, leaving any reviews or comments, or filling in forms through the RUBY app);
• contact us or request information from us in any other way; and
• participate in our customer satisfaction surveys or other market research.

Purpose of processing your personal information

We may process your personal information for the following purposes:

• to provide you with our services and other information you have requested;
• to authenticate your access to the RUBY app;
• for system administration purposes and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to distinguish you from other users (for example to remember your log-in details);
• to monitor your use of the RUBY app to improve the user experience and to ensure that content is presented in the most effective manner for you and for your device;
• to provide customer support and ensure we provide a good level of customer service;
• to notify you of any changes to our services;
• for security and fraud prevention;
• to ensure that the RUBY app is safe and secure; and
• to comply with applicable laws and regulations.

Legal basis for processing

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

• Consent: You can withdraw your consent at any time. You can do this by contacting dataprivacy@glassmoon.co.uk.
• Our legitimate business interests: Where it is necessary for us to understand our customers/users and promote our services and operate effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.
• Performance of a contract with you (or in order to take steps prior to entering into a contract with you).
• Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

We may share this information with

We may share your personal information within our group of companies. We may also share your personal information with our suppliers, business partners and service providers (e.g. such as our hosting provider and IT support provider), solely to the extent necessary to enable us to provide the service. Any such third parties are not permitted to use such information for their own purposes, and we put in place safeguards to ensure they treat any such information securely.

How we store your personal information

The personal information that we collect may be transferred to, and stored at, a destination outside the EEA or the UK, including countries, which have less strict, or no data protection laws, when compared to those in the EEA or the UK.

Whenever we transfer your information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy notice. In these cases, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

How we keep your personal information

We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in most cases anonymised. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.

Where we have collected the personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information.

If you choose to delete your RUBY account, we will dispose of the following information we collected with immediate effect:

• Name;
• Email address;
• Password;
• Social account credentials;
• Date of birth;
• Title of moment;
• Notes of reflection;
• Significant moments;
• Date of moments; and
• Intentions.

If you choose to delete your RUBY account, your personal data will be removed from our servers within 24 hours. However, we will retain your non identifiable data for social impact longitudinal research purposes. This is how we influence thinking, policy, and practice, to help companies and businesses know how to properly ‘see’ individuals. We want to help them to work with and serve individuals in the best possible way. We collect anonymised data to do this. This data can never be tracked to you.

Children

The RUBY app is not intended for and should not be used by anyone under the age of 18. We do not knowingly collect personal data from anyone under the age of 18.

Security and passwords

You must keep your password and any other authentication information for the RUBY app confidential. If you know or suspect that anyone other than you knows your password or any other authentication information, you must promptly notify us using the email address below.

Unfortunately, the transmission of information via apps and/or the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted during your use of the RUBY app.

Your data protection rights:

Under data protection law, you have rights which include:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask us to transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please contact us at dataprivacy@glassmoon.co.uk. You will generally not be required to pay any charge for exercising your rights. If you make a request, we generally have one month to respond to you.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us via the following email address dataprivacy@glassmoon.co.uk

You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns, we request that you initially contact us (at dataprivacy@glassmoon.co.uk) so that we can investigate, and hopefully resolve, your concerns. The data protection authority in the UK is the ICO:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

Changes to this privacy notice

We may change this privacy notice at any time. The new privacy notice will be displayed through the RUBY app. The date this privacy notice was last updated appears at the bottom.

This Privacy Notice was last updated on 01 November 2022.