Privacy Policy

FinalPush - Privacy Policy - Version 1.0 - 29/06/2020

This Privacy Policy explains how FinalPush Limited, a company registered in England (company number 11953946) with its registered office at Delta Place, 27 Bath Road, Cheltenham, England, United Kingdom, GL53 7TH (“FinalPush”, “we”, “our”, “us”), processes your personal data and your rights in relation to the personal data we hold via your use of the website (“Website”) and “FinalPush” web application owned by us and available through the website and relevant app stores (the “FinalPush App”).

Any reference to “​you​” or “​your​” is a reference to you as a user of our Website or the FinalPush App.

We do not use cookies on our Website or the FinalPush App. Please see further details below and in our Cookie Notice.

This Website if not intended for children and we not knowingly collect data relating to children.

For the purposes of any applicable data protection laws in England and Wales, including from 25 May 2018 the EU General Data Protection Regulation 2016/679 (GDPR), FinalPush is the data controller of your personal data.

If you have any questions about these rights or how your personal data is used by us, you should contact our Privacy Manager using the details below:

Post – Privacy Manager, FinalPush Limited, Delta Place, 27 Bath Road, Cheltenham, England, United Kingdom, GL53 7TH

Email – (for the attention of the Privacy Manager)

1. How your personal data is collected

FinalPush collects your personal data from the following sources:

1.1. From you, when you:

Directly interact with our Website or the FinalPush App, for example when you:

- register or subscribe to the FinalPush App;

- fill in forms on our Website or our the FinalPush App, for example to make enquiries;

- select buttons to track your progress through the relevant topics on the FinalPush App;

- communicate with us by post, email, social media or in person;

- complete surveys or testimonials on our Website or the FinalPush App,

Use our Website or the FinalPush App, which results in the automatic collection of technical data about your equipment, browsing actions and patterns.

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 your relationship with us.

1.2. From third parties such as:

- Paypal, our payment provider, who will confirm your details of your payments;

- our platform providers who host and operate our website and apps.

Our Website and the FinalPush App may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website or the FinalPush App, we encourage you to read the privacy policy of every website you visit.

2. What categories of personal data are collected?

2.1. Identification, contact details and app use

- biographical information such as your name, country of origin and medical grade;

- your email address;

- log in details that you are assigned as part of registration;

- information you input into the FinalPush App to track your progress through the relevant topics.

2.2. Online and transactional

- when you visit our Website or use the FinalPush App apps we/our platform provider collect details of your Internet Protocol (IP) address, location (including institution), browser type and version, and operating system;

- information you provide in your communications with us;

- details about how you use our Website and the FinalPush App including the content you accessed, any searches you conducted, your length of visit, login details, time and date of visit and what method you used to browse away from our website;

- products you have purchased and details of financial transactions to the extent provided by Paypal;

- details of your current and previous subscriptions.

2.3. Cookies

- Our Website and the FinalPush App do not use cookies.

3. How we use your data, the basis for processing your data and with whom we share it

We will only use your data as the law allows. You can find details below:

3.1. As part of a contractual relationship

We may process your personal data because it is necessary for the performance of a contract, for example, to deliver the subscription you have requested, or in order to take steps at your request prior to entering into a contract. In this respect, we use your personal data for the following purposes:

- to register you as a new customer;

- to administer and correspond with you about your subscription;

- to provide you with access to the FinalPush App;

- to conclude transactions with you for the purchase of the online subscription;

- to monitor use of our site in accordance with our Subscription Terms;

- notifying you about changes to our terms and conditions or policies;

- to enable you to compete a survey or provide a testimonial.

3.2. Legitimate interests

Your personal data will also be processed because it is necessary for FinalPush’s legitimate interests or the legitimate interests of a third party. This will be weighed against your rights, interests and expectations. Examples of where we process data for purposes that fall under legitimate interests include

- detecting breaches of our Subscription Terms;

- processing technical information about your use of our Website and apps to ensure that content on our site is presented in the most effective manner and to allow you to use interactive features of our Website and the FinalPush App;

- processing enquiries, complaints, surveys, feedback forms and to analyse our services;

- providing your data to a buyer or prospective buyer of the whole or a part of our business (except in circumstances where this is necessary for the performance of a contract to which you are a party);

- consulting our professional advisers where it is necessary for us to obtain their advice or assistance.

We will not use your personal data to send you marketing communications.

3.3. FinalPush’s Legal Obligations

Your personal data will also be processed by FinalPush for compliance with its legal obligations. For example, for the detection and prevention of crime and in order to assist the police and other competent authorities with investigations.

In this respect, we may in specific circumstances need to share your personal data with third parties who have made legitimate requests under data protection law; the police and other law enforcement agencies; HMRC and FinalPush’s external auditors.

3.4. Consent

We do not rely on consent as a legal basis for processing your personal data.

3.5. Sharing personal data with third parties

Save as set out above, we do not otherwise share your personal data with third parties.

4. How long we retain your information

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 nature of the personal data, the potential risk from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal, regulatory, tax, accounting and other requirements.

By law we have to keep basic information about your customers (including contact, identity, financial and transaction data) for 6 years after they cease being customers for tax purposes.

In some circumstances, you can ask us to delete your data - see below.

5. Your rights under data protection legislation

- To obtain access to, and copies of, the personal data we hold about you;

- To require us not to send you marketing communications (although we will not send you marketing communications);

- To request that we erase your personal data;

- To object to, or request that we restrict, our data processing activities in relation to your personal data;

- To request the transfer or your personal data to you or a third party;

- To require us to correct the personal data we hold about you if it is incorrect; and

- To withdraw your consent at any time where we are relying on your consent to process your personal data.

Please note that the above rights are not absolute, and requests may be refused where exceptions apply. To initiate this process please contact our Privacy Manager and they will let you know the information we need to complete the request.

If you are not satisfied with how your personal data is used by FinalPush you can make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.