Software Privacy Notice

Last updated: [04 December 2020]

Thanks for getting our software.

We respect your right to privacy. We want to tell you about what personal information we collect, share and use when you use our software, and how you can exercise your privacy rights.

Quick links: We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link below to jump to that section.

Who we are

What personal information do we collect and why?

Why are we allowed to use your information?

Cookies and similar tracking technology

Who can see your personal information?

How do we keep your personal information secure?

Where is your personal information kept?

You have rights about your personal information and can complain

How long do we keep your personal information for?

Updates to this Privacy Notice

Get in touch

1. Who we are

1.1 We are JCR Group Ltd (trading as Bodyswaps), a company registered in England (company no. 10317882). Our registered office is at 87-91 Hackney Road, London, E2 8FE.

1.2 We provide soft skills training services to employers, using our virtual reality software and/or mobile app.

1.3 We are the controller of your personal information.

1.4 To learn more about us, you can visit our website: https://bodyswaps.co/. If you have any questions or concerns about our use of your personal information, we have provided our contact information below in the Get in touch section.

2. What personal information do we collect and why?

The personal information that we may collect about you broadly falls into the following categories.

2.1 Information we collect automatically

(a) When you use our software, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area or the United Kingdom, this information may be considered personal information under applicable data protection laws.

(b) Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our software, including the training modules accessed and how long the software was used for.

(c) Collecting this information enables us to better understand how people use our software. We use this information for our internal analytics purposes and to improve the quality and relevance of our services.

(d) Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading Cookies and similar tracking technology.

2.2 Information we collect when you interact with a training module

(a) When you interact with a training module on our software, we will also obtain some or all of the following additional information about you during the scenario.

(i) Your spatial movements (i.e. how and where your hands and head move).
(ii)  Semantic information (i.e. what you say, using speech-to-text analysis).
(iii)  A recording of your voice.
(iv)  Emotional data (i.e. your tone of voice).
(v) Any answers you provide to our short feedback questionnaires at the end of a training module.

(b) We use your spatial movements, semantic information, recording and emotional data to analyse, and provide feedback, on your performance. We will also use this data to show you a recording of your session, which you can watch back for self-analysis purposes at the end of a training module.

(c) We do not keep a recording of your completed training module – these recordings are only used to play back your sessions to you. However, we will keep a copy of the script of what was said during your session to train the tools that we use in order to improve the functionality of the software. If we use your information in this way, it will be anonymised so that it cannot be traced back to you.

2.3 Information you provide voluntarily

(a) We may also ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us.

(b) The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

2.4 Information from third party sources

(a) From time to time, we may receive personal information about you from third party sources (including your employer), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

(b) The types of information we collect from third parties include name, location and work email address and we use the information we receive from these third parties to identify you in the system and provide email notifications.

3. Why are we allowed to use your information?

3.1 We explain what information we get from the software at What information do we collect and why?. Our legal basis for collecting and using this personal information will depend on the personal information concerned and the specific context in which we collect it.

3.2 However, we will normally collect personal information from you only (i) where the processing is in our legitimate interests and not overridden by your rights, or (ii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

3.3 If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you (such as when you download the software), we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

3.4 Where we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be:

(a) to operate our platform and communicate with you as necessary to provide our services to you;

(b) to train the tools we use during the training modules in a way that keeps your information safe, so that we can make our software easier and better to use; and

(c) for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.

We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

3.5 For more information about how we balance our legitimate interests against your rights when using your personal information, you can contact us using the contact details provided under the Get in touch heading below

4. Cookies and similar tracking technology

4.1 We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you.

5. Who can see your personal information?

5.1 We explain what personal info we collect from you at What information do we collect and why?.

5.2 We may disclose your personal information to the following categories of recipients:

(a) to our third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our software), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.

(b) to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

(c) to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;

(d) to any other person with your consent to the disclosure.

6. How do we keep your personal information secure?

6.1 We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

7. Where is your personal information kept?

7.1 Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

7.2 Specifically, our servers are located in United Kingdom, and our third party service providers and partners operate in the UK and EU. This means that when we collect your personal information we may process it in any of these countries.

7.3 However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.

8. You have rights about your personal information and can complain

8.1 You have the following data protection rights.

(a) If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the Get in touch heading below.

(b) In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the Get in touch heading below.

(c) You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the Get in touch heading below.

(d) Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

(e) You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area/UK are available here.

8.2 We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

9. How long do we keep your personal information for?

9.1 We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

9.2 When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. Updates to this Privacy Notice

10.1 We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

10.2 You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

11. Get in touch

If you want to know more, please visit https://bodyswaps.co/ or contact us at hello@bodyswaps.co. Alternatively, you can write to us at:

Bodyswaps
Attn: Data Protection Officer
87-91 Hackney Road
London E2 8FE (UK)

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