LifePass

LIFEPASS PRIVACY NOTICE

Mountain Technologies Ltd (“Mountain Technologies”) respects your right to privacy and is committed to protecting your personal data in line with its obligations under UK GDPR and EU GDPR. This privacy notice (together with our end-user licence agreement and terms of use and any additional terms incorporated by reference into them) will inform you as to how we use and protect your personal data when you:

Visit our Website https://lifepass.eu (“the Website”) (regardless of where you visit from)
Use our LifePass Web App (“the Web App”);
Use our LifePass Device (“the Device”);
Access or engage with any services, including sales, marketing, or events (Services), available through our Website or Web App;

This privacy notice is provided in a layered format so you can click through to the specific areas set out below:

Important information and who we are
The data we collect about you
How is your personal data collected
How we use your personal data
Disclosures of your personal data
International transfers
Data security
Data retention
Your legal rights
Glossary

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy notice

This privacy notice aims to give you information on how Mountain Technologies collects and processes your personal data through the use of our Website and Web App, including any data you may provide when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services or otherwise when you contact us.

Our Website and Web App are not intended for children and we do not knowingly collect personal data relating to children. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. The personal data of children may be processed if you assign a LifePass Device a nickname containing the personal data of a child.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Mountain Technologies Ltd is the controller and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

In the UK:

Full name of legal entity: Mountain Technologies Ltd

Name or title of data privacy manager: Chief Executive Officer (CEO)

Email address: info@lifepass.eu

Postal address: Mountain Technologies, 5 Parade Road, Ballygarvey, Ballymena, County Antrim, BT43 7JZ, United Kingdom

If you are resident in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues.

In the EEA:

Full name of legal entity: Mountain Technologies SARL

Name or title of data privacy manager: Chief Executive Officer (CEO)

Email address: info@lifepass.eu

Postal address: Mountain Technologies SARL, Milano (MI) Bastioni di Porta Nuova 21, CAP 20121

You have the right to make a complaint at any time to Garante per la protezione dei dati personali, the Italian regulator for Data Protection issues.

We would, however, appreciate the chance to deal with concerns before you approach your local data protection supervisory authority so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy policy under regular review. 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, for example, a new address or email address.

Third party links

Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and we do not accept any responsibility or liability for these policies or any personal data that may be collected through these websites or services.

2. THE DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data: includes first name, last name, any previous names, username or similar identifier, age range, title.
Contact Data: includes email address and telephone numbers.
Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
Geolocation Data: includes location-based information from your mobile device, either continuously or while you are using our Web App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Data: including your mobile device's camera, nfc / rfid, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
Device Data: includes location-based information from the LifePass Device.
Profile Data: includes purchases or orders made by you in our web shop including your lift pass information, your ski insurance purchases, your interests, preferences, feedback including feedback provided via our Chat Bot tool and survey responses.
Usage Data: includes information about how you interact with and use our Website, Web App, products and services.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may request to send you push notifications regarding your account or certain features of the Web App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but it is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website or Web App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity, Contact, Technical, Geolocation, Mobile, and Usage Data by filling in forms online, on the Website, Web App (together our Sites), or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Apply for our products or services;
Register to use the Web App;
Create an account on our Web App;
Use the LifePass Device;
Subscribe to our service or publications;
Make a purchase in our Web Shop;
Share data via the Web App’s social media functions;
Request marketing to be sent to you;
Enter a competition, promotion or survey; or
Give us feedback including via our Chat Bot tool or contact us.

Automated technologies or interactions

Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data Technical Data. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

Location Data

We also use GPS technology to determine your current location.

Third parties or publicly available sources

We will receive personal data about you from various third parties as set out below:

Technical Data: is collected from the following parties:
- Analytics providers such as Google based outside the UK;
- Advertising networks; and
- Search information providers.
Contact, Financial and Transaction Data: is collected from providers of technical, payment and delivery services.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the Web App, Website and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the Web App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

Where you have consented before the processing.
Where we need to perform a contract we are about to enter or have entered with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

See the Lawful Basis section below to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/activity	Type of data	Lawful basis for processing
To register you as a new App user	Identity, Contact, Financial, Device	Performance of a contract with you
To post testimonials	Identity, Contact, Location	Necessary for our legitimate interests
To manage our relationship with you	Identity, Contact, Financial, Profile	Your consent, Performance of a contract with you, Necessary for our legitimate interests, Necessary to comply with legal obligations
To enable you to participate in a competition	Identity, Contact, Device, Profile	Your consent, Performance of a contract with you, Necessary for our legitimate interests
To administer and protect our business	Identity, Contact, Device	Necessary for our legitimate interests

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that the Website and Web App may become inaccessible or not function properly. For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy.

5. DISCLOSURES OF YOUR PERSONAL DATA

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We will not transfer your personal data outside of the UK and EEA.

7. DATA SECURITY

All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password/passcode that enables you to access certain parts of Our Sites, you are responsible for keeping this password/passcode confidential.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

8. DATA RETENTION

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 amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data. To find out more please see YOUR LEGAL RIGHTS in the glossary:

Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact the data privacy manager using the details set out at Section 1 above.

10. GLOSSARY

Lawful Basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

EU GDPR: the General Data Protection Regulation ((EU) 2016/679).

UK GDPR: the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) as defined in the Data Protection Act 2018. Personal Data is subject to the legal safeguards specified in the UK GDPR.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

External Third Parties

Service providers acting as processors based in the UK and EEA who provide IT, payment processing, customer support and system administration services.
Ski Resorts acting as independent controllers who are resellers of LifePass and who will be notified in the event that the SOS function is activated on the LifePass Device.
Ski Patrol organisations acting as independent controllers who may be notified in the event that the SOS function is activated on the LifePass Device.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and EEA who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK and EEA who require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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 processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.