Bright Sky Privacy Statement - June 2020

This Privacy Statement explains how Aspirant collects and processes information through your use of the Bright Sky app (the "App").  We invite you to read this privacy statement, which describes our privacy settings and security practices. We want you to understand when and how data is handled by us through your use of the App. As processes improve and change, we reserve the right to make changes to this policy from time to time, please check here for the most up-to-date version.

Collection of Personal Information

"Personal information" is any information that can be used to identify you or that we can link to you.

Information We Collect from You

We collect, process and use personal information when you download and use the App.

The information we collect includes the information that you provide when you use the App including:

  • Information that you enter when using the My Journal feature of the App;
  • Your email address.

We also receive information automatically when you download the App including:

Actions:

The number of daily and monthly installs for V1, V2 and Vs1&2

Opened Application

Took assessment (V1 only)

Start Assessment - Am I At Risk

Complete Assessment - Am I At Risk

Start Assessment - Friends/Family At Risk

Complete Assessment - Friends/Family At Risk

Start Assessment - Myths

Complete Assessment - Myths

Called Advocate

Called National Resource

Searched for location - By Postal code/Other

Searched By Current Location

Clicked content link (in app text)

Clicked Content Link (in menu)

Sent Photo Journal

Sent Text Journal

Sent Video Journal

Sent Voice Journal

Called Emergency Phone Number

Open Guide - Online Safety Guide

Open Guide - Sexual Consent

Open Guide - Stalking & Harassment

Open Guide - Forms of Abuse

Open Guide - Types of Support

Open Guide - How Can I Help

Open Guide - Leaving Abusive Relationship

Users:

The operating system of your device (Apple and Android) for V1 and Vs1&2.

Covert Mode Used

Language(s) selected

 

How We Use the Information We Collect

When you use the My Journal feature of the App and provide information, this information will not be saved onto your device, the app or our server.  We do not save or have access to any entries that you send using the My Journal feature. 

Your journal entries will be emailed to you if you enter an email address.  We only collect the email address in order to facilitate your record keeping of your entries using the My journal feature, but we will not keep a record of the email address or the content of the entries.  You will need to provide the email address each time you use the My Journal feature of the App. 

How we share the information we collect

Other than pseudonymised analytics, we do not share the information we collect with third parties. 

In the rare occurrence that data is shared outside the European Union is shared pursuant to certain approved data transfer frameworks, such as EU-U.S. Privacy Shield.

Legal Bases for Using Your Personal Information

There are different legal bases that we rely on to use your personal information provided via the App, namely:

  • Performance of a contract – The use of your personal information may be necessary to allow you to download and use the App including to allow us to email your journal entries to you. 
  • Legitimate interests – We may use your personal information for our legitimate interests. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

Your Choices and Your Rights

You have certain rights regarding your personal information.  Every user is entitled to the following:

The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we to complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

 

If you make a request, we have one month to respond to you. We have engaged Juksta GDPR Representative Limited as our Article 27 GDPR Representative and Data Subject Requests are facilitated through their online web portal.

Web Portal: https://requests.juksta.eu/aspirant

Address: Jusksta GDPR Representative Limited, 22 Northumberland Road, Ballsbridge, Dublin 4 Ireland

Other Websites

The App contains links to external websites.  Please note that when you click on these links, you are entering a website which may have a different privacy policy.  We encourage you to be aware of other third-party websites and their privacy notices. 

How to contact us

If you have any queries about this Privacy Statement, please contact the Data Protection Officer at Aspirant.  Aspirant’s Data Protection Officer can be reached at legal@aspirant.com.  

How to contact the appropriate authorities.

You also have the right to make a complaint to the appropriate authorities.  By country they are as follows:

United Kingdom: Information Commissioner's Office: www.ico.org.uk/concerns/

Czech Republic: The Office for Personal Data Protection: www.uoou.cz

Ireland: Data Protection Commissioner: www.dataprotection.ie

Romania: The National Supervisory Authority for Personal Data Processing: www.dataprotection.ro

Important Safety Guidance When Using the Bright Sky App – January 2020

If you ever feel in danger, call your national emergency number immediately. You can do this using the emergency call feature within the app (on your mobile phone only and not smart devices) or by using the keypad on your mobile phone.

For your safety, we advise that you only download and/or use the app if you feel it is safe for you to do so (i.e. if you don’t live with the abuser) and onto a device which you feel safe using and which only you have access to.

The questionnaires within the app are designed to give you an indication of the abuse you may be experiencing in your relationship. However, this should not be taken as the only indication to determine the health of any relationship. If in doubt, please seek advice from a specialist support agency.

It is likely that if you are completing the ‘Am I at Risk?’ questionnaire, that you identify some aspects of your relationship which may indicate that you are being abused. If you are unsure, we always advise that you contact your nearest support agency, which can be found using the Find Help, Find Support Services, Call National Helplines and Resources features within the app.

Additionally, if you are completing the ‘Family or Friend at Risk?’ questionnaire, it is important to note that the result is not definitive and if you have any concern that your friend, family member, colleague is at risk, we recommend that you offer them support providing it is safe (for both of you) to do so. You can find advice on this in the ‘How Can I Help?’ section within the app. If in doubt, please seek advice from a specialist support agency.

Please note:

  • Only take the questionnaires in a private place, preferably on your own so that nobody can influence the outcome.
  • Before using the app’s 'My Journal’ feature, please read the ‘How to Use My Journal’ section. Make sure that your chosen email address to send entries is safe to use and nobody else has access to. If you need to, you can create a new email address or use a trusted friend or family member’s email. To get advice on how to create a new email address, go to the app’s i button located next to the cloud icon on the top bar.
  • The new email address you create does not need to include your name (for e.g. hot.water.bottle@icloud.com).
  • Avoid adding the newly created email address to your mobile phone and/or smart devices. You should also avoid accessing the newly created email address on your mobile phone and/or smart devices. This is so your safety is not compromised.
  • When using the 'My Journal’ feature, it is important that you enter your chosen email address correctly. Any content (text, audio, photo or video) sent to an incorrectly typed in email address will be lost and cannot be retrieved.

.           Be aware that if you send entries through the 'My Journal’ feature to an email address added to your phone or smart device, it may be the case that the media sent may get saved in your photo gallery or album. Please check your phone settings before using the ‘My Journal’ feature.

.           Please note that when using the My Journal feature on some Android devices, to send media files, and then cancel the entry and choose not to send it, the media file may still show in your device’s media gallery. In such cases, we recommend that you delete such media from your device if you have any concerns. Please seek advice on how to delete media files from your device.

 

  • Be aware that any calls made using the app, such as your national emergency number, a National Helpline or Resource or a specialist support service will appear in your phone’s call history and on the payer’s phone bill. You can delete calls from your phone’s call history if you are concerned that they may be found. If you do not know how to do this, please contact your mobile phone provider for advice or visit a phone shop providing it is safe to do so.
  • For confidentiality purposes, most of the addresses for services provided in the app’s directory are those of their local authority; and not the services own physical address. We recommend that before visiting a service, you contact them to check their location and opening hours. You can contact each service displayed in your search results by selecting the Phone icon.
  • If you are concerned about your safety, we recommend that you delete the app once you have finished using it. The app can then be re-installed when required. The store from which you have downloaded the app may show your purchase history and this may include this app even after you have deleted it. If you are concerned about the app showing in your purchase history, please contact your mobile provider for advice.

.           Be aware that after exiting the app and returning to it at a later stage, the app will open on the same page it was on previously. It is always safer to choose covert mode before exiting the app.

  • Some of the app’s content could cause distress for children under the age of 13.