Privacy Notice & UK GDPR Compliance
Data Controller: Mobility Measure Ltd, 9 Grafton Way West Ham Ind Est Basingstoke RG22 6HY UK
Contact / DPO: info@mobilitymeasure.co.uk
1. Scope and Legal Framework
This Privacy Notice sets out how we collect, process, and safeguard your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. Categories of Data Collected
- Account Data: Name, email address, year of birth, and account authentication credentials.
- Kinematic & Sensor Data: Joint coordinate vectors, range-of-motion calculations, cadence, and velocity.
- Visual Recordings: Imaging frames containing movement sequences. All facial imagery is blurred automatically on-device prior to network transmission.
- Special Category Health Data: Mobility metrics, injury tracking self-reports, and physical assessment summaries.
- Technical Metadata: Device model, operating system version, crash diagnostics, and IP address.
3. Lawful Bases for Processing
- Explicit Consent (Article 6(1)(a) & Article 9(2)(a)): For capturing movement video footage and processing physical mobility metrics.
- Contractual Necessity (Article 6(1)(b)): To deliver account access, synchronise your analytical progress, and maintain app functionality.
- Legitimate Interests (Article 6(1)(f)): To monitor network health, prevent fraudulent access, and maintain application security.
4. Facial Obfuscation and Network Transmission
- Facial anonymisation occurs in local device memory before any data leaves your handset.
- Obfuscated image streams are encrypted in transit using TLS 1.3 or higher and at rest using AES-256 standards.
- Unblurred image frames are retained strictly in volatile device memory and wiped immediately upon completion of the recording session.
5. Third Parties and International Data Transfers
We do not sell your data. We share obfuscated video sequences and calculated telemetry only with trusted data processors under strict Data Processing Agreements. If data is processed outside the UK, we ensure adequate safeguards are in place.
6. Data Retention
- Blurred Visual Files: Stored on secure cloud infrastructure for 30 days to enable analytical calculation, after which raw imagery is purged.
- Kinematic Metrics: Stored for as long as your account remains active, or until you request erasure.
7. Your Statutory Rights Under UK GDPR
- Right to access: Request a copy of the personal data held about you.
- Right to rectification: Correct inaccurate or incomplete data.
- Right to erasure: Request deletion of your account and associated visual recordings.
- Right to withdraw consent: Revoke consent for processing health data at any time through the App settings.
- Right to object and restrict processing: Limit how we utilise specific datasets.
To exercise any of these rights, contact our Data Protection Officer at info@mobilitymeasure.co.uk. If you are unsatisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.