Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of our website, the App, the Yepic Hub or any other products or services available to you from us.

We do not knowingly collect data relating to children who are below the age of 16 and we will collect data from children between the ages of 16 and 18 if they agree to use the App or Yepic Hub as part of their employment with the consent of their employer and parent or guardian.

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

Morpheus Limited 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 policy. If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact our data privacy manager using the details set out below:

• Name of Company: Morpheus Limited
• Email address: privacyandterms@morpheushq.com
• Postal address: 141 Farmer Ward Road, Kenilworth, Warwickshire, CV8 2SU
• Telephone number: 0333 090 4380

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

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

We keep our privacy policy under regular review and may change it from time to time.

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.

Third-party links

Our website, the Yepic Hub and/or the 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, we encourage you to read the privacy policy of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you (if applicable to your use of the App and any other products and services which we may provide) which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier (this is your mobile number), your trade/job title and (where applicable) your employer.
• Contact Data includes address, email address and telephone numbers.
• Location Data includes details of your current location disclosed by GPS technology or similar technology. 
• Content Data includes photos and information which you upload to the App and/or the Yepic Hub.
• Device Data includes the platform type of your device, the version and manufacturer of your device and your device name.
• 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, and other technology on the devices you use to access our website, the Yepic Hub and/or the App.
• Profile Data includes your username and password.
• Usage Data includes information about how you use our website, the Yepic Hub and/or the App.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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, Yepic Hub and/or 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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to enable you to use the App and/or the Yepic Hub). In this case, we may have to suspend your use of the App and/or the Yepic Hub but we will notify you if this is the case at the time.

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

Direct interactions. You may give us your Identity, Contact, Content, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Create an account on our App and/or the Yepic Hub;
• Upload content to the App and/or the Yepic Hub;
• Update your username and/or password;
• Request marketing to be sent to you;
• Give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, the Yepic Hub and/or App, we will automatically collect Device, Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the cookies section below for further details.

GPS technology or similar technology. The location-enabled features within the App and the Yepic Hub require your Location Data for such features to work. If you wish to use these particular features, you will be asked to consent to your data being used for this purpose when you subscribe to the App and/or the Yepic Hub. You can withdraw your consent at any time by disabling Location Data in your settings.

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

• Where we need to perform the contract we are about to enter into or have entered into with you, for example, in order to enable your use of the App and/or the Yepic Hub.
• 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 obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent to collect and use your Location Data and before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to us processing your Location Data by disabling Location Data in your settings and/or us or any third party sending you marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below 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. We have also identified what our legitimate interests are where appropriate.

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: To register you as a new subscriber to the App and/or the Yepic Hub

Type of data: (a) Identity (b) Contact (c) Profile (d) Device

Lawful basis for processing including basis of legitimate interest: Performance of a contract with you

Purpose/ Activity: To enable you to use the App and/or the Yepic Hub in accordance with our terms including the storage of photos, information and other content you upload to the App

Type of data: (a) Identity (b) Contact (c) Content (d) Device (e) Technical (f) Profile (g) Usage

Lawful basis for processing including basis of legitimate interest: Performance of a contract with you

Purpose/ Activity: To track your location in order for you to use certain features within the App and/or the Yepic Hub (for more information about our use of your Location Data, please see the “Location Data” section of this privacy policy below)

Type of data: Location

Lawful basis for processing including basis of legitimate interest: Consent

Purpose/ Activity: To manage our relationship with you which will include notifying you about changes to the App, our terms or privacy policy

Type of data: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation(to inform you of any changes to our terms and conditions) (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use the App)

Purpose/ Activity: To administer and protect our business, the App, the Yepic Hub and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data: (a) Contact (b) Technical (c) Device

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Purpose/ Activity: To deliver relevant website, Yepic Hub and App content and advertisements to you, to measure or understand the effectiveness of the advertising we serve to you and to monitor trends so we can improve the App and the Yepic Hub

Type of data: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how users use the App, to develop the App, to grow our business and to inform our marketing strategy)

Purpose/ Activity: To use data analytics to improve our website, the Yepic Hub, the App, products/services, marketing, relationships with our users and user experiences

Type of data: (a) Technical (b) Usage (c) Content (d) Profile (e) Device

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of users for the App and our other products and services, to keep our website and App updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/ Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

Cookies and other technologies

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 some parts of this website may become inaccessible or not function properly.

We also use technologies within our app for the purpose of improving your experience, these must be enabled in order for the app to run correctly.

For more information about how we use these, please see the section on “Cookies and Other Technologies” below.

Location data

We collect your Location Data to:

• Enable the auto enriching of visits (arrival time, departure time, and duration of visit) to your worksites inside the App and/or the Yepic Hub
• Enable us to suggest more efficient ways of working e.g. least-cost path analysis
• Enable the tagging of worksites with your information to help enable your use of the App
• Enable, with your relevant consent, the provision of location-specific offers from our partners
• Prevent and detect fraud

We collect such Location Data from your device if you enable the settings on your device and within the App and the Yepic Hub in order for us to do so. We collect such Location Data from the time you consent for us to do so by enabling location services to the point at which you withdraw your consent by disabling such location services (and we may indicate the collection of your Location Data via an icon or notification on your device, depending on your device's operating system), and any time the App and/or the Yepic Hub is running in the foreground of your device (e.g. the App is open and on-screen).

You may use the App and/or the Yepic Hub without enabling us to collect Location Data from your device. However, this may affect your ability to use certain features in the App and/or Yepic Hub. For example, if you have not consented to us processing your Location Data you will not benefit from auto enriching visits for your work locations. In addition, please note that the Location Data collected from you during a job will be linked to your customer's address, even if your customer has not enabled location data to be collected from their device.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share your personal data with the parties set out below for the purposes set out above (unless otherwise stated below).

• Amazon Web Services, based in the UK and the Republic of Ireland, for the purposes of hosting the App.
• Google Cloud, based in the UK, for the purposes of reporting data so that we are able to provide the App.
• Professional advisers, including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue and Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. 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.

We generally do not transfer your personal data outside Jersey, the UK and the Republic of Ireland.

Where we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Where we have given you (or where you have chosen) a password that enables you to access the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

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. For example, we will retain any personal data processed in relation to your use of the App for as long as remain subscribed to the App. 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 12 months, then we will treat the account as expired and your personal data may be deleted.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• 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 us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Our website and App use cookies and other technologies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website or use our app and also allows us to improve.

Lawful basis

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.

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.
  - 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.

Revision History

30th March 2021 - First draft in current format

15th September 2021 - additional location permissions

4th April 2023 – Updates made as part of general review of privacy policy