Moki

Privacy Policy

This Privacy Notice tells you what you can expect if you are using a MokI band or are part of a Group, School or Organisation that is using MoKi technology.

About MoKi:

“MoKi” and “MoKi Bands” are  products of Moki Technologies Limited, a Company registered in England & Wales (Company number: 11266496) with it’s registered offices at, Unit 10, 1 Luke Street, London, UK, EC2A 4PX

Data Controller and Data Protection Officer Contact Details

Moki Technologies Limited is the Data Controller for all personal information that we process unless stated otherwise.

Moki Technology is registered with the Information Commissioner's Office - registration number: ZA439656

Entry details can be found here:

https://ico.org.uk/ESDWebPages/Entry/ZA439656

You can contact our Data Protection Officer directly using the following methods:

Email:

dataprotection@mokibands.com


Post:

Data Protection Officer

Moki Bands

Unit 10,

1 Luke Street,

London, UK,

EC2A 4PX


Our Legal Basis for Processing

Under the General Data Protection Regulations (GDPR)  there are various legal basis for processing of data.

The legal basis that MoKi uses is Consent or Legitimate Interests.

This means that all the users of Moki Technologies have consented and where that individual is a child aged 13 or under we will always require Consent from the appropriate parent or guardian.  Where Consent is not used for processing data then we rely on Legitimate Interest as our legal basis of processing and we will have conducted appropriate LIA’s (Legitimate Interest Assessments) to ensure Privacy is at the forefront of how we process any data.

Privacy by Design

Moki has been developed using a Privacy by Design approach, this means that Privacy and Information Security has been at the heart of the Moki solution through all areas of development and we do not request, hold nor process any data that is not essential to the delivery of the core service.  

Any data that we do collect about our users is other Anonymized and remains at the local level or is Encrypted during transit and at rest.  

What Information do we Process?

In order to carry out our day to day operations and offer the benefits to MoKi users we obtain the following information, either directly for you or from our Customer.

This is the maximum information that will be collected, in some cases only part of this data will be collected depending on what level of service is requested


Data Subject
(Whose data is this?)
Data Category
(What data is obtained?)
Description of the Data Collected
How is data captured and where is it stored?
Security if data is transmitted to Moki servers

The individual who will wear the MokI band

Forename

The Forename of the individual

Provided by school, Stored locally within the Moki Application and anonymised.

Not Applicable - data is anonymised

The individual who will wear the MokI band

Surname

The Surname of the individual

Provided by school, Stored locally within the Moki Application and anonymised.

Not Applicable - data is anonymised

The individual who will wear the MokI band

DOB

The date of birth of the individual

Provided by school, Stored locally within the Moki Application and on Moki secure servers

Encrypted within the application and secured in transit and at rest. Encryption key held by DPO and School

The individual who will wear the MokI band

Gender

The gender of the individual

Provided by school, Encrypted and stored locally within the Moki Application and on Moki secure servers

Encrypted within the application and secured in transit and at rest. Encryption key held by DPO and School

The individual who will wear the MokI band

Group / Class

The Group or Class that the individual  is linked to (for example - class 4R)

Provided by school, Stored locally within the Moki Application and anonymised.

Not Applicable - data is anonymised

The individual who will wear the MokI band

Organisation / School

The Organisation that the individual  is linked to (for example - Beachwood School)

Provided by school, Stored locally within the Moki Application and anonymised.

Not Applicable - data is anonymised

The individual who will wear the MokI band

Step Data

The number of steps that the individual makes

Provided by school, Encrypted and stored locally within the Moki Application and on Moki secure servers

Encrypted within the application and secured in transit and at rest. Encryption key held by DPO and School

The individual who purchases MoKi bands on behalf of their Organisation / Group

Forename

The Forename of the individual

Provided by the individual. Encrypted and stored locally within the Moki Application and on Moki secure servers

Encrypted within the application and secured in transit and at rest. Encryption key held by DPO and School

The individual who purchases MoKi bands on behalf of their Organisation / Group

Surname

The Surname of the individual

Provided by the individual. Encrypted and stored locally within the Moki Application and on Moki secure servers

Encrypted within the application and secured in transit and at rest. Encryption key held by DPO and School

The individual who purchases MoKi bands on behalf of their Organisation/Group

DOB

The date of birth of the individual

Provided by the individual. Encrypted and stored locally within the Moki Application and on Moki secure servers

Encrypted within the application and secured in transit and at rest. Encryption key held by DPO and School

The individual who purchases MoKi bands on behalf of their Organisation / Group

Gender

The gender of the individual

Provided by the individual. Encrypted and stored locally within the Moki Application and on Moki secure servers

Encrypted within the application and secured in transit and at rest. Encryption key held by DPO and School

The individual who purchases MoKi bands on behalf of their Organisation / Group

Postal Address

The Postal address of the individual

Provided by the individual. Encrypted and stored locally within the Moki Application and on Moki secure servers

Encrypted within the application and secured in transit and at rest. Encryption key held by DPO and School

The individual who purchases MoKi bands on behalf of their Organisation / Group

Payment Card Details

The payment details used to purchase MoKi

Provided by the individual. Encrypted and stored locally within the Moki Application and on Moki secure servers

Encrypted within the application and secured in transit and at rest. Encryption key held by DPO and School

The individual who purchases MoKi bands on behalf of their Organisation / Group

Email Address

The Email address of the individual

Provided by the individual. Encrypted and stored locally within the Moki Application and on Moki secure servers

Encrypted within the application and secured in transit and at rest. Encryption key held by DPO and School

The individual who purchases MoKi bands on behalf of their Organisation Group

Telephone Number

The Telephone Number of the individual

Provided by the individual. Encrypted and stored locally within the Moki Application and on Moki secure servers

Encrypted within the application and secured in transit and at rest. Encryption key held by DPO and School


How We Process Your Personal Information

We use your personal information only to the extent that is required for us to carry out the services on behalf of our Customer.  Key identifiable data about our individual users is anonymised and never transmitted outside of the application within the class or other group environment.  This ensures that PII data (Personally Identifiable Information) is not transmitted outside of the class environment.

MokI has been developed with your Privacy in mind and we have taken appropriate technical and organisational measures to protect the confidentiality and integrity of your data during storage, transit and all processing activities.

Sharing Personal Information with Third Parties

We go through a stringent due diligence process when we select any third parties to work with to ensure their ethics, policies and processes are in line with our own.


These Third Parties include:


Type of Service
Reason why we would share data with them

Email Service Provider (ESP)

So that we are able to communicate to our customers and MoKi users about the products and services via email

SMS Providers

So that we are able to communicate to our customers and MoKi users about the products and services via SMS

Payment Processors

So that we can securely take payments from our Customers

Hosting Providers

So that we can provide our services to Customers and that data can be held within a secure data centre


We will only access you personal information where it is required to supply the services.  We will only disclose your information to parties not listed in our Privacy Notice in the following circumstances:


Your Rights

Under data protection law you have rights we need to make you aware of, these are listed below.  

Please contact our Data Protection Officer to discuss any of these rights and how we may assist.

Your right of access:

You have the right to ask us for copies of your personal information

Your right to rectification:

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete

Your right to erasure:

You have the right to ask us to erase your personal information in certain circumstances

Your right to restriction of processing:

You have the right to ask us to restrict the processing of your information in certain circumstances

Your  right to data portability:

This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you.

Data Retention and Erasure Policy

We will only retain information for as long as necessarily required  to deliver the services to our Customers safely and securely.

Our data retention policy is based on specific data types that we process;



Type of Information collected & Stored

Can a unique individual be identified by this data?

Retention Period (maximum)

MoKi Player Account information

No

24 months from capture date

Moki band identifier information

No

24 months from capture date

MokI Customer Account information, name of organisation and associated details

Yes

12 months from capture date



Changes to our Privacy Policy

This Privacy Policy goes through regular reviews and is updated where appropriate, revised version will be visible on our websites.

Contact Us

Email: 

dataprotection@mokibands.com


Post:

Data Protection Officer

Moki Bands

Unit 10,

1 Luke Street,

London, UK,

EC2A 4PX