This Privacy Policy explains how Bullet AI (Trading name of Red Bullet Web Development Ltd) & Medway Council ("we," "us," or "our") collects, uses, shares, and protects the personal information of individuals who use our Quit Coach (AI powered stop smoking support tool) ("the Tool").

1. Information We Collect

When you use the Tool, we may collect the following information:

• Personal Information:
  • Name
  • Contact details (phone number, email address)
  • Date of birth
  • Gender
  • GP practice
  • Address
  • Your Smoking habits
  • NRT (Nicotine Replacement Therapy) product selection
  • Profiling data (e.g. ethnicity, sexual orientation, disabilities)
• Usage Data:
  • Information about your interactions with the Tool, such as the features you use and the pages you visit.
• Technical Data:
  • Information about your device and internet connection, such as your IP address and browser type.

2. How We Collect Information

We collect information directly from you when you:

• Register for the Tool
• Use the Tool's features
• Interact with our customer support team

3. How We Use Your Information

We use your information for the following purposes:

• Providing and improving the Tool:
  • To provide you with the stop smoking support services
  • To personalise your experience with the Tool
  • To develop and improve the Tool's features and functionality
• Communicating with you:
  • To send you updates, notifications, and other communications related to the Tool
  • To respond to your inquiries and requests
• Monitoring and improving our services:
  • To analyse usage patterns and identify areas for improvement
• Complying with legal and regulatory obligations:
  • To comply with applicable laws and regulations, such as data protection laws.

4. Data Security

We take appropriate security measures to protect your information from unauthorised access, use, or disclosure. These measures include:

• Data security: Your personal information is encrypted in transit and securely stored using industry-standard protection measures
• Secure data storage: Your data is stored on secure servers hosted in a UK-based AWS data centre.
• Access controls: Only authorised members of the council and approved members of the Bullet AI team can access the data portal, with access requiring two-factor authentication (2FA).

5. Data Sharing

We may share your information with the following parties:

• Council smoking advisors: For the purpose of providing you with support and monitoring your progress.
• Service providers: We may share your information with third-party service providers who assist us in providing the Tool, such as data storage providers and customer support providers. These service providers are contractually obligated to protect your information.

6. WhatsApp Integration

• We use WhatsApp to engage with you through an AI-powered coach.
• No requested personal data is transmitted through WhatsApp's infrastructure.
• The WhatsApp chat transcript is held on a separate platform (Brava) and can be reviewed by council smoking advisors. This data is also encrypted in transit and at rest. Chat transcripts are reviewed for monitoring and safeguarding purposes.
• If any data capture is needed, you will be provided with a link to a secure web page that connects to the data portal. No data will ever be requested directly within the WhatsApp chat.

7. Your Rights

You have the following rights regarding your personal information:

• Access: You have the right to request access to the personal information we hold about you.
• Correction: You have the right to request the correction of any inaccurate or incomplete personal information we hold about you.
• Erasure: You have the right to request the erasure of your personal information in certain circumstances.
• Restriction: You have the right to request the restriction of processing of your personal information in certain circumstances.
• Data portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• Objection: You have the right to object to the processing of your personal information in certain circumstances. You should contact us in this case.

8. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at [email protected]

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated Privacy Policy on our website.

10. Data Ownership, Controller, and Processors

• Data Controller: Bullet AI is acting as the data processor for the council. The council is the data controller and ultimately responsible for determining the purposes and means of processing personal data.
• Data Processor: Bullet AI processes personal data on behalf of the council as instructed and in accordance with the council's instructions and applicable data protection laws.
• Data Ownership: The council owns the data collected through the Tool.