At ZANEC, as the service provider for Recovery 360, we value your privacy and take the protection of your personal data seriously. Recovery 360 app powered by AlcoChange® (iOS & Android) (the "App") is operated by ZANEC as a Digital Therapeutic as a Service (DTaaS), with CyberLiver® Ltd serving as the data controller and licensed provider of the AlcoChange® DTx platform. This Privacy Policy is intended to inform you about how we handle and protect your personal data when you use the App.
If a user registers for Recovery 360 products and services, CyberLiver® will act as the data controller for any personal data collected, with ZANEC acting as the data processor and service provider.
Please review the Terms of Use for Recovery 360 when you sign up for the app.
This Privacy Policy aims to provide details on how personal data is collected and processed when you interact with the Recovery 360 app powered by AlcoChange®, including all features within the App.
In addition, this policy outlines your legal rights concerning the use, access, and correction of your personal data. If you disagree with the data practices outlined in this Privacy Policy, we advise you to refrain from using the App. By using the App, you are presumed to have accepted and agreed to the terms outlined in this Privacy Policy.
ZANEC is the data processor and service provider for the Recovery 360 app.
To address any inquiries you may have about this Privacy Policy or how we handle your information, you can contact us by emailing [email protected].
We keep this Privacy Policy under regular review. We will post any changes to this Privacy Policy on this page. If the changes are significant, we will provide more prominent notice by sending you a notification in the App, and you may be required to read and accept the changes to continue your use of the App.
While we notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically. Historic versions can be obtained by contacting us.
The personal data that we hold about you must be accurate and current. Please keep us informed if your personal details change during our relationship.
The Recovery 360 app powered by AlcoChange® is not intended for or targeted at children under 18; we do not knowingly or intentionally collect information about children under 18. If you believe we have collected information about a child under 18, please get in touch with us at [email protected] so we may delete the information.
The App may include links to third-party websites, plug-ins and applications. Clicking or enabling those links may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the App, we encourage you to read every website's privacy policy.
The Recovery 360 app might be connected to third-party devices and sensors, including a digital breathalyser.
Users can Sign up for Recovery 360 programme from the apps. When you visit the App Store or Play Store and signup to use the App, we will request that you provide personal data about yourself (including first name, last name, date of birth, email address, weight, height and gender) and you will also be asked to create a unique password.
You may upload a profile photo to your account within the App either when you sign up to the App or at any time when you use the App. You do not have to upload a profile photo, and you can remove your profile photo at any time.
You will be asked to supply personal and special category data when using the App. We will use this information to enable the use of our services.
This refers to any information that you voluntarily submit to us when you signup and Use the App, and that identifies you personally, including contact information, such as your first and last name, e-mail address, date of birth, gender, location (including postcode and country) height, weight, weekly drinking average, and other information about yourself which you've provided.
Special category data also includes your digital biomarker data and health-related data measured through sensors and services through the Recovery 360 app including your abstinence, alcohol consumption, nutrition (food, fluid etc.,), sleep activity, physical activity, drink location, coping strategies, triggers, personal interests (ex., music, sports, etc.,) and time stamp of the activities in the App.
Optional access to Name and contact number of supportive friends or family from phone contacts or phonebook.
Permission to turn on notifications, Bluetooth (to connect breathalyser or wearable devices), and turn off battery optimisation to run the app in the background.
When using the HelpDesk support bot inside the app, you will be asked to provide your name and email address for any technical support, and this information will be stored in our database. We will use this information to contact you to provide any technical support.
We may also collect information your browser, or App sends whenever you visit the App (Log Data). This Log Data may include information such as your devices Internet Protocol (IP) address, device model, IMEI number, battery percentage, permissions, browser type, browser version, the pages of our Website or App that you visit, the time and date of your visit, and the time spent on those pages, mobile UDID, geo-localisation data, and other statistics. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
In addition, we use third-party services such as Google Analytics to collect, monitor and analyse this information to improve our App functionality and make your experience more enjoyable.
We may link the information stored within the analytics software to personal data you submit within the App. We do this to improve your services and our marketing, analytics and site functionality.
In addition, when you use the App, we may collect your city location, precise and approximate location (optional), phone model and version, device identifier (or UDID), OS version, and Recovery 360 account credentials.
We don't collect your personal data from publicly available sources such as social media websites unless you specifically request support by posting your personal information on our social media handles and managed communities. We might use this information provided by you on social media and managed communities to help improve your services.
Location Data: We also use GPS technology to determine your current location. Some of our location-enabled services within the App require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to the use of your personal data. You can withdraw your consent anytime by disabling Location Data in your settings.
Our legal basis for collecting and using the personal data described above will depend on the personal data and the specific context in which we collect it. However, we will generally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Sometimes, we may also legally be obligated to collect your personal data.
When you install the Recovery 360 app powered by AlcoChange®, please register as a user and subsequently use the App and its features. You consent to us processing the personal data you have provided us under this Privacy Policy.
If we ask you to provide personal data to comply with a legal requirement, we will make this clear at the relevant time and advise you whether providing your personal data is mandatory (as well as the possible consequences if you do not provide your personal data).
We will rely on your consent to process any Special Categories of Personal Data you voluntarily disclose. You do not have to tell any Special Categories of Personal Data to use the App. By voluntarily providing Special Categories of Personal Data to us, we will proceed on the basis that you have given your consent to the processing of the Special Categories of Data disclosed to us.
If we collect and/or use your personal data in reliance on our legitimate interests (or those of any third party), this interest will usually be to operate our business and communicate with you as necessary to provide our services to you or for our legitimate commercial interest including, but not limited to:
Unless you tell us otherwise, undertaking marketing of any or all of the services that we provide (either directly or through our authorised third parties) and which we consider may be of interest to you and which we will notify you via push notifications in the App;
To monitor trends so that we can improve the App;
to detect or prevent illegal activities or where we need to comply with a legal obligation, or 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.
We send push notifications from time to time in the App as motivational messages to update you about your progress, events or promotions. You may turn them off at the device level if you no longer wish to receive such communications.
We will get your consent before sending direct marketing communications to you via email or text message. You can withdraw consent to marketing at any time by contacting us.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we use your data. Please get in touch with us if you need details about the specific legal ground we rely on to process your personal data.
We post user testimonials and comments on our App pages, Play Store, App Store, Social media promotions, websites, and portal, which may contain personal data. We obtain each user's consent via email before posting the user's name and testimonial.
We use various security technologies and procedures to help protect your personal data from unauthorised access, use or disclosure. We secure the personal data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All personal data is protected using appropriate physical, technical and organizational measures.
The App might include Social Media Features, such as the Facebook/Google Login and Facebook Like buttons and Widgets, such as the Share This button or interactive mini-programs that run in the App. These features may collect your IP address and which page you visit on our apps and set a cookie to enable the feature to function correctly. Social Media Features and Widgets are hosted by a third party or hosted directly on the App. This Privacy Policy does not apply to these features. The companies' privacy and other policies govern your interactions with these features.
The App may provide links to other websites. We do not control and are not responsible for the content or practices of these other websites. Providing such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.
Our App provides public message boards, blogs, and community forums that are accessible to all. Any information you disclose directly on these platforms may be collected and used by third parties. If you wish to have any posted information corrected or removed, please refer to the "Opting Out and Unsubscribing" section below for instructions on how to do so.
We will never sell your personal data to a third party.
Per the terms and conditions agreed in the collaboration agreement between the collaborators of Recovery 360 real-world RCT, you agree that we may disclose your personal data to the collaborators.
We might use your anonymised data to apply for regulatory compliance with our products in the future.
We may disclose your personal data to service providers who provide data processing services to us or whose services are integral to the delivery of our services to you (for example, to the provision of services to you according to a contract that you have entered into with us or to support the delivery of, provide functionality on, or help to enhance the security of the App), or who otherwise process personal data for purposes that are described in this Privacy Policy or notified to you when we collect your personal data.
We may disclose your personal data to professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services. HMRC
We may disclose your personal data to HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who may require reporting of processing activities in certain circumstances.
We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may interest you. We will only send you marketing information by email whilst you have opted into our marketing database.
We may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide user support. We work with experts within our organisation and trusted partners who might use the personal data collected from you to do analysis, research, and release the results in the public domain. We ensure the user identity is anonymised whenever the research results are published and not shared with any third party. We might use the collected personal data for research based on the consent received during sign-up.
We may contact you for consent if you want to participate in future research and sign a separate privacy and research agreement.
We may share your personal data with third parties to whom we may sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your data like this Privacy Policy.
We reserve the right to use or disclose your personal data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
All third parties to which we disclose your personal data are prohibited from using your personal data except for the purposes for which that data has been disclosed to them, and they are required to maintain the confidentiality of your information.
Certain of our third-party suppliers are based outside the European Economic Area (EEA); therefore, their processing of your personal data will involve a transfer of data outside of the EEA. When we transfer your personal data from the EEA, we use the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed unauthorised, 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 are subject to a duty of confidentiality.
We have established procedures to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.
You have the following data protection rights:
To exercise any of these rights, please get in touch with us at [email protected]. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of our actions.
You may unsubscribe from our communications by clicking on the "unsubscribe" link at the bottom of our e-mails, updating your communication preferences, or emailing us at [email protected]. Users cannot opt out of receiving transactional emails related to their accounts.
Visit us at ZANEC Recovery 360
If you have any questions about how we use your personal data or want to exercise your rights over your information, you can email us at [email protected] or [email protected].
This policy was last updated on April 03, 2025. We may update it at any time.
Please refer to this page for the latest Privacy policy for the Recovery 360 app.
Please find the previous versions of the Privacy policy below.