Updated April 2025
This Privacy Statement explains how Aspirant collects and processes information through your use of the Bright Sky app (the “App”). We invite you to read this privacy statement, which describes our privacy settings and security practices. We want you to understand when and how data is handled by us through your use of the App. As processes improve and change, we reserve the right to make changes to this policy from time to time, please check here for the most up-to-date version.
Collection of personal information
“Personal information” is any information that can be used to identify you or that we can link to you.
Information we collect from you
We collect, process and use personal information when you download and use the App.
The information we collect includes the information that you provide when you use the App including:
- Information that you enter when using the My Journal feature of the App;
- Your email address.
We also receive information automatically when you download the App including:
- Actions:
- The number of daily and monthly installs for V1, V2 and Vs1&2
- Opened Application
- Took assessment (V1 only)
- Start Assessment – Am I At Risk
- Complete Assessment – Am I At Risk
- Start Assessment – Friends/Family At Risk
- Complete Assessment – Friends/Family At Risk
- Start Assessment – Myths
- Complete Assessment – Myths
- Called Advocate
- Called National Resource
- Searched for location – By Postal code/Other
- Searched By Current Location
- Clicked content link (in app text)
- Clicked Content Link (in menu)
- Sent Photo Journal
- Sent Text Journal
- Sent Video Journal
- Sent Voice Journal
- Called Emergency Phone Number
- Open Guide – Online Safety Guide
- Open Guide – Sexual Consent
- Open Guide – Stalking & Harassment
- Open Guide – Forms of Abuse
- Open Guide – Types of Support
- Open Guide – How Can I Help
- Open Guide – Leaving Abusive Relationship
- Users:
- The operating system of your device (Apple and Android) for V1 and Vs1&2.
- Cover Mode Used
- Language(s) selected
How we use the information we collect
When you use the My Journal feature of the App and provide information, this information will not be saved onto your device, the app or our server. We do not save or have access to any entries that you send using the My Journal feature.
Your journal entries will be emailed to you if you enter an email address. We only collect the email address in order to facilitate your record keeping of your entries using the My journal feature, but we will not keep a record of the email address or the content of the entries. You will need to provide the email address each time you use the My Journal feature of the App.
How we share the information we collect
Other than pseudonymised analytics, we do not share the information we collect with third parties.
In the rare occurrence that data is shared outside the European Union is shared pursuant to certain approved data transfer frameworks, such as EU-U.S. Privacy Shield.
Legal bases for using your personal information
There are different legal bases that we rely on to use your personal information provided via the App, namely:
- Performance of a contract – The use of your personal information may be necessary to allow you to download and use the App including to allow us to email your journal entries to you.
- Legitimate interests – We may use your personal information for our legitimate interests. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.
Your choices and your rights
You have certain rights regarding your personal information. Every user is entitled to the following:
- The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
- The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we to complete the information you believe is incomplete.
- The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
- The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. We have engaged Juksta GDPR Representative Limited as our Article 27 GDPR Representative and Data Subject Requests are facilitated through their online web portal.
Web Portal:
- EU: https://aspirantltd.gdprlocal.com/eu (opens in a new tab)
- UK: https://aspirantltd.gdprlocal.com/uk (opens in a new tab)
Address:
- EU: INSTANT EU GDPR REPRESENTATIVE LIMITED Office 2 12A Lower Main Street, Lucan Co. Dublin K78 X5P8 Ireland
- UK: GDPR Local Ltd 1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB
Other Websites
The App contains links to external websites. Please note that when you click on these links, you are entering a website which may have a different privacy policy. We encourage you to be aware of other third-party websites and their privacy notices.
How to contact us
If you have any queries about this Privacy Statement, please contact the Data Protection Officer at Wavestone. Wavestone’s Data Protection Officer can be reached at dpo@wavestone.com.
How to contact the appropriate authorities
You also have the right to make a complaint to the appropriate authorities. By country they are as follows:
- United Kingdom: Information Commissioner’s Office: www.ico.org.uk/concerns/ (opens in a new tab)
- Czech Republic: The Office for Personal Data Protection: www.uoou.cz (opens in a new tab)
- Ireland: Data Protection Commissioner: www.dataprotection.ie (opens in a new tab)
- Romania: The National Supervisory Authority for Personal Data Processing: www.dataprotection.ro (opens in a new tab)