Privacy Policy

Welcome to the Beam Privacy Policy

Beam respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal
data and for what purposes, and your rights in relation to your personal data.
Prior to installation of this App, you will be asked to indicate your consent to our processing of your personal data (including your name,
contact details and device information) as described in this policy
YES, I consent to the installation of the App. Beam captures, visualises, and interprets your emotions and indictive behaviours, allowing
you to better understand your everyday life, help reduce unnecessary stress. It “helps you to help yourself” by understanding and
interpreting your emotional triggers and behaviour patterns, establishing an optimistic and resilient mind-set to help you become more
confident and productive in your everyday life
NO, I do not consent to the installation of the App.
How you can withdraw consent
Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us
at info@beamandme.com but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
BEAM (we) are committed to protecting your personal data and respecting your privacy.
Introduction
This policy applies to your use of:
• BEAM mobile application software (App) once you have downloaded a copy of the App onto your mobile telephone or
handheld device (Device).
• Any of the services accessible through the App (Services). This policy sets out the basis on which any personal data we collect
from you, or that you provide to us, will be processed by us. This App is not intended for children, and we do not knowingly
collect data relating to children. Please read the following carefully to understand our practices regarding your personal data
and how we will treat it.
This policy is provided in a layered format so you can click through to the specific areas set out below.
IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED?
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY
DESCRIPTION OF CATEGORIES OF PERSONAL DATA
Important information and who we are
Beam is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).
Contact details
Our full details are:
• Full name of legal entity: Tutto Limited
• Email address: info@beamandme.com
• Postal address: 30 Binley Road, Coventry, West Midlands, United Kingdom, CV3 1JA
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data
protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
This version was last updated on 23.12.2023. It may change and if it does, these changes will be posted on this page and, where
appropriate, notified to you when you next start the App. The new policy may be displayed onscreen, and you may be required to read
and accept the changes to continue your use of the App or the Services.
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 our relationship with you.

The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
• Identity Data.
• Contact Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Location Data.
We collect data to allow us to inter alia register you as a user of the App. 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 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 collect limited data re any Special Categories of Personal Data about you (but not details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, nor do we collect any information about
criminal convictions and offences.)
How is your personal data collected?
We will collect and process the following data about you:
• Information you give us. This is information (including Identity, contact data and Profile data) you consent to giving us about
you by filling in forms on the App.
• Information we collect about you and your device. Each time you use our App we will automatically collect personal data
including Device, and Usage Data.
How we manage third party Integrations via API or other Integrations
Beam facilitates the sharing of your personal data from third party apps, plugins, or websites that integrate with our App Services such as
health, personal finance, screen time as well as with third parties who work with Beam such as TrueLayer to allow us to offer integrated
features. You can choose to share your profile data and activity data. If you click on the “Connect your Data” link and subsequent
authorisations, you will leave our platform and the third party will be able to identify that you visited their platform from Beam.
Information collected by these third parties is subject to their terms and policies. Beam is not responsible for the terms or policies of third
parties.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following
circumstances:
• Where you have consented before the processing.
• Where we need to perform a contract, we are about to enter or have entered with you.
• 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 or regulatory obligation.
• Only accessed, stored, or processed where necessary for the operation of your account in accordance with data minimisation
principles
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that
consent at any time by contacting us.
We will not share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data

Purpose/activity To install the App and register
you as a new App user

Type of data Identity Contact Device

Lawful basis for
processing Your Consent

Purpose/activity To Deliver Services

Type of data Identity Contact Device Location

Lawful basis for
processing

Your Consent Performance of a
contract with you. Necessary for
our legitimate interests

Purpose/activity To manage our relationship with
you including notifying you of
changes to the App or any
Services

Type of data Identity Contact Profile

Lawful basis for
processing

Your consent Performance of a
contract with you Necessary for
our legitimate interests (to keep
records updated and to analyse
how customers use our
products/Services)

Purpose/activity To enable us to use your data to
make recommendations to you in
accordance with the purpose of
the App

Type of data Identity Contact Device Profile

Lawful basis for
processing

Performance of a contract with
you Necessary for our legitimate
interests (to analyse how our
customers use our
products/Services and to develop
them and grow our business)

Purpose/activity To administer and protect our
business and this App including
troubleshooting, data analysis and
system testing

Type of data Identity Contact Device

Lawful basis for
processing

Necessary for our legitimate
interests (for running our
business, provision of
administration and IT services,
network security)

Purpose/activity To deliver content to you

Type of data Identity Contact

Lawful basis for
processing Consent

Purpose/activity To monitor trends so we can
improve the App

Type of data Device Content Profile Usage

Lawful basis for
processing

Necessary for legitimate interests
(to develop our products/Services
and grow our business)

Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the
third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• 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
International transfers
Where an external third party is based outside the EEA their processing of your personal data will involve a transfer of data outside the
EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least
one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for
personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of
personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give
personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the
transfer of personal data to third countries
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires
them to provide similar protection to personal data shared between Europe and the US. For further details, see European
Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the
EEA
Data security
Your personal data will be stored and processed on Amazon Web Services (AWS). All data is encrypted and protected and can’t be
accessed by anyone except the Beam technical team. All passwords are also encrypted and can’t be seen by anyone including Beam
admin. There will be no advertising directly served to you on Beam and your data will not be shared. We ask you not to share a password
with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from
being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures as part of the Beam Security Policy to deal with any suspected personal data breach and will notify you
and any applicable regulator when we are legally required to do so.
Data retention
By law we must 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 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.
If you do not use the App for a period of 24 months then we will treat the account as expired and your personal data may be deleted.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You have the right to request that you are not subject to any decisions or insights generated by Beam based solely on automated
processing.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can report any knowledge of a child accessing the app and providing personal data, without parental consent.
You can exercise any of these rights at any time by contacting us at Tutto Limited 30 Binley Road, Coventry, West Midlands, United
Kingdom, CV3 1JA or info@beamandme.com
We commit to respond to any request within 30 working days.
Glossary
Lawful basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a
specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can

withdraw your consent at any time by contacting us. Should the purpose of data collection change, you will be informed, and consent will
be re-obtained.
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.
Third parties
Internal third parties
Other persons acting as controllers or processors and who are based in the UK provide IT and system administration services and
undertake leadership reporting
External third parties
Service providers who provide IT and system administration services
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting
services
HM Revenue and Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
Our Commitment
We are committed to ensuring protection of all personal information that we hold, and to provide and to protect all such data. We
recognise our obligations in updating and expanding this program to meet the requirements of GDPR.
We are dedicated to safeguarding the personal information under our control and in maintaining a system that meets our obligations
under GDPR 2018. Our practice is summarised below.
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:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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; or
(d) 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.
Description of categories of personal data
• Identity Data: first name, last name, maiden name, username or similar identifier, title, date of birth, gender
• Contact Data: billing address, delivery address, email address and telephone numbers
• Transaction Data: includes details about payments to and from you and details of in-App purchases.
• Device Data: includes the type of mobile device you use a unique device identifier [(for example, your Device’s IMEI number,
the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device) mobile network
information your mobile operating system, the type of mobile browser you use, time zone setting,.

• Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey
responses.
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to,
whether this is required for our own billing purposes or otherwise and the resources that you access
How we protect your data and what data breach procedures we have in place
• We are using SSL/HTTPS encryption throughout any data transfer. This encrypts our user communications with the servers so
personal identifiable information is never captured by third parties without authorization.
• Databases are sanitized (actual user personal details are removed) before deploying to development or testing environment.
• In case of a data breach, System Administrators will immediately go through affected users and will attempt to reset passwords
if needed after informing the user.
• Should you suspect a data breach has occurred, please contact out Data Protection Officer using the details at the end of this
policy.
How to contact us or complain
If you have any concerns or queries about our use of your personal information, you can contact our Data Protection Officer Georgina
Magnani at Tutto Limited 30 Binley Road, Coventry, West Midlands, United Kingdom, CV3 1JA or info@beamandme.com.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk