Air Free

If you would like your account and associated data to be deleted, please use the contact form below to provide details of the email address and phone number you have used to login to the app. All your data will be permanently deleted.

We may contact your to confirm that you are the authorised user of the app.

Red Star Air Free Asthma App Privacy Policy – App Users – v1.1

Type of system: A pilot system to collect data from users to allow them to manage and understand their asthma.
Effective date: 1st day of October, 2025

Red Star Air Free app (the “Site” or the “App”) is owned and operated by Red Star AI Ltd. Red Star AI Ltd is the Data Controller and can be contacted at:

support@redstar.ai

The Red Star Air Free App is used to collect data from users to support self-management of their asthma.

Purpose
The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:

  1. The personal data we will collect;
  2. Use of collected data;
  3. Who has access to the data collected; and
  4. The rights of Site users.

This Privacy Policy applies in addition to the terms and conditions of our Site.

GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

Consent
By using our Site users agree that they consent to:

  1. The conditions set out in this Privacy Policy.

Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

For data which users enter into the system (e.g. details of symptoms) we rely on the following legal basis to collect and process the personal data of users in the EU:

1.   Consent of the data subject.

Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site:

  • First and last name;
  • Email address;
  • Phone number;
  • Postcode;
  • Symptoms (e.g. how is your asthma today);
  • Details of Parents (where the user is below 12 in Scotland or 13 in England and needs parental consent);
  • Asthma Control Test;
  • Asthma Action Plan;
  • Messages sent or received;

This data may be collected using the following methods:

  1. Through online forms completed by users in the the App

Data collected in an automatic way

Where the user has consented, we will collect the following information through integration with the user’s device. Users can turn this off in the Settings menu

  • Coughing – where the user has provided access to the device microphone and selected to record, we will record coughs which are detected. We will only store a timestamp of when the cough was recorded. We will not store any audio or recording data
  • Location – where the user has consented to store location, we will collect and store details of the location from the user’s device
  • Steps – where the user has consented, we will collect a daily count of steps from Android Health Connect or iOS Health App

How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect when the user performs certain functions may be used for the following purposes:

  • To allow users to enter details of their asthma symptoms and track these over time
  • To display a users Asthma Action Plan
  • To allow user to enter details of their Asthma Control Test and track results over time
  • To facilitate remote monitoring by healthcare professionals where users have consented to share this data
  • To understand if the user is coughing more frequently
  • To understand if there is a change in the user’s daily activity in terms of daily step count
  • To understand the user’s location and alert them if there are high pollen or pollution levels in the user’s location
  • To aggregate the data to understand at a population level who the users of the system are and how the App helps them improve asthma control

Who We Share Personal Data With
Employees
We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Third Parties
We may share user data with the following third parties:

  1. Gov.uk notify (https://www.notifications.service.gov.uk/)

The following data is shared with Gov.uk notify:

  1. Email addresses
  2. Phone numbers

We may share user data with Gov.uk notify for the following purposes:

  1. To send invitations, reminders and alerts in relation to the service
  2. To send emails and text messages to support logins to the service

We may share the user’s device identifier and text of notifications with 650 Industries Inc (also known as ‘Expo’) where the user has provided access through their device. Users may turn this off through settings. No personally identifiable information will be contained in the notification text. This is shared for the following purpose:

  1. To enable push notifications to the user’s device

Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.

Other Disclosures
We will not sell or share your personal data with other third parties, except in the following cases:

  1. If the law requires it;
  2. If it is required for any legal proceeding;
  3. To prove or protect our legal rights; and
  4. To buyers or potential buyers of this company in the event that we seek to sell the company.

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

How Long We Store Personal Data
User data will be stored until the purpose the data was collected for has been achieved.

You will be notified if your data is kept for longer than this period.

How We Protect Your Personal Data
All data is encrypted on transit, requires a secure login to access, and our system has been security tested by experts

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

Your Rights as a User
Under the GDPR, you have the following rights:

  1. Right to be informed;
  2. Right of access;
  3. Right to rectification;
  4. Right to erasure;
  5. Right to restrict processing;
  6. Right to data portability; and
  7. Right to object.

Children

The App is aimed at helping children and young people in the UK control their asthma. The legal age of consent is 12 year in Scotland and 13 years in the rest of the UK. Where a user indicates they are below this age, we will require parental consent.

If we learn that we have collected personal data from a child under the relevant age of consent without a supporting parental consent, the personal data will be deleted as soon as possible. If a child under the age of consent has provided us with personal data their parent or guardian may contact our data protection officer.

How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our data protection officer here:

Andrew Conkie
andrew.conkie@redstar.ai
________________________________________
________________________________________

Modifications
This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner’s Office in the UK.

Contact Information
If you have any questions, concerns or complaints, you can contact our data protection officer, Andrew Conkie, at:

andrew.conkie@redstar.ai