Privacy Policy

Table Of Contents

  1. LAWFUL BASIS 11
  2. THIRD PARTIES 12
  3. EXTERNAL THIRD PARTIES 12
  4. YOUR LEGAL RIGHTS 12

CONSENT TO INSTALLATION OF/ ACCESS TO THE APPS

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. This information is provided in this policy and it is important that you read that information.

Before installation or access to the Apps, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this policy.

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 (ros.watchorn@championhealth.co.uk) but that will not affect the lawfulness of any processing carried out before you withdraw your consent. We may still need to retain certain information, including some of your health information only where this strictly required for insurance purposes or other legal compliance, but we will delete anything we don’t strictly need to comply with our own legal obligations as we are required to by the GDPR. We won’t be able to remove any data you provided that we have fully anonymised as part of an Aggregated data set (which we describe below) that doesn’t reveal any individual’s identity.

Champion Health Ltd (we, us, our) are committed to protecting your personal data and respecting your privacy.

INTRODUCTION

This policy (together with our end-user licence agreement as set out at www.championhealth.co.uk/eula or as presented to you when you first use or install any of our Apps (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

  • All versions of our Apps, whether available whether made available to you on your phone or online through our website (App Site) or the relevant application market on your device, once you have downloaded or streamed a copy of the App onto your personal computer, mobile telephone or handheld or other suitable electronic device (Device).
  • Any of the services accessible through the Apps or the App Site via any Device (Services) that are available on the App Site or other sites of ours (Services Sites). 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 as part of our Services provided via the Apps.
  • No matter how you interact with us, by phone or computer, this policy will govern the processing of your personal data that we carry out and where we do something specific to either mobile or web (depending on what versions of our Apps you use) then we will make it clear where that kind of processing only applies to either our mobile application, or our web application versions of the Apps.

The Apps are not intended for use by, or for the purpose of the collection of any personal data relating to, children (under the age of 16 years) 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

Champion Health Ltd a company registered in England and Wales with company registration number 11456257 of with registered address at 10 Kenwood Park Road, Sheffield, United Kingdom, S7 1NF. We are the controller who is responsible for your personal data (collectively referred to as, “we”, “us” or “our” in this policy).

We have appointed a data protection officer (DPO). If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

  • Full name of legal entity: Champion Health Ltd
  • Name or title of DPO: Rosalind Watchorn
  • Email address: ros.watchorn@championhealth.co.uk
  • Postal address: 23, Kenwood Park Road, Sheffield, S71NE

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 another competent supervisory authority of an EU member state if the App is downloaded outside the UK and you are not a UK citizen.

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 17 April 2019. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email when you next start the Apps or log onto one of the App Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Apps 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.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact Data and Identity Data. Please check these policies before you submit any personal data to these websites or use these services.

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.
  • Health Data (Special Category)
  • Financial Data.
  • Transaction Data.
  • Device Data.
  • Content Data.
  • Profile Data.
  • Usage Data.
  • Marketing and Communications Data.

We will be collecting Special Categories of Personal Data about you (the definition of Special Categories includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

If you use our Services then you will be providing us with information regarding a Special Category of personal data, and because this may be provided via a free-text response by email, online contact form or over the phone, then by providing this information you are deemed to consent to our processing of that data in accordance with this policy. We do not collect any information about criminal convictions and offences. We will ask for your consent when you first use or install the App and thereafter we will only ask for your consent again if the purpose of our processing changes.

AGGREGATED DATA AND ANONYMISATION

We also create, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data as described above, which includes your Health Data (Special Category), but is not considered personal data in law as this data will not directly or indirectly reveal your identity. This data falls outside of the scope of the GDPR and the UK Data Protection laws because it can’t be linked back to you. 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.

This policy doesn’t necessarily need to describe what we do with aggregated data, the GDPR says this kind of data falls outside its scope because you can no longer be identified from it, but we still want to tell you about what we plan to do with this data anyway.

We will use aggregated or anonymised data for research and scientific purposes in order to either try and improve the way we deliver our own services, or for other bodies and organisations to improve the ways in which they deal with and manage the health of their employees in the workplace. We also want to work with research groups and universities and use this data, in combination with other data sets, to help us and those third-party researchers understand health and wellbeing so that together we can try to understand the root cause and impact it has on people’s health. We might work with other people or companies for the same purposes from time to time, and we will do our best to tell you all about it on our website, or as part of our newsletter.

If you really do not want us or anyone else to use your data in this way, even though no one will be able to tell that you are the source of that data, then please contact us to let us know before you use our App or any of our Services. Because of the way in which we anonymise and aggregate data, we won’t be able to tell which data is yours if you decide you want to try to “opt-out” of this in the future, and if you do decline this processing of non-personal data then we might not be able to provide parts of our Services to you at all.

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, Health, Financial, and Marketing and Communications Data) you consent to giving us information about you by filling in forms whilst using our Apps, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download, register or use an App for the first time, subscribe to any of our Services, search for an App or Service, share data via an App’s social media functions, enter a competition, promotion or survey and when you report a problem with any of the Apps, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
  • Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy below for further details.
  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Device Data from analytics providers such as Google based outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, Inc based in the United States of America, GoCardless and Xero.
  • Identity Data, Contact Data, Health Data (Special Category), Financial Data, Transaction Data, Device Data, Content Data, Profile Data, Usage Data, Marketing and Communications Data from our third-party IT services providers who manage and run our App and the Services under our strict instructions and not for their own purposes.
  • Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

COOKIES

We use cookies and other tracking technologies such as pixels to distinguish you from other users of our Apps, the App Site, the distribution platform (relevant Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use and the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy below.

Cookie Name

Purpose

 

__utma

This cookie is used to monitor the number of times a visitor has been to the site related to the cookie, when they first visited the site, and when they were last on the site. Google Analytics uses the information from this cookie to calculate things like Days and Visits to purchase.

More information

__utmb
__utmc

These two cookies work together to establish how long a visit has taken. b signals when a user enters the site and c signals when a user leaves.

More information

__utmt

A cookie used to throttle the request rate for the service, limiting the collection of data on high traffic sites.

More information

__utmz

This cookie captures how a visitor accessed the site including: which search engine was used, what link was clicked on, what keywords were used and geographical location.

More information

Facebook Pixel

A cookie issued to monitor traffic directed to our website from Facebook. This is used to provide relevant feedback to the user based on the content in which they have shown interest in. It is also used to gauge the effectiveness of our digital marketing campaigns. A user can opt out on the Facebook site.

 

More Information

 

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.
  • To protect your vital interests where you are unable to give consent.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email and only then if we have your approval. We will ask you to opt-in to receiving such marketing communications before we send anything to you. You have the right to opt-out of receiving marketing from us at any time by contacting us or changing your marketing preferences.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes, but we don’t normally do this.

We won’t ever send you marketing based on your Health Data, and we will never ever share your Health Data with third parties unless you can’t be linked to that information (so that it is no longer personal data).

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Purpose/activity

Type of data

Lawful basis for processing

To install the App and register you as a new App user

Identity

Contact

Financial

Device

Performance of a contract with you.

To deliver our Services

Identity

Contact

Financial

Transaction

Device

Marketing and Communications

Health Data (Special Category)

Your consent (where we collect information about your state of health and wellbeing (Special Category))

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

Where necessary to protect your vital interests where you cannot give consent.

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

Identity

Contact

Financial

Profile

Marketing and Communications

Performance of a contract with you.

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey

Identity

Contact

Device

Profile

Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

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

Identity

Contact

Device

Health Data (Special Category)

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

To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Consent

Necessary for our legitimate interests where you have expressly opted in or indicated a request for these (to develop our products/Services and grow our business)

 

DISCLOSURES OF YOUR PERSONAL DATA

When you provide us with your personal data, we may 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:

  • External Third Parties as set out in the Glossary.
  • Specific third parties such as Stripe, Inc, GoCardless and Xero.
  • 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.

Who we WILL NOT share your Health Data (Special Category) with:

  • Your employer or the group or organisation to which you belong
  • Third party marketing providers or databases
  • Anyone outside of our business, unless and until we have made sure that you can’t be identified from the data we create (except as expressly set out in this policy). For more information on how this data is used after it is no longer “personal data” see the section on “AGGREGATED DATA” above.

INTERNATIONAL TRANSFERS

We are based outside the EEA (in the UK) so our processing of your personal data will involve a transfer of data outside the EEA if you are a citizen of an EEA country/state.

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. If and when the UK is approved and added to this list, this will be our main safeguard mechanism for transferring your personal data to the UK.
  • 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. These are called the Standard Contractual Clauses and this will be the main safeguard mechanism we use to transfer personal data to the UK until the UK is added to the list of approved countries subject to an adequacy decision as described above.
  • Where we use providers based in the US, we may transfer data to them if they are part of the relevant Privacy Shield framework which requires them to provide similar protection to personal data shared between Europe and the US (or Switzerland and the US where applicable).

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

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone else.

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. Data is secured using a Next Generation firewall and hosted on a secure web hosting platform. Systems are penetration tested annually (scheduled) and Cyber Essentials certified. Systems are monitored and patched regularly ensuring security risks are mitigated.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5).

We have put in place procedures 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

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

By law we have to 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 Your legal rights 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.

In the event that you do not use the App for a period of twenty years 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.

Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer or your personal data.
  • Right to withdraw consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at support@championhealth.co.uk

GLOSSARY

  1. 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.

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.

Protecting your vital interests means processing your data where your vital interests are at stake, such as in an emergency situation, where we would consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data pursuant to this justification.

  1. THIRD PARTIES
  2. EXTERNAL THIRD PARTIES

Service providers acting as processors based in the United Kingdom who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Delivery services who we instruct in order to deliver our products and services to you who will be based in the United Kingdom where this is required in order to actually carry out and deliver your order.

  1. YOUR LEGAL RIGHTS

5          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, marital status, title, date of birth, gender].
  • Contact Data: [billing address, delivery address, email address and telephone numbers].
  • Financial Data: [bank account and payment card details].
  • 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,] [OTHER INFORMATION].
  • Content Data: includes information stored on your Device, including [login information,] [photos, videos or other digital content,] [OTHER INFORMATION].
  • 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, [traffic data [and other communication data],] whether this is required for our own billing purposes or otherwise [and the resources that you access].
  • Marketing and Communications Data: includes [your preferences in receiving marketing from us and your communication preferences].