Privacy Policy
Who we are and how to contact us
Who we are
Hedroc Ltd is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either “Hedroc”, “we”, “us” or “our” in this Privacy Policy).
Our address is: 131, Finsbury Pavement, EC2A 1NT
Contact: [email protected]
Your rights relating to your Personal Data
Under certain circumstances, by law you have the right to:
- Request access to your Personal Data. 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 information we hold about you corrected.
- 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 exercised your right to object to processing (see below).
- Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data. 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. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
How to exercise your rights
If you want to exercise any of the rights described above, please contact us using the contact details shown on the Hedroc site.
Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints
If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: [email protected]
We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.
Marketing communications preferences
If you sign up to receive email newsletters or promotional materials from us we will use the information you give us to provide the communications you have requested. You can ask us to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you. If you no longer wish to receive push notifications, you may turn them off at the device level.
Where you opt out of receiving these marketing messages, this will not apply to service correspondence which help you administer your account and allows us to update you when our Site changes or you receive notifications on your account.
What Personal Data we collect
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.
It does not include any information shared in ‘Myndspace’ sessions, and ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).
However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
Category of personal data collected
| Category of personal data collected | What it means |
|---|---|
| Identity Data | First name Last Name, email, department/team, employee number (or similar identifier provided by your employer if required), gender and date of birth. |
| Contact Data | Your work location, email address and telephone numbers. |
| Marketing and Communications Data | Your preferences in receiving marketing from us and your communication preferences. |
| Behavioural Data | Inferred or assumed information relating to your behaviour and interests, based on your online activity. |
| Technical Data | Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services. |
| User-Generated Data | Personal Data you may include in your user-generated content (i.e. information and content that you submit to the Site). |
What it means
Personal Data you may include in your user-generated content (i.e. information and content that you submit to the Site), for instance when you fill in the comments box of the “Check-In” form, when you send a praise to someone and personalise the message, or in the dialog with Zeno (our “chatbot” designed to guide you through the Site and answer your questions).
Aggregated Data
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data to calculate the percentage of users accessing a specific Site feature, or to understand whether and how use of our Services may improve your mood. 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 only share Aggregated Data (i.e. anonymous data) with your employer(s) – for instance, they will be able to see whether their workforce is overall happy or when there are stress periods, and whether use of the Services is beneficial for their employees’ wellbeing. Your employer(s) will not have access to the data on your Hedroc account or any User Generated Data. We also use such Aggregated Data to understand our end-users, to develop the Hedroc offering, to publish white papers and to share the data with health professionals and researchers.
Special Categories of Personal Data
Through our Site, and the services we offer, we may collect some “Special Categories of Personal Data” about you, if you provide such data in your User Generated Data. Special Categories of Personal Data are data that include 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. The data you provide us may contain data relating to your health or other Special Categories of Personal Data.
With your consent, we may also anonymise your Special Categories of Personal Data in an Aggregated Data format, in order to develop the Hedroc services, to publish white papers and to share the data with health professionals and researchers.
With your consent, we share Aggregated Data that may include Special Categories of Personal Data with your employer(s), as further described in the “Aggregated Data” section above.
We do not share any of your Personal Data (including any Special Categories of Personal Data) with your employer.
We do not collect any information about criminal convictions and offences.
How we use your Personal Data and why
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Different grounds than those set out above are required by the GDPR to allow us to process your Special Categories of Personal Data. Most commonly, we will rely on one of the following grounds:
- Where the processing is necessary to enable you to exercise your right to work in a safe workplace and to enable your employer’s reciprocal duty to provide a safe workplace to their employees (“Employment Ground”).
- Where the processing is necessary for the purposes of preventive or occupational medicine, the assessment of the working capacity of employees, medical diagnosis, the provision of health or social care or treatment, or pursuant to a contract with a health professional (“Healthcare Ground”). We will only rely upon the Healthcare Ground where the processing is done by, or under the responsibility of, a clinical psychologist (or other mental health professional subject to obligations of professional secrecy) and in accordance with English laws and/or rules established by a national competent body.
- Where the processing is necessary for scientific research or statistical purposes, as further explained in the “Aggregated Data” section above (“Research Ground”). We will always ensure your Personal Data is anonymised when using it for research purposes.
- Where we have your explicit and specific consent to carry out the processing for the Purpose in question (“Explicit Consent”).
Generally, we do not rely on your Consent (or Explicit Consent) as a legal basis for using your Personal Data (including your Special Categories of Personal Data) other than in the context of direct marketing communications.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
| Purpose | Categories of personal data involved | Why we do this | Our legal basis for this use of data |
|---|---|---|---|
| Account creation | Identity data | To register you as a new user | Contractual necessity |
| Surveys | Identity data Contact data User-generated data |
To complete surveys and obtain data for research purposes and in anonymised format (although you do not have to respond to such surveys) | Legitimate interests.
We have a legitimate interest in understanding service-users to develop Hedroc services, to publish white papers, and to share the data with health professionals and researchers. To the extent your data provided in surveys contains Special Categories of Personal Data, we rely on the healthcare Ground. |
| Aggregation for Research and Development purposes | Identity data Contact data User-generated data |
In an anonymised format, in order to develop Hedroc services, to publish white papers and to share the data with health professionals and researchers | Legitimate interests.
We have a legitimate interest in understanding service-users to develop Hedroc services, to publish white papers, and to share the data with health professionals and researchers. To the extent your data provided in surveys contains Special Categories of Personal Data, we rely on the healthcare Ground. |
| Aggregation for your Employer (s) information | Identity data Contact data User-generated data |
In an anonymised format for your Employer (s) to be able to see whether their workforce is overall happy or when there are stress periods, whether Hedroc services is beneficial for their emplyees’ wellbeing. Your Employer (s) will not have access to identifiable data held by Hedroc. | Legitimate Interests.
We have a legitimate interest in demonstrating to our partner-employers the effect the use of Hedroc services has on their workforce. |
| Fraud Prevention | Identity data Technical data Contact data |
To keep our website, our services and associated systems operational and secure. | Legitimate Interests.
We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks. |
| Troubleshooting | Technical Data | To track issues that might be occurring on our systems. | Legitimate Interests.
It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services. |
| Marketing | Identity data Contact data Marketing and Communications data |
To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant to you. | Consent (and to the extent the processing of your data for marketing Purposes includes Special Categories of Personal data, we rely on your Explicit Consent). |
What happens when you do not provide necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Hed Gym Service).
In this case, we may have to stop you from using our services, but we will notify you if this is the case at the time.
How we use cookies & other tracking or profiling technologies
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies:
- first party cookies, served directly by us to your computer or mobile device; and
- third party cookies, which are served by our partners or service providers on our Site.
Cookies we use
Our Site uses the following types of cookies for the purposes set out below:
Type of cookies
Functionality Cookies
These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
Analytics and Performance Cookies
We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
Disabling cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Local Storage
We use local storage, to store content information and preferences.
Log Files
We gather certain information automatically and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
If you receive the HTML-formatted version of our emails, your opening of the email is notified to us and saved. Your clicks on links in the emails are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
Who we share your Personal Data with
How do we keep Data Secure
| Recipients | Category (ies) of Personal Data we share | Why we share it | Location (s) |
|---|---|---|---|
| HM revenue & Customs, regulators and other authorities | Identity Data Contact Data |
Authorities may require reporting of processing activities in certain circumstances | Within Europe |
How do we keep Data Secure
We have put in place appropriate security measures to prevent Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
Access to Data is limited to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Data breach. In the event of any such breach, there are systems in place to work with applicable regulators. In circumstances where there has been a breach of data, where Hedroc may notify you of breaches affecting Data.
How long do we store Data?
Hedroc will retain Data for as long as it reasonably needs to use it for the purposes set above, unless a longer retention period is required by law (for example for regulatory practices).
Third party links
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.
LAST UPDATED 6/10/2019
