1.
INTRODUCTION
1.1
This privacy notice (Privacy Notice) sets out the ways in which we, Wellbe Global Limited (we, us, our), collect and use your personal data (your personal information) in connection with our online Platform, Wellbe. It also explains what rights you have to access or change your personal data.
1.2
In this Privacy Notice, the capitalised terms below have the following meanings:
1.2.1
Wellbeing Service Provider: means a user of the Wellbe Platform who offers products and services via the Wellbe Platform.
1.2.2
Corporate Employer: an entity registered with Wellbe in order to provide its employees, staff members and other authorised individuals with access to the Wellbe Platform and services.
1.2.3
Employee: an employee, staff member or other individual authorised by a Corporate Employer to access the Wellbe Platform.
1.2.4
Listing: information published on the Wellbe Platform by Wellbeing Service Providers about products and services they offer.
1.2.5
Wellbe Platform: means the website www.wellbe.global and the Wellbe application.
2.
ABOUT US
2.1
We are a company registered in England under company number 11954870 with our registered address as set out below.
2.2
You can contact us as follows:
Address:
35-41 Folgate Street, London, United Kingdom, E1 6BX
Telephone:
+44 203 948 4364
3.
OVERVIEW OF THE WELLBE PLATFORM
3.1
The Wellbe Platform is a confidential online platform for Employees to discover and access health and wellbeing services based on their needs, from counselling services, to alternative therapies such as acupuncture and reflexology. We are committed to keeping your personal information safe, secure and confidential. Any information that you share with us will be processed in accordance with the terms of this Privacy Notice and data protection laws.
3.2
Any information relating to Employees’ health and wellbeing, and individual use of the Wellbe Platform is kept strictly confidential, and we will not share any of this information with Corporate Employers unless we are required to do so by law or as otherwise set out in section 3.3. We also will not sell, distribute or lease personal information to third parties at any time unless we have permission or are required by law to do so.
3.3
We will provide aggregated and anonymised statistics to Corporate Employers about the overall health and wellbeing of Employees using the Wellbe Platform, and the impact that the use of Platform. For example, we provide statistical reports to Corporate Employers of common issues faced by their Employees (such as anxiety, depression, work-related stress) and details on how access to the Wellbe Platform affects these statistics. These reports are completely anonymised and do not enable the identification of any individual Employees. This feedback helps Corporate Employers better understand and plan their corporate wellbeing strategy.
4.
INFORMATION WE MAY COLLECT ABOUT YOU
4.1
Information that you provide to us.
4.1.1
We will collect any information that you provide to us when you:
(a)
are making an enquiry over the phone, by email or via the Wellbe Platform;
(b)
submit correspondence to us by post, email or via the Wellbe Platform;
(c)
create an account to use the Wellbe Platform as an Employee, a Corporate Employer or a Wellbeing Service Provider;
(d)
update your profile and other account details;
(e)
respond to questionnaires and surveys regarding your health, wellbeing, preferences, hobbies and interests;
(f)
post Listings on the Wellbe Platform;
(g)
respond to Listings on the Wellbe Platform;
(h)
enter into a transactions with Wellbeing Service Providers;
(i)
contact other users via the Wellbe Platform;
(j)
fill in a form, conduct a search, respond to surveys, participate in promotions or use any other features of the Wellbe Platform;
(k)
submit reviews on the Wellbe Platform;
(l)
subscribe to our newsletter and mailing lists;
(m)
‘follow’, ‘like’, post to or interact with our social media accounts;
(n)
register to and/or attend our events or meetups, including where you attend as a presenter;
(o)
submit a CV/application to a job vacancy; and
(p)
attend an interview or assessment.
4.1.2
The information you provide to us might include:
(a)
Identity and contact data: Title, names, addresses, email addresses and phone numbers.
(b)
Employee account profile data: If you’re registering for an Employee account, in addition to the information above, you may provide details of your employer, your telephone number, your email address, your password, your age, your gender, your ethnicity, your hobbies, preferences, interests and goals and any other account profile information specified.
(c)
Wellbeing questionnaire and survey data: If you’re using the Wellbe Platform as an Employee, you may choose to participate in our questionnaires and surveys regarding your wellbeing, where may provide us with details of your mental and physical health and goals. Please see the section on ‘special categories of data’ for more details on how we process these types of sensitive personal information.
(d)
Platform and service feedback data: From time to time we might ask if you would be willing to participate in our surveys about the Wellbe Platform and our services; if you participate, we will collect any information that you provide as part of those surveys.
(e)
Financial data: In order to pay fees for use of the Wellbe Platform and other Wellbe services, Corporate Employers and Wellbeing Service Providers will provide us with payment details, which may include billing addresses, credit/debit card details and bank account details.
(f)
Employment and background data: If you are submitting a job application, are attending or presenting at one of our events, you may also provide additional information about your academic and work history, qualifications, skills, projects and research that you are involved in, references, proof of your entitlement to work in the UK, your national insurance number, your passport or other identity document details and any other such similar information that you may provide us.
(g)
Equal opportunities and accessibility information: If you are submitting a job application, you may provide information about your race or ethnicity, religious beliefs, sexual orientation, health and whether or not you have any disability. Please see the section on ‘special categories of data’ for more details on how we process these types of sensitive personal information.
4.3
Information we receive from third parties
4.3.1
In certain circumstances, we will receive information about you from third parties. For example:
(a)
Information from Corporate Employers: If you are using the Wellbe Platform as an Employee, we will receive details of your name, email address and employment status from your Corporate Employer in order to verify that you are eligible to register for, and continue to use the Wellbe Platform.
(b)
Authorised representative and account administrator information: If you are an authorized representative or an account administrator for a Corporate Employer or Wellbeing Service Provider, we will receive details of your name, job title, username and password from the Corporate Employer or the Wellbeing Service Provider, as applicable.
(c)
Fraud detection agencies: Where permitted or required by law, we may receive information about you, including demographic data or fraud detection information from third party service providers.
(d)
Employers, recruitment agencies and referees: If you are a job applicant we may contact your recruiter, current and former employers and/or referees, who may be based inside or outside the EU, to provide information about you and your application.
(e)
Service providers: We may collect personal information from the Wellbe Platform developer, IT support provider, customer service support provider, survey tool providers and payment services provider.
(f)
Platform security: We will collect information from the Wellbe Platform security service partners about any misuse to the Wellbe Platform, for instance, the introduction of viruses, Trojans, worms, logic bombs, Platform attacks or any other material or action that is malicious or harmful.
(g)
Publicly available sources: We currently use publicly available sources such as Companies House, for instance to carry out identity and compliance checks.
4.3.2
We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
5.
HOW WE USE PERSONAL INFORMATION
5.1
We may use your information for the following purposes:
5.1.1
To register and maintain your account: When you sign up to use the Wellbe Platform, we will use the details provided on the account registration form to register and maintain your account.
5.1.2
To provide Employees with targeted recommendations and suggestions: When you use the Wellbe Platform as an Employee, tailor the Listings that you see on the Wellbe Platform based on your listed preferences, your location, you responses to questionnaires and assessments and on your actions on the Wellbe Platform. For example, if you have indicated that you suffer with anxiety, we may show you professional counsellors near you that have registered on the Wellbe Platform as a Wellbeing Service Provider. We do not share any personal information with Wellbeing Service Providers in order to make recommendations. We will only share personal information if you choose to engage with a Wellbeing Service Provider, for instance, if you respond to a Listing.
5.1.3
To enable you to communicate and transact with other Platform users: We may use your personal information to enable you to communicate with and transact with each other, including for Wellbeing Service Providers to post Listings, and Employees to respond to Listings, and to enable users to message each other via the Wellbe Platform.
5.1.4
To enable you to communicate and transact with other Platform users: We may use your personal information to enable you to communicate with and transact with each other, including for Wellbeing Service Providers to post Listings, and Employees to respond to Listings, and to enable users to message each other via the Wellbe Platform.
5.1.5
To provide statistical analysis to Corporate Employers: We provide aggregated and anonymised statistics to Corporate Employers about the wellbeing and health of Employees using the Wellbe Platform, and the impact that the use of Platform is having on Employee wellbeing.
5.1.6
To provide statistical analysis to Wellbeing Service Providers: We provide aggregated and anonymised statistics to Wellbeing Service Providers of the Wellbe Platform about overall engagement with the Platform.
5.1.7
To process and facilitate transactions with us: We will use your information to collect and recover money owed to us.
5.1.8
To help resolve disputes between Platform users: We may use your information when we elect to provide assistance in relation to any disputes between Platform users.
5.1.9
Relationship management: To manage our relationship with you, which will including notifying you about changes to our terms of use or Privacy Notice, and asking you to leave a review or take a survey.
5.1.10
User support: To provide user service and support, deal with enquiries or complaints about the Wellbe Platform and share your information with the Wellbe Platform developer, IT support provider, payment services provider, and survey provider as necessary to provide user support.
5.1.11
Prize draws, competitions and surveys: To enable you to take part in prize draws, competitions and surveys.
5.1.12
Recruitment: To process any job applications you submit to us, whether directly or via an agent or recruiter, including sharing this with our third party recruitment agency.
5.1.13
Marketing: To keep in contact with you about our news, events, new Platform features or services that we believe may interest you, provided that, where necessary, we have the permission to do so, and sharing your information with our marketing services provider.
5.1.14
Analytics: To use data analytics to improve the Wellbe Platform, products/services, marketing, customer relationships and experiences.
5.1.15
Research: To carry out aggregated and anonymised research about general engagement with the Wellbe Platform and services.
5.1.16
Social media interactions: To interact with users on social media platforms, for example, responding to comments and messages, posting, sharing and liking posts.
5.1.17
Fraud and unlawful activity detection: To protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud.
5.1.18
Compliance with policies, procedures and laws: To enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees and share your information with our technical and legal advisors.
5.2
Lawful grounds for using non-sensitive personal information
We will use your personal information for the purposes listed above on the basis of:
5.2.1
performance of your contract with us and the provision of our services to you;
5.2.2
your consent (where we request it);
5.2.3
your vital interests or the vital interests of another living person;
5.2.4
where we need to comply with a legal or regulatory obligation; or
5.2.5
our legitimate interests. Where we use your information on the basis of our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” below.
6.
Lawful grounds for using sensitive personal information
As indicated elsewhere in this Privacy Notice, we collect and process “special categories” of particularly sensitive personal information, which may include information about your health, racial or ethnic origin, sexual orientation or trade union membership. In addition to the lawful grounds listed above, we must have additional legal basis to process these types of sensitive personal information. As such, we may process your sensitive personal information:
6.1.1
with your explicit written consent;
6.1.2
on the basis of our legal obligations or the exercise of rights in connection with employment, social security and social protection laws;
6.1.3
on the basis of substantial public interest, such as for equal opportunities monitoring;
6.1.4
where it is needed in relation to legal claims;
6.1.5
where it is needed to protect your vital interests, or the vital interests of someone else, and you are not capable of giving your consent;
6.1.6
where you have already made the information manifestly public; or
6.1.7
as otherwise legally permitted under data protection laws.
7.
WHO WE MIGHT SHARE YOUR INFORMATION WITH
7.1
In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we may share your personal information with third parties that we work with such as:
7.1.1
Wellbe’s service providers: Service providers we work with to deliver our business, who are acting as processors and provide us with:
(a)
platform development and hosting services based in the UK and Ireland;
(b)
IT, system administration and security services based in the UK and Ireland;
(c)
marketing and advertising services in the UK and USA;
(d)
survey tool services based in the UK and USA;
(e)
maps services based in the UK;
(f)
social media services;
(g)
payment services based in the UK;
(h)
identity verification, fraud prevention and detection services based in the UK;
(i)
banking services based in the UK;
(j)
legal, accountancy, auditing and insurance services based in the UK; and
(k)
recruitment service providers based in the UK.
7.1.2
Regulators and governmental bodies: HM Revenue & Customs, regulators, governmental bodies and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
7.1.3
Prospective sellers and buyers of our business: Any prospective seller or buyer of such business or assets, only in the event that we decide to sell or buy any business or assets.
7.1.4
Other third parties (including professional advisers): Any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) based in the United Kingdom where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
7.2
We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
8.
SHARING DATA DIRECTLY WITH THIRD PARTIES
8.1
You might end up providing personal information directly to third parties as a consequence of your interactions with the Wellbe Platform and other services offered by Wellbe. You may also provide your personal information directly to a third party if you attend an event hosted by us where you communicate personal information directly with other attendees. Wellbe is not responsible for how such third parties use personal data provided by you.
8.2
Please be responsible with personal information of others when using the Wellbe Platform and the services available on it. Wellbe is not responsible for your misuse of personal information, or for the direct relationship between you and others.
9.
COOKIES
9.1
We use cookies to ensure that you get the most out of the Wellbe Platform. Cookies are small amounts of information in the form of text files which we store on the device you use to access the Wellbe Platform. Cookies allow us to monitor your use of the Wellbe Platform and simplify your use of the Wellbe Platform. The cookies we place on your device fall into the following categories:
9.1.1
Session cookies—these allow our the Wellbe Platform to link your actions during a particular browser session. These expire each time you close your browser and do not remain on your device afterwards.
9.1.2
Persistent cookies—these are stored on your device in between browser sessions. These allow your preferences or actions across the Wellbe Platform to be remembered. These will remain on your device until they expire, or you delete them from your cache.
9.1.3
Strictly necessary cookies—these cookies are essential for you to be able to navigate the Wellbe Platform and use its features. Without these cookies, the services you have asked for could not be provided.
9.1.3
Performance cookies—these cookies collect information about how you use our the Wellbe Platform, eg which pages you go to most often. These cookies do not collect personally identifiable information about you. All information collected by these cookies is aggregated and anonymous, and is only used to improve how the Wellbe Platform works.
9.1.4
Functionality cookies—these cookies allow the Wellbe Platform to remember the choices you make (such as your user name, language, last action and search preferences) and provide enhanced, more personal features. The information collected by these cookies is anonymous and cannot track your browsing activity on other websites.
9.2
If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies, you may not be able to access all of the functions of the Wellbe Platform.
9.3
The Wellbe Platform may contain content and links to other sites that are operated by third parties that may also operate cookies. We don’t control these third party sites or cookies and this Privacy Notice does not apply to them. Please consult the terms and conditions and Privacy Notice of the relevant third party site to find out how that site collects and uses your information and to establish whether and for what purpose they use cookies.
10.
HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR
10.1
We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
10.1.1
ensuring the digital security of the Wellbe Platform by protecting it using Secure Sockets Layer (SSL) encryption;
10.1.2
ensuring that your access to the Wellbe Platform is password protected;
10.1.3
ensuring the physical security of our offices or other sites;
10.1.4
ensuring the physical and digital security of our equipment and devices by using appropriate password protection; and
10.1.5
limiting access to your personal information to those in our company who need to use it in the course of their work.
10.2
We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it.
11.
HELP KEEP YOUR INFORMATION SAFE
11.1
You can also play a part in keeping your information safe by:
11.1.1
choosing a strong account password and changing it regularly;
11.1.2
using different passwords for different online accounts;
11.1.3
keeping your booking references and passwords confidential and avoiding sharing your login with others;
11.1.4
making sure you log out of the Wellbe Platform each time you have finished using it. This is particularly important when using a shared computer;
11.1.5
letting us know if you know or suspect that your account or booking has been compromised, or if someone has accessed your account without your permission;
11.1.6
keeping your devices protected by using the latest version of your operating system and maintaining any necessary anti-virus software; and
11.1.7
being vigilant to any fraudulent emails that may appear to be from us. Any emails that we send will come from an email address ending in ‘@wellbe.global.
12.
INTERNATIONAL TRANSFERS OF YOUR INFORMATION
12.1
Our company is located in the UK.
12.2
Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
12.2.1
We will 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;
12.2.2
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, European Commission: Model contracts for the transfer of personal data to third countries; and
12.2.3
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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
13.
Please contact us using the contact details at the top of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.
14.1
You have certain rights in respect of the information that we hold about you, including:
14.1.1
the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Notice;
14.1.2
the right to ask us not to process your personal data for marketing purposes;
14.1.3
the right to request access to the information that we hold about you;
14.1.4
the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
14.1.5
the right to withdraw your consent for our use of your information in reliance of your consent (where we have specifically requested it), which you can do by contacting us using any of the details at the top of this Privacy Notice;
14.1.6
the right to object to our using your information on the basis of our legitimate interests 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;
14.1.7
the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format, in certain circumstances;
14.1.8
in certain circumstances, the right to ask us to limit or cease processing or erase information we hold about you; and
14.1.9
the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) as well as a right to lodge a complaint with the relevant authority in your country of work or residence.
14.2
We may need to retain certain information for our own record-keeping and research purposes. We may also need to send you important non-marketing, service-related communications relating to your user account even when you have requested not to receive marketing communications.
14.3
How to exercise your rights
14.3.1
You may exercise your rights above by contacting us using the details in the ‘ABOUT US’ section of this Privacy Notice, or in the case of preventing processing for marketing activities also by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing or by updating your marketing preferences via your account with us.
14.3.2
You may contact us via the details at the top of this Privacy Notice if you wish to action any of these additional rights and we will comply with your requests unless we have a lawful reason not to do so.
14.4
What we need from you to process your requests
14.4.1
We may need to request specific information from you to help us confirm your identity and to enable you 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.
14.4.2
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will 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.
15.
THIRD-PARTY LINKS
16.
The Wellbe Platform may include links to third-party websites, plug-ins and applications, for example, links to websites for Wellbeing Service Providers. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Wellbe Platform, we encourage you to read the privacy notice of every website you visit.
17.
CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
17.1
We may make changes to this Privacy Notice from time to time. We will post any changes to our site, or notify you of any material changes by e-mail.
17.2
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 your relationship with us by updating your profile account information or contacting us via the contact details at the top of this Privacy Notice.