1. WHO DOES THIS PRIVACY NOTICE APPLY TO?
This notice applies to:
- the users of our website, online content and features;
- the registered users of our wellness platform;
- our business customers who purchase access to our wellness platform and related services;
- our service providers and business partners;
- our job applicants; and
- anyone else who interacts with us, if you call, email or visit us or otherwise engage with us online or offline.
2. WHAT TYPES OF PERSONAL DATA DO WE PROCESS?
“Personal data” generally means any information that identifies you or relates to you. However, the exact definition will depend on the laws which apply to your use of our online services.
Depending on your interaction with us, this may include the details of your enquiry, contact information, wellness information, usage information, your profile and other information.
Our wellness platform focuses on helping our registered users in relation to sleep, mental well-being, physical activity and nutrition. Our users may choose to provide information about their wellness activities to us by various means available to them including via a wearable device. We do not seek to process any special category personal data relating to health and our services are not designed and, in many respects, not capable to do so.
For more information, please see the "categories of personal data" section below.
3. DATA ACCURACY
We will always trust that your personal data is accurate, complete and up to date, as required to provide our services to you. We ask that you keep us informed of any changes or any errors in your personal data.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
We collect your personal data as follows:
- From you, if you complete the request form on our website, when you send us an email, when you sign up to our wellness platform, when you deal with our representatives, when you visit our offices or otherwise deal with us.
- From your user interactions with our website, online content, predefined modules and features, wellness platform or other online services, for example, when you initiate, interrupt or skip watching one of our expert-led educational videos on our wellness platform, navigate our website, install our app or otherwise interact with our online services.
- From the public domain, such as information on the internet, Companies House, social media or other public records.
- From third parties, such as our business customer (who will give us your details so we can invite you to use our wellness platform), recruitment agencies, your referees, affiliated persons, social media platforms and other third parties.
If you provide information about others, please ensure you have their consent to do so or let us know if you do not.
5. WHY DO WE PROCESS YOUR PERSONAL DATA?
This section explains what personal data is necessary for each purpose. We believe you would not find it helpful to see descriptions of all processing activities that fall under each purpose but please contact us if you have any questions. We keep our processes and data collection under review and will update this notice should any personal data no longer be necessary for the given purpose.
The "lawful basis" column explains how we comply with a technical legal justification for data processing. Please contact us if you have any questions.
|
Purpose |
Personal data |
Lawful basis of processing (for UK and EU individuals only) |
|
To assist with your enquiries. |
details of enquiry contact information
|
Necessary for our legitimate interest in responding to enquiries and complying with best practice or, as the case may be, necessary for taking steps prior to entering into a contract. |
|
To onboard our business customers.
|
contact information public information your background information |
Necessary for our legitimate interest in knowing our business customers and their officers, directors and shareholders and complying with best practice, as well as complying with our legal obligations. |
|
To provide services to our business customers and their authorised users including corporate access to our wellness platform where the business customer can access our dashboard showing aggregated wellness score and other statistics about users, set a step challenge or other goals for users, track goals achieved by users, offer rewards for achievements, receive reports about user engagement and how user wellness contributes to the performance of the customer organisation, and access other features based on statistical data only. For example, the business customer cannot see the attributes of users, their gender, or precise body measurements as all such information is aggregated by adding "noise" such as range of data, estimates or general designations. The business customer will be able to see the total number of users. |
contact information user details usage information
Statistical data based on user details, usage information and wellness information.
|
Necessary for our legitimate interest in providing our services to our business customers who encourage the use of our wellness platform, stimulate users by setting goals and pay for user access to our wellness platform.
Users have the option to opt-out from their personal data being included in generating the statistical data for the relevant business customer. |
|
To manage our professional relationship with our business customers and prospects using our record management systems and engagement tools, identifying opportunities and contacting you by phone, email and other relevant means of communication. |
business opportunity information usage information user details |
Necessary for our legitimate interest in winning new business, understanding and maintaining our business relationships and administering our business. |
|
To onboard our users and provide access to our wellness platform on web or app.
We will verify your details based on the information provided to us by the relevant business customer about you. The business customer's admin user will invite users to our wellness platform by email or, as appropriate, via chat or by other means. You can then create a user account and set other credentials.
As a user, you may connect your compatible app, wearable device or smartphone to our wellness platform to provide information relating to your sleep, mental well-being, physical activity and nutrition or, where applicable, you may choose to input data manually. |
user details technical information wellness information
|
Necessary for taking steps prior to entering into a contract with you as our user, the performance of our contract with you, and compliance with our legal obligations.
|
|
To provide the services and features of our wellness platform to our users such as wellness goal recommendations, suggested content, results of activities, participation in challenges and other services. |
user details usage information technical information wellness information |
Necessary for our legitimate interest in providing our online features and services to our users and the performance of our contract with our users. |
|
To feature the name, experience and achievements of a user on the "leader board" for their relevant customer organisation and other users to see. Only general wellness score or designation is shown to rank the user and no accurate metrics are displayed.
|
First name last name email address score ranking |
Necessary for our legitimate interest in providing to the relevant customer organisation the feature of showing logged in users in real-time.
Users have the option to opt-out from showing as logged in to the relevant customer organisation.
|
|
To provide our online services including our website, online content and features to you and the general public which may remember your preferences or include personalised content and services. |
profile information technical information usage information
|
Necessary for our legitimate interest in providing our online services to the public and complying with best practice, the performance of our contract with our users and compliance with our legal obligations.
Where required by law, we rely on your consent to deploy cookies or similar technologies on your device or to read information on your device except where necessary for essential services. Your consent is obtained if you select your choices in our cookie panel. Your choices will extend to first party and third party cookies. Please see the cookies section below for further information. |
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To send you service communications about matters relevant to your use of our wellness platform and our online services, changes in our terms, surveys and other feedback requests, etc. |
contact information engagement information usage information |
Necessary for the performance of our contract with you and our legitimate interest in understanding how our services are used and viewed by our customers and keeping our customers informed. |
|
To send you relevant marketing communications including by email, phone, text message and other means. |
contact information engagement information details of enquiry |
Our legitimate interest in promoting our organisation to our business contacts. You will have the right to opt-out from future marketing communications.
We will obtain your consent where required by law (for example, in relation to marketing sent to consumers) which you can withdraw at any time or we might rely on the existing customer (soft opt-in) exemption which allows us to send you marketing without consent in certain circumstances. |
|
To display relevant advertisements on websites, apps, social media and other inventory. Our advertising tools rely on cookies, similar scripts and advertising ID solutions and complex automated processes and decision-making.
We use pseudonymised information that does not include your name or similar information, except in very limited cases and in encrypted form. We rely on your customer profile data to understand your interests, preferences, behaviour and attitudes known, observed and inferred to design marketing and advertising campaigns that are relevant to you (also known as “profiling”, “personalisation” and “predictive analytics”), use an ID such as your hashed email address to identify you within third party datasets or on social media without actually disclosing your email and allocate your profile to relevant audience segments (also known as “matching”, “data enrichment”, “targeting”) or matching you against our typical customer profile (creating "lookalike audiences"), and measuring conversion events linked to your advertising ID to optimise campaign performance. |
pseudonymised engagement information profile information security information technical information usage information
|
Where required by law, we rely on your consent to deploy cookies or similar technologies on your device or to read information on your device except where necessary for essential services. Your consent is obtained if you select your choices in our cookie panel. Your choices will extend to first party and third party cookies. Please see the cookies section below for further information.
Some of our marketing and advertising activities are necessary for our legitimate interest in understanding your interests from the information available to us, information observed or inferred and from third party information, promoting our business and understanding campaign metrics.
|
|
To assess your job application and for business administration purposes.
For example, if you apply for a job, we will review your CV, publicly available information about you, information from your previous employers and professional references. |
contact information details of your enquiry public information special categories of personal data your background information
|
Necessary for our legitimate interest in considering applications, responding to queries and, as the case may be, necessary for taking steps prior to entering into a contract. Special categories of personal data may be processed as is necessary in the context of employment and social security laws. |
|
To develop and improve our wellness platform, website, online content and features and other services and our organisation through analytics, engagement monitoring, split testing and other testing, training of machine learning models and similar activities. |
Pseudonymised engagement information usage information profile information security information technical information wellness information |
Necessary for our legitimate interest in analytics and service development.
Where required by law, we rely on your consent to deploy cookies or similar technologies on your device or to read information on your device except where necessary for essential services. Your consent is obtained if you select your choices in our cookie panel. Your choices will extend to first party and third party cookies. Please see the cookies section below for further information. |
|
To collect and generate insights about wellness for internal purposes and for sharing with the public. |
Pseudonymised usage information
|
Necessary for our legitimate interest in creating and using know how and, where applicable, sharing it with the public. |
|
To ensure the proper administration of our organisation, including to:
|
all personal data as is necessary and proportionate
|
Necessary for compliance with our legal obligations, to establish, exercise or defend legal claims and necessary for our legitimate interest in the proper administration of our organisation and services and protecting our reputation.
|
|
To ensure information security of our information systems, premises, meetings and communications. |
usage information security information
|
Necessary for our legitimate interest in ensuring the security of people, our organisation and assets and compliance with our contractual obligations, and as is necessary for compliance with our legal obligations. |
|
To ensure your health and safety at our premises or to make reasonable adjustments on account of your disability. |
special categories of personal data
|
Necessary for our legitimate interest in ensuring health and safety and good accessibility at our premises in the substantial public interest and as is necessary for compliance with our legal obligations. |
|
To engage our third party service providers and advisors who may process your personal data on our behalf or otherwise to facilitate the provision of our services and the fulfilment of essential service functions including cloud storage, backup, telecommunications, information security, professional advice and other services. |
all personal data as is necessary and proportionate
|
Necessary for our legitimate interest in providing our services and running our organisation. |
|
To monitor interactions and operations for the prevention and detection of crime including fraud, and to share information with law enforcement authorities and other stakeholders. |
all personal data as is necessary and proportionate
|
Necessary for our legitimate interest in protecting people, our organisation and assets and detecting and preventing crime, and as is necessary for compliance with our legal obligations. |
|
To share data with another organisation in accordance with the law for the purposes of a joint venture, collaboration, merger or acquisition. |
all information as is lawful, necessary and proportionate |
Necessary for our legitimate interest in engaging in activities to promote our organisation and as is necessary for compliance with our legal obligations. |
|
Processing and sharing your personal data in connection with legal claims and law enforcement or regulatory requests. |
all personal data as is necessary and proportionate
|
Necessary for compliance with our legal obligations, to establish, exercise or defend legal claims or for our legitimate interest in complying with best practice. |
We may process your personal data for other purposes which are compatible with the existing ones. However, we will obtain your prior consent for any new purpose where required by law.
6. COOKIES AND SIMILAR TECHNOLOGIES
We utilize technologies that enable us to store information, or access information stored, on your device such as your computer or smartphone, including:
- Cookies are small text files sent to or accessed by your web browser which will enable you to navigate our online services and features. Cookies sit on your device and make themselves known to us when you access online services such as our website or app. We see how you as our returning user navigate our services on different occasions and what content you might be interested in.
- Pixels or tags are tiny graphics files that are downloaded when you interact with our online services. This will then alert us that you have opened an email, clicked on content or other action. These are typically used to capture interaction information and measure the relevance of our content.
- Tracking URLs are custom generated links that help us understand which page you come to us from and later go to.
- Local storage is used to more efficiently manage the temporary storage of information that allows you to access our services on your device.
- Digital fingerprint is used to recognise your device based on your device & browser data without relying on cookies.
Like most organisations with online presence, we use cookies and similar technologies to (as is further described in our "why" section):
- provide our services which is not possible without certain essential cookies;
- remember your settings and preferences to improve your experience, speed up your searches and recognise you when you return to our service;
- understand our online traffic through analytics tools;
- personalise our marketing and advertising by creating an advertising profile; and
- connect you with our social media features.
To accomplish this, we will, in certain cases, also link information from cookies and similar technologies with personal data held about you.
We will deploy cookies and similar technologies ourselves (first party cookies). However, our services may also include cookies and similar technologies deployed by third parties (third party cookies). Our cookies and similar scripts are listed below.
7. WHO IS YOUR PERSONAL DATA DISCLOSED TO?
We may share your personal data with the following third parties:
- Our service providers, business partners and advisors as required for the proper administration of our organisation or in the context of our services. In some cases, the service provider such as our payment processor will process your payment card data, and we will not store or collect your payment card data.
- The public if you interact with us on social media or as required by law
- Recruitment agent, your former employer or other person proving a reference about you
- Our business customer who pays for your access to our wellness platform receives statistical information derived from your personal data
- Tax authority, law enforcement and other authorities as strictly required by law or best practice
- Third party where ordered by the court or necessary in establishing, exercising or defending legal claims
- Another organisation in case of a merger, acquisition or collaboration
- Other third parties where you have provided consent
8. HOW DO WE SECURE YOUR PERSONAL DATA?
We have put in place appropriate organisational and technical measures to safeguard your personal data that we keep on premise and on our systems.
We seek to ensure our third-party service providers do the same. We only appoint service providers under an appropriate contract who provide sufficient guarantees about data security in accordance with applicable law. For example, our payment processor adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover.
No system is completely secure and we cannot fully guarantee the security of your personal data. We will deal with any personal data breach in accordance with our incident response procedure and will notify you and the regulator where we are legally required to do so.
Our staff undergo training on confidentiality and access to your personal data is restricted on a "need to know" basis.
9. HOW LONG IS YOUR DATA KEPT?
We will retain your personal data for as long as it is necessary for the purposes set out above or longer, as may be required by law, for legal claims or otherwise. By way of example, the following retention periods may apply.
|
Details of your enquiry |
One year from collection |
|
User details and wellness information |
Erased upon user instruction or user account deletion or within 2 years of user inactivity. |
|
Business opportunity information |
6 years from collection |
|
Job applications |
One year from collection |
|
Profile data |
2 years from collection. Your online behaviour which makes up a part of your profile data is often collected by using cookies and similar technologies. Please note that the lifespan of each cookie and similar technology used may differ. We use both session and persistent cookies. Session cookies only last until you close your browser. Persistent cookies are not automatically deleted when you close your browser and they recognise returning users. |
After the retention period, your personal data will either be securely deleted or anonymised, and it may be used for analytical purposes
10. WHERE WE STORE YOUR PERSONAL DATA
Generally, your personal data will be held in the UK. Wellness information is generally held within the customer organisation's region, for example, the EU.
However, we may use or make available tools which require the transfer of your personal data outside the UK such as the US. In these cases, we will satisfy ourselves that your data protection rights are adequately protected by appropriate technical, organisational and contractual safeguards in accordance with data protection laws before any such transfer.
11. OPT-OUT
- If you would like us to stop sending you marketing communications and to process your personal data for direct marketing purposes, please contact us.
- You can request to stop receiving our marketing communications at any time by clicking on the unsubscribe link at the bottom of each marketing message and we will add you to a suppression list or otherwise arrange that you no longer receive marketing communications.
- In relation to cookies and similar technologies, if you delete or clear data on your device, the next time you visit our online services our cookie consent banner will reappear, and you will need to select your preferences again. Remember that if you change your settings to exclude cookies in your browser or device but later request services by interacting with our service features (e.g. you click on a social media plug-in on our website), this may override your browser or device settings.
12. YOUR RIGHTS
Depending on your rights and our obligations under applicable data protection law, you may contact us in writing to:
- Request disclosure of your personal data held by us.
- Request correction of any inaccurate or incomplete personal data held by us.
- Withdraw consent previously provided to us in respect of your personal data.
- Request deletion of your personal data held by us.
- Request not to sell or share your personal data with third parties, particularly in the context of behavioural advertising.
- Exercise other data rights which we are bound to comply with.
Please contact us at 
if you wish to exercise your data rights. All requests will be processed without undue delay and no later than within one month. If we cannot process your request within this period, we shall explain why and process it as soon as possible thereafter.
Cookies and similar technologies. You can withdraw consent by changing your settings in our cookies consent banner. While we try to ensure that your choices are fully respected, this may not always be possible, particularly where third parties are involved. For this reason, aside from relying on your cookie choices, please also consider turning off the automatic download feature in your browser, as described at allaboutcookies.org; opting out from online interest-based advertising from companies that participate in opt-out programs through the Digital Advertising Alliance, the Interactive Digital Advertising Alliance, Appchoices or Network Advertising Initiative. We do not participate but some of our advertising partners may do; and opting out from third party services that deploy cookies and similar technologies, such as Google Analytics, by visiting www.google.com/settings/ads or by downloading the opt-out add-on at https://tools.google.com/dlpage/gaoptout.
What happens if I disable cookies? By disabling cookies, you may experience a reduced online service. For example, opting out of the placement of advertising cookies does not necessarily mean that you will not see advertisements – it means you will not see personalised advertising.
13. THIRD PARTIES MAY PROCESS YOUR PERSONAL DATA
Our wellness platform, website, content and features and services may involve the use of third party services, social media platforms such as Twitter and Facebook, or other third party services.
We may also share your personal data with third parties, such as payment services providers (such as our current provider Chargebee), performance measurement service provider (such as our current provider HubSpot), public authorities and others who process your personal data for their own purposes.
You should check the privacy statements of these third parties and we are not responsible for how they may process your personal data. Please note some of them may use your personal data for business administration, product development or advertising purposes.
14. CATEGORIES OF PERSONAL DATA
We process the following categories of personal data about you:
|
Business opportunity information |
Your personal and professional details as business customer and other opportunity records. |
|
Contact information |
including your home or business address, telephone, email and similar information. |
|
Details of enquiry |
Details of your enquiry, service request, job application or other communication. |
|
Profile information |
including your demographic information from our analytics and advertising partners, your preferences and interests known, observed or inferred by using analytics, advertising or other tools and sources including notes of your past interactions with us. |
|
Public information |
from public registers, databases, social media, the Internet and similar sources. |
|
Security information |
including activity data, network monitoring and logging data, antivirus scan, information in security logs and similar information. |
|
Special categories of personal data |
including your race, ethnic origin, religious or philosophical beliefs, sexual orientation, political or trade union affiliation and information about your health. |
|
Technical information |
including online identifiers, internet protocol (IP) address, details of operating system, browser type, language, time zone setting, location, date and time of access, local storage data, information necessary to connect your device with our wellness platform and similar information obtained from your device, browser, an API or similar source. |
|
Usage information |
including about how you navigate our wellness platform, completion of modules, views of our videos, connection with your devices, website downloads, clickstream data with URLs visited previously, webpage interaction, such as scrolling, clicks, and mouse-overs, methods used to browse away from our website, email open rates, click rates, view rates, active time spent, ‘likes’ on our social media pages and similar online activity information. |
|
User details |
including your name, email address, user credentials and similar information. |
|
Wellness information |
information provided by the user, collected or otherwise processed about the user of our wellness platform including information about lifestyle choices and habits, daily wellness activities and similar information. |
|
Your background information |
including your personal, professional and financial information obtained from you, public sources and third parties such as former employers, colleagues and similar information. |
15. LIST OF COOKIES AND SIMILAR TECHNOLOGIES
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.
16. FOR UK/EU INDIVIDUALS
a. PERSONAL DATA
“Personal data” means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b. YOUR RIGHTS
Subject to certain exemptions, limitations and appropriate proof of identity, you have the following rights in relation to your personal data:
- Right to information about matters set out in this notice. You may also contact us for further details about our data retention policy, international data transfers and other matters that are unclear.
- Right to make an access request to receive a copy of your personal data held by us.
- Right to rectification of any inaccurate or incomplete personal data.
- Right to withdraw consent previously provided, for example, your explicit consent to use your health data or your consent to include your wellness information in statistical records generated for the relevant customer organisation.
- Right to object to our processing of personal data based on our legitimate interests, such as objecting to your profile showing as online when you are using our wellness platform.
- Right to erasure of personal data that is no longer needed, for example, you can seek a deletion of your user account.
- Restriction on the processing of personal data.
- Right to human intervention in respect of any automated decision-making without human involvement that significantly affected you.
- Right to data portability from one service provider to another, where applicable. For example, you can instruct us to transfer your user details and wellness information to another provider of your choosing.
- Right to lodge a complaint with the Information Commissioner’s Office.
Please contact us at if you wish to exercise your data rights. All requests will be processed without undue delay and no later than within one month. If we cannot process your request within this period, we shall explain why and process it as soon as possible thereafter.
17. UPDATES TO THIS NOTICE
If we make any changes to our notice, you will be able to see them on this page, as indicated by the “Last updated” date at the top.
If any such changes significantly affect you, we will ask for your prior consent where we are required to do so by law.