Privacy Policy

LAST UPDATED: 3rd June 2020

What does this Privacy Policy Cover?

Unmind respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our platform, app and website (“Site”) and tell you about your privacy rights and how the law protects you.
‍

With that in mind, this Privacy Policy is designed to describe:

‍

This Privacy Policy aims to give you information on how Unmind collects and processes your Personal Data through your use of this Site, including any data you may provide through this Site.

The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.
‍

We will post any modifications or changes to this Privacy Policy on this page.

Who we are and how to contact us

Who we are

Unmind Ltd is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either “Unmind”, “we”, “us” or “our” in this Privacy Policy). Our address is: 180 Borough High Street, London, England, SE1 1LB

How to contact us

You can contact us by emailing: privacy@unmind.com.

Our Data Protection Officer

The GDPR requires us to appoint a “Data Protection Officer”, this is a person who is responsible for overseeing and advising us in relation to our compliance with the GDPR (including compliance with the practices described in this Privacy Policy). If you want to contact our Data Protection Officer directly, you can email: privacy@unmind.com.

Your rights relating to your Personal Data

Your rights in connection with 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 at privacy@unmind.com.
‍

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: privacy@unmind.com.
‍

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 ‘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

Identity Data

Contact Data

Marketing and Communications Data

Behavioural Data

Technical Data

User-Generated Data

What it means

First name, Last Name, email, location, department/team, employee number (or similar identifier provided by an employer if required), gender, and date of birth.

Email address, telephone number.

Your preferences in receiving marketing from us and your communication preferences.

Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into “segments” (e.g., there may be a segment for women, living in London and aged under 25, who like mindfulness).

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.

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 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 better understand whether and how use of our Site may improve your wellbeing. 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. Some non-exhaustive examples of why we may share Aggregated Data (i.e. anonymous data) is to demonstrate the average wellbeing of different sub-groups, identify patterns of poor sleep across varying geographic locations, and extrapolate whether use of the Site is more beneficial for some populations compared to others. In no scenario will the sharing of Aggregated Data contain personal information related to your Unmind account or any personally identifiable User Generated Data. We also use such Aggregated Data to better understand our end-users, to develop the Unmind offering, to create and distribute white papers, to conduct and publish research, and to share the data with health professionals and academics to improve Unmind and other services relating to mental wellbeing.

‍

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. Since you are able to upload details of your mood or mental state on the Site (e.g. through the “Check-In” option), the data you provide us may contain data relating to your health or other Special Categories of Personal Data.
‍

You do not have to submit such data in order to use the Unmind Site and access the content. You will still be able to access the content provided on the Unmind Site and use the Site and Unmind services, even if you do not provide such Special Categories of Personal Data.
‍

We may also anonymise your Special Categories of Personal Data in an Aggregated Data format to better understand our end-users, to develop the Unmind offering, to create and distribute white papers, to conduct and publish research, and to share the data with health professionals and academics to improve Unmind and other services relating to mental wellbeing. When sharing Aggregated Data we do not share any of your Personal Data (including any Special Categories of Personal Data).
‍

None of your Personal Data (including Special Categories of Personal Data) will ever be shared with your employer or any such organisation with whom you are similarly affiliated (e.g. academic institution, governing body).
‍

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 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 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 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

‍

Account Creation

Site Operation

‍
‍

Unmind Content Recommendation

Praise

Surveys

Aggregation for Research & Development purposes

Aggregation for affiliated or associated organisations (e.g. employers, academic institutions, governing bodies)

Fraud Prevention

Troubleshooting

Marketing

Categories of personal data involved

• Identity Data
• Contact Data

• Identity Data
• Contact Data
• Behavioural Data
• User-Generated Data
‍

‍
• Identity Data
• Contact Data
• User-Generated Data

‍
• Identity Data
• Contact Data

‍
• Identity Data
• Contact Data
• User-Generated Data

• Identity Data
• Contact Data
• User-Generated Data

• Identity Data
• Technical Data
• Contact Data

• Technical Data

• Identity Data
• Contact Data
• Marketing and Communications Data

Why do we do this

‍

To register you as a new user.

To provide you with the services offered on our Site (including technical support services), such as for example, “Insights” (helping you to track your wellbeing).

We do this through a smart recommendation engine, to provide you with recommended content from our Site, based on your profile, use of the Site and Unmind Index.

‍

To send you your colleagues’ praises.

To complete surveys and obtain data for research purposes and in an anonymised format (although you do not have to respond to such surveys).

In an anonymised format, to develop the Unmind offering, to create and distribute white papers, to conduct and publish research, and to share the data with health professionals and academics to improve Unmind and other services relating to mental wellbeing.

In an anonymised, aggregated format to demonstrate the average wellbeing of different populations, to identify usage patterns across and between sub-groups locations, to extrapolate whether use of the Site is more beneficial for some audiences compared to others. These aggregated reports do not contain Personal Data related to your Unmind account or any personally identifiable User Generated Data.

To keep our website, our services and associated systems operational and secure.

To track issues that might be occurring on our systems.

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 for you.

Our legal basis for this use of data

‍

Contractual Necessity.

Contractual Necessity, save to the extent your User Generated Data contains Special Categories of Personal Data, in which case we rely on the Healthcare Ground.

‍

Legitimate Interests.
We have a legitimate interest in ensuring that your experience on our Site is as tailored to your specific needs as possible so that the content you view in priority on our Site is most likely to be helpful to you.

To the extent your User Generated Data contains Special Categories of Personal Data, we rely on the Healthcare Ground.

Contractual Necessity.

Legitimate Interests.
We have a legitimate interest in understanding our end-users to develop the Unmind offering, to publish white papers and to share the data with health professionals and researchers.

To the extent your User Generated Data and data provided in surveys contains Special Categories of Personal Data, we rely on the Healthcare Ground.

Legitimate Interests.
We have a legitimate interest in understanding our end-users to develop the Unmind offering, to publish white papers and to share this anonymous data with health professionals and researchers.

To the extent your User Generated Data contains Special Categories of Personal Data, we rely on the Research Ground.

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.

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.

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 functionalities of the Site).
‍

In this case, we may have to stop you from using our Site or revoke your Unmind account but we will notify you if this is the case at the time.

Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Third party data source‍

Your Employer(s), academic institution(s), governing bodies

Analytics Providers

The provisioner of your “guest” account (where your Site access has been granted by a friend, family member, or peer)

Publicly available?

Categories or other types of personal data received

• Identity Data
• Contact Data

• Behavioural Data
• Technical Data

• Contact Data

How we use cookies & other tracking or profiling technologies

Cookies.

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 cookie

Your Employer(s) academic institutions, governing bodies

Functionality Cookies

Analytics and Performance Cookies

Purpose

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.

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.

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.
‍

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.
‍

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, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on the Site may also use HTML5 to collect and store information.

Disabling Local Storage

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your mobile phone. This software may record information such as how often you use the Site, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link the information we store within the analytics software to any personal information you submit within the mobile application.

Log Files

As true of most websites, 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.

Recipients
‍

Service Providers

Professional advisers

HM Revenue & Customs, regulators and other authorities

The provisioner of your“guest” account (where your Site access has been granted by a friend, family member, or peer)

Why we share it

Our service providers provide us with IT and system administration services.
‍

Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services.

Authorities may require reporting of processing activities in certain circumstances

To maintain and validate your “guest” account access we may need to inform the provisioning account holder of any changes you make to your primary email alias or if your account is deleted for any reason.

Data transfers
‍

Some of the third parties with whom we may share your Personal Data are based outside the UK and European Economic Area (“Europe”) so their processing of your Personal Data will involve a transfer of data to countries based outside of Europe.
‍

We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We may 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.

• Where we use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.

• Where we use service providers based in the U.S., 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 Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
‍

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Europe.

‍

How we keep your Personal Data secure

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
‍

We limit access to your Personal Data 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 Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
‍

We are currently hold Cyber Essentials and Cyber Essentials Plus certifications and are expecting ISO 27001 certification in Q2 2020.

How long we store your Personal Data

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out in this policy, unless a longer retention period is required by law (for example for regulatory purposes).
‍

The table below shows our standard retention practices:

‍

Category of Personal Data

• Behavioural Data

• Marketing and Communications Data
• Technical Data

• Contact Data
• Identity Data

• User-Generated Data

Retention period

Two months from the date on which we collected or received it.
‍

For so long as you have anAccount with Unmind or our Site(s).

‍

For so long as retention is necessary to fulfil the Purposes/Use for which it is used.

For so long as you have an Account with Unmind or our Site(s).

Our policy on children

This Site is not intended for children below 16 and we do not knowingly collect data relating to such children. You should not use the Site if you are below 16.

‍

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.
‍

‍