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.
How to contact us
You can contact us by emailing: firstname.lastname@example.org.
Our Data Protection Officer
Your rights in connection with your Personal Data
Under certain circumstances, by law you have the right to:
How to exercise your rights
If you want to exercise any of the rights described above, please contact us at email@example.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.
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.
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.
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).
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.
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.
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:
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:
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.
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.
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.
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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
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.
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.
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.
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.
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.
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:
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.