This Privacy Notice was last updated on 5 January 2022.
Ownminder Limited (“Ownminder”, “we”, “us” or “our”) is committed to safeguarding your privacy. This Privacy Notice contains important information about how we collect, manage and use personal data when you make use of the Ownminder mental fitness app (the “App”) or visit the Ownminder website at https://www.ownminder.com/ (the “Website”).
For the purposes of applicable legislation, including the UK General Data Protection Regulation and the Data Protection Act 2018 (the “Data Protection Laws”), Ownminder is the “controller” of personal data collected through the App or Website. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Laws to notify you of the information contained in this Privacy Notice.
We may change this Privacy Notice from time to time. Please check back regularly so that you are aware of the most recent version and the date that it was last updated.
- Personal data we may collect via the App
We may collect personal data from you during your use of the App. This may include your:
- chosen language;
- responses to our in-App “Mind Fitness Check” questionnaire. As these responses will provide information indicative of your sense of mental well-being, the information that we collect is classified as “special category personal data” under the Data Protection Laws.
- responses to the Short Warwick-Edinburgh Mental Wellbeing Scale (SWEMWS) (a questionnaire developed to measure mental wellbeing, which we deploy via the App). The sensitivity of the information collected via this questionnaire means that it is also classified as “special category personal data”.
We will use the personal data that we collect in order to personalise your use of the App (including by prioritising the Mind Fitness Strength episodes and Mind Fitness tools that you are shown), to ensure that you receive the best quality user experience.
In accordance with the Data Protection Laws, our legal basis for collecting and processing your personal data is that the processing is necessary for the purpose of our legitimate interests in allowing you to sign up for an App account and providing you with the highest quality user experience.
In accordance with the Data Protection Laws, our legal basis for collecting and processing your special category personal data is that you have provided your explicit consent to its processing for the purposes described in this Privacy Notice. You will be asked to provide your explicit consent to our processing of your special category personal data when you first use the App.
Additional personal data may be shared with us by your employer for the purpose of providing you with the ability to sign up for an App user account (including your work email address, phone number and company name). Ownminder acts as a “processor” of this personal data until such time as you create an Ownminder account, at which point we will process this personal data as a controller in line with the lawful bases outlined above. In order to verify your identity, we will also ask you to provide this personal data directly. Please consult your employer’s privacy notice for further information on how it collects, processes and shares personal data with Ownminder.
- Personal data we may collect via the Website
When you contact us directly via the Ownminder Website
If you contact us by raising a query through the Website’s “Find Out More” page, we will collect your first name, last name, email, phone number, the name of your employer and any additional information that you provide to us within your query. We will use this information to:
- respond to your query;
- take any action that may be necessary with respect to your enquiry, and
- comply with legal obligations to which we are subject, or enforce our rights.
In accordance with the Data Protection Laws, our legal basis for collecting and storing information about you is that:
- the processing is necessary for compliance with a legal obligation to which Ownminder is subject, or
- the processing is necessary for the purposes of our legitimate interests in running Ownminder and responding to enquiries from clients, potential clients and App users.
When you contact Ownminder via social media
Ownminder maintains profiles on social media platforms, including Instagram, Facebook and LinkedIn. You can interact with us through these platforms, for example, by commenting on any information that we post. Links to our social media profiles can be found via the Website.
We may use the information that you provide to us in order to review and respond to any queries that you have.
In accordance with the Data Protection Laws, our legal basis for collecting and storing the personal data you provide to us is that it is necessary for our legitimate interest in operating Ownminder.
Cookies are small text files that are placed on your device by websites or apps that you visit. They are widely used in order to make websites and apps work, or work more efficiently, as well as to provide information to the owners of the website or app.
The table below explains the cookies we use via the App and why.
Google Analytics is integrated into the App and will collect data throughout the period during which you are logged in. These cookies are used to track the level of user traffic flowing to the App and may also be used to track installations, uninstallations and the sending of campaign notifications. These cookies collect information including your IP address, which may amount to your personal data.
Click here for an overview of privacy at Google.
We also utilise cookies to ensure the Website functions effectively. The table below explains the cookies we use via the Website and why.
We utilise WordPress cookies within the “member zone” of the Website. These cookies are used to store your Website authentication details upon login and will record who you are and when you are logged into the Website. These WordPress cookies are “session” cookies, meaning the cookie is available for the time a user is on a page or until their session expires.
Click here for more information on the use of WordPress cookies.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
On your first visit to each of the App and Website, you will be asked to accept or reject the use of the cookies on your device.
- Contacting you about in-App prizes
We may contact App users directly via email or SMS where your Mind Fitness Tank scores entitle you to a prize (your Mind Fitness Tank score will be determined according to your use of the App and the number of milestones that you reach). These communications are classified as “direct electronic marketing” under applicable data privacy legislation.
In accordance with the Data Protection Laws, our lawful basis for providing you with direct electronic marketing communications is that you have provided your consent to the receipt of these communications from Ownminder in respect of in-App prizes.
- Sharing your information
Upon using the App your personal data will not be shared with your employer. However, certain data (including your Mind Fitness Tank scores, details of the Mind Fitness tools you have completed, and your responses to the App’s Mind Fitness Check and SWEMWS questionnaires) may be shared with your employer on an aggregated, anonymised basis.
We will share your personal data with selected third parties including:
- Our suppliers and sub-contractors for the performance of any contract we enter into with them or you. For instance, the App utilises MySQL for the purpose of obtaining an effective database management solution. The App also utilises DigitalOcean for the purposes of obtaining cloud storage services.
- Analytics and search engine providers that assist us in the improvement and optimisation of the App. The App uses web tracking technologies provided by Google Analytics, as detailed above.
- If Ownminder merges with another organisation or forms a new entity, your personal data will be transferred to that new entity.
We will disclose your personal data to third parties such as courts, regulatory or law enforcement bodies, or our professional advisors if this is permitted by law and is necessary in order to:
- Comply with any court order or other legal obligation or when data is requested by our regulators or by government agencies or law enforcement agencies.
- Enforce or apply any agreement to which we are party.
- Protect the rights, property, or safety of us, our employees, our clients or others.
- International transfers of personal data
From time to time, we may transfer your personal data outside of the UK to service providers for the purposes described in this Privacy Notice. If we do transfer your personal data, we will put in place appropriate safeguards required by law. For example, we may use model contracts in a form approved by regulators.
We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Notice.
- How long will we hold your personal data for?
We will hold your personal data on our systems for as long as necessary to fulfil the purposes that we collected it for, as explained in this Privacy Notice, and for the purposes of satisfying any legal requirements to which we are subject. Where there are no such requirements, we will hold your personal data in a form which identifies you for as long as appears appropriate based on the amount, nature and sensitivity of the personal data and the potential risk of harm from unauthorised use or disclosure of your personal data.
- Your rights
You have rights in relation to the personal data we hold about you. These include the right to request access to your personal data, to request that it is erased, that its processing is restricted, or that any inaccurate personal data is rectified. You may also have the right to object to the processing of your personal data, or in some circumstances to obtain a copy of the personal data in machine-readable format.
If you would like to exercise any of these rights, please contact us using the details in the ‘Contact Us’ section below. We may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal data, and ensure that we are only releasing personal data to those entitled to receive it. Where we provide personal data to you (or someone else on your behalf), we will provide it free of charge except in exceptional circumstances.
If you have a concern or wish to complain about our processing of your personal data, you can contact us using the details below; if possible, please state “data protection” in the subject line of your email. You also have the right to complain to the data protection regulator, the Information Commissioner’s Office at: https://ico.org.uk/global/contact-us/. If you are not happy about the handling of your personal data, then we would encourage you to contact us first, so that we can try to resolve matters directly with you.
You also have the right to withdraw your consent to the processing of your personal data. You may withdraw your consent at any time by contacting us using the details in the ‘Contact Us’ section below. We will action all requests to withdraw consent as soon as we are able.
Please note that withdrawing your consent to the processing of your special category personal data (namely your responses to in-App questionnaires) will result in you losing access to your App account and Ownminder deleting all personal data relating to your account. Failure to provide this consent initially will also result in Ownminder being unable to provide you with an App account.
- Contact Us
If you have any questions regarding this Privacy Notice, wish to exercise any of your rights or wish to make a complaint, please contact us via email at firstname.lastname@example.org